Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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The attached letter serves as the public comment of Arif Ali, John Murino, Michael Palage, Flip Petillion, Mike Rodenbaugh, & Jan Janssen on the Proposed Revisions to the ICANN Documentary Information Disclosure Policy, submitted in lieu of completing the public comment form. A summary of the attached letter is provided in the "Summary of Submission" section of the public comment submission.
We submit our comments on the Revised Policy because the policy raises significant concerns about ICANN’s commitment to transparency. ICANN has obligations towards the Internet community, such as operating “for the benefit of the Internet community as a whole” and “to the maximum extent feasible in an open and transparent manner[,]” and employing “open, transparent and bottom-up, multistakeholder policy development processes.” In line with its commitment to transparency and other commitments, ICANN formed a working group to enhance ICANN accountability; the group published a final report with recommendations intended to improve ICANN’s transparency regarding its Documentary Information Disclosure Policy (“DIDP”). The Revised Policy fails to effectively incorporate these recommendations and instead contains troubling revisions to the DIDP that significantly compromise ICANN’s transparency commitments.
First, the Revised Policy rejects Recommendation 8.1.17 by failing to incorporate provisions for the disclosure of documents in redacted or severed form. To “operate to the maximum extent feasible” in a transparent manner, ICANN should provide for the disclosure of documents to the greatest degree possible by disclosing documents with information subject to Nondisclosure Conditions in redacted or severed form.
Second, the Revised Policy rejects Recommendation 8.1.18 by removing ICANN’s obligation to “provide a written statement … identifying the reasons for the denial” of a DIDP Request and by not requiring that ICANN identify the rationale for a decision. Such a change does not improve or enhance the DIDP and instead results in less transparency than the current DIDP.
Our comment urges ICANN to reject the proposed Revised Policy as it is presently drafted and incorporate language reflecting Recommendation 8.1.17 and 8.1.18. To act for the public benefit and operate with transparency, ICANN must not further inhibit attempts to obtain information about its processes.