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This ICANN comment period is a Kafkaesque nightmare

Kevin Murphy, September 29, 2020, 17:38:37 (UTC), Domain Policy

With the deadline for commenting on draft new gTLD program rules rapidly approaching, you may be tempted to visit the ICANN web site to peruse the comments that have already been submitted by others. Good bloody luck.

The way ICANN has chosen to present the comments is so bafflingly opaque, confusing and confounding that I can’t help but conclude it must have been deliberately designed to be as soul-crushing as possible.

Regular comment periods are pretty straightforward: you email your comments as prose to ICANN, ICANN publishes the email and any attachments for others to read. Everyone knows where everyone stands. Job done.

But recently there’s been a worrying trend towards a questionnaire and spreadsheet model based around Google Docs, and that’s the model being used for comments on the final draft report of the new gTLD program working group, known as SubPro.

You can check out the spreadsheet here.

The first thing you’ll notice is that the spreadsheet is 215 columns wide, with each respondent given one row for their responses.

You’ll also notice that the spreadsheet doesn’t seem to understand line breaks. Where the respondent has provided some textual commentary, it’s spread across multiple columns in some cases and not in others.

And then there’s the column headings.

While stumbling randomly through the spreadsheet, I discovered an interesting nugget of information — it seems the new gTLD registry MMX wants the next application round delayed until all of the 2012 round have been launched, which I found a bit surprising.

This nugget can be found under the column heading “Enter your response here”, a heading that is helpfully shared by 90 (ninety) other columns on the same damn page.

The heading “Do you want to save your progress and quit for now? You will be able to return to the form to complete it at a later time” appears 10 times in the document.

No information in adjacent columns sheds any light on what triggered MMX to make its comment.

In order to figure out the question for pretty much any response, the only option appears to be to cross-reference the spreadsheet with the original form questionnaire, which can be found as a PDF here.

But the questionnaire has 234 questions and there’s no straightforward correlation between the question number and the columns on the spreadsheet, which are addressed as AA through IG.

So when you see that European industry group CENTR went to the trouble to “Support Output(s) as written” in column DI, under the heading “If you choose one of the following responses, there is no need to submit comments”, it’s virtually impossible to figure out what it actually supports.

If you are able to figure out which question it was answering, that probably won’t help you much either.

The form merely contains brief summaries of changes the working group has made. To see the “Output(s) as written” you’d have to cross-reference with the 363-page draft final report (pdf).

A lot of you are probably thinking that I should just export the spreadsheet into Excel or OpenOffice and clean it up a bit. But, no, you can’t. ICANN has disabled exporting, downloading, and even copy-pasting.

It’s enough to make one feel like going out and licking the floor on public transport.

Way to go on the transparency, ICANN!

I have to believe that the ICANN staffer responsible for compiling all these comments into the official ICANN summary has some tools at his or her disposal to render this mess decipherable, because otherwise they’ve got a huge, hair-ripping job on their hands.

Of course, since there doesn’t appear to be a way for the rest of us to verify the summary report’s accuracy, they can probably just write whatever they want.

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Comments (7)

  1. Sheri Falcon says:

    To provide context for MMX’s comment referenced above, MMX agrees that the next round should be predictable and at a date certain but given there are still outstanding TLDs not yet delegated from the 2012 round and given there are substantive rights and procedures not yet established for the 2012 round (e.g., voluntary PIC revision opportunities, CPE matters, etc.) – we feel it is premature to open the next round of applications until those issues are resolved.

  2. Jeff Neuman says:

    Thanks for the comments Kevin. I agree that the outputs are difficult for anyone other than ICANN to export into its public comment tool which will be distributed to everyone.

    We are told that using the Google Survey Form makes it much easier for ICANN to create its summary report. But yes until that happens it does make it hard for everyone else to see the responses.

    That said this is not a deliberate attempt to hide the responses. I raised the same issues initially as well. We are still experimenting with different forms, but this feedback is helpful. If you believe that anything in the comment summary we produce is inaccurate, you can write to me personally and I will look into it.

    Thanks for doing everything you do and looking forward to hearing your thoughts.

    Jeff Neuman
    SubPro PDP Co-Chair

    • Kevin Murphy says:

      Thanks Jeff.

      I wonder if there’s some kind of hybrid solution that can serve both ICANN’s efficiency needs and the community’s transparency needs.

  3. mark svancarek says:

    “That said this is not a deliberate attempt to hide the responses.”
    Well, it’s not a deliberate attempt to reveal the responses, either.

    • Jeff Neuman says:

      Its a deliberate attempt to make it as easy as possible to produce a public comment report for the working group and the community. Yes, it means that we need to wait a little longer, but on balance, the WG leadership team believed (and continues to believe) the balance tips in favor of using the Google Form.

  4. Jeff Neuman says:

    Kevin – We (the Leadership Team) have made similar requests and we are told that ICANN is looking into it for future pdp comment periods.

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