I submit my views as under:

1.The process of challenging a policy should not be hit by time-bar. If it is very strongly felt that a fixed time limit is necessary, a period of minimum 5 years should be allowed.


2.The Independent Review Process IRP has to protect not just the contracted parties [ mostly commercial] but also Registrants so that the scope of legislation is expanded in the interest of non-commercial users and ICANN at large.  

3. 'Policies' should be brought within the ambit in addition to 'implementaitons' which will give a chance to Registrants of 'being heard' and upholds principles of natural justice.

4. A minimum of 90 days should be given to Registrants to file an IRP Challenge to the Policy.

yours sincerely
 
Gangadhar Panday
President, Babul Films Society NGO Nonoprofit
www.babul.ngo - Videos and ICT for Eco-awareness


On Tuesday, 10 January 2017 7:42 AM, Edward Morris <[log in to unmask]> wrote:


Hi Milton,
 
Thanks very much for this blog post. In our rush to meet deadlines I'm not sure we thought through clearly enough some of the specifics of our accountability mechanisms. We've changed the nature of the IRP from being an arbitration device to being a quasi-constututional court. Yet in areas like statutes of limitations we've kept rules more applicable to commercial arbitration proceedings than to the new broadened remit of the IRP.
 
An extraordinarily well done and important blog post. Public comments are due on 25 January for the IRP Supplemental Procedures report. Hopefully we can get multiple comments submitted by NCSG members.
 
Kind Regards,
 
Ed Morris
 
 
 
From: "Mueller, Milton L" <[log in to unmask]>
Sent: Monday, January 9, 2017 8:48 PM
To: "[log in to unmask]" <[log in to unmask]>
Cc: "[log in to unmask]" <[log in to unmask]>
Subject: [NCUC-DISCUSS] My views on the supplementary rules for the Independent Review Process
 
This blog post takes a seemingly legalistic and obscure set of rules and shows how it is very important for the ICANN accountability reforms. My comments are intended to help NCSG develop public comments on the IRP rules, hope people can follow up. We still have time to fix the problem if we act. http://www.internetgovernance.org/2017/01/07/putting-your-rights-on-the-clock-the-irp-supplementary-rules/ Dr. Milton L Mueller Professor, School of Public Policy Georgia Institute of Technology Internet Governance Project http://internetgovernance.org/ _______________________________________________ Ncuc-discuss mailing list [log in to unmask] http://lists.ncuc.org/cgi-bin/mailman/listinfo/ncuc-discuss