I have incorporated the legal analysis from Sidley Austin LLP into our public comments. Gratifyingly, their legal analysis of the supplementary IRP rules totally supports our concerns about the time limits. 
One question for the crowd: I got my hands on the Sidley comments in my email box - are these comments posted anywhere so the NCSG comments can link to them? 

Thanks to all of you who contributed to these comments. I have now edited them, accepting most of the amendments proposed by members and adding a title and such. I would ask the Policy Committee to do what it needs to do to conclude the filing of these comments. 
https://docs.google.com/document/d/1TMI2n_EgBDVTSUZm2Xwl7SSHWks9Hz076NQGfsXxqso/  

Dr. Milton L Mueller
Professor, School of Public Policy
Georgia Institute of Technology
Internet Governance Project 
http://internetgovernance.org/