ICANN’s garbage public comment system

Despite my misgivings about the sham that is the comment period for the Phase 1 Initial Report of the Review of All Rights Protection Mechanisms in All gTLDs Policy Development Process which I’ve written about in the past 4 blog posts, I attempted to continue to submit my comments today, which I had already started over the weekend (already more than 20 hours invested, to get to about 25% through the various questions, including background research and reading the report, etc.). However, the comment system is entirely broken.

Using a provided link, I should have been able to resume where I left off. But, advancing through the pages, I hit a roadblock, as the system said “Your response is too large. Try shortening some answers.” This didn’t make any sense at all, given I had already submitted those answers over the weekend successfully. Furthermore, the system didn’t highlight which answers were too long! Even worse, when I went back to earlier pages, and then attempted to go back to page 3, somehow all of the previously saved answers just disappeared (despite still being visible on the public spreadsheet of submissions).

Fortunately I had a backup of my previous responses, so I wasted 30 minutes copying/pasting them all back on page 3, and saved my work again. Then, when I went back to edit again, to try to advance to page 4 (of the 11 page form!), what message did I receive? Again with the “Your response is too large. Try shortening some answers.” It felt like Groundhog Day, albeit with none of the charm or comedic elements.

This is definitely a reproducible bug in their system, and not something I’ve done wrong. I’m relatively technically competent. How is an “average” or “typical” user supposed to deal with this system?

ICANN’s CIO blogged recently about “Best-of-breed software” — however this comment system is definitely not “best-of-breed”. I should be able to save/resume responses with ease, and not have to deal with a horrible interface for viewing submissions by others. It’s designed to make things easier for ICANN staff, rather than for members of the public who wish to make thoughtful comments. Instead of making the system as accessible as possible, it’s designed so that only the most motivated “insiders” will put up with its limitations and who will expend enormous resources to overcome the obstacles of commenting. And, as I pointed out previously, it’s completely blocked in countries like China.

But, don’t take my word for it, here’s what ICANN’s SSAC said when the system was first used, for the EPDP on WHOIS in late 2018:

The new comment mechanism only allowed a predetermined subset of feedback, limited by what questions were asked and how they were asked. The form was ill-suited for providing feedback about higher-level issues, or about topics found only in the body of the report. We also have comments relevant to specific recommendations but found that our comments did not line up with any of the specific question/response fields. Ultimately we feel that this experiment was not entirely successful and is not yet refined enough to be used as a model for ICANN public comments. [footnote 3, page 3]

That’s the diplomatic way of saying it’s garbage.

ICANN should:

  1. extend the public comment period by 30 days (as Kathy Kleiman noted the precedent by others)
  2. bring back the standard email comment periods, that have proven the test of time, and which are used by other organizations, including the NTIA

I have written to ICANN staff to disclose the above problems, but have yet to receive a response.

Additional Notes: After not hearing from ICANN staff, I did some additional research on the Google Support site (why should I be debugging ICANN’s systems, by the way, when they are getting paid for this, and I’m not?), and found a thread which mentions an apparent global limit of 32,700 (or 50,000) characters for form submissions.  This makes the system
essentially unusable when you have very long forms, say if you have
responses spread out over 11 pages and nearly 200 questions! (look at
how many columns there are in the spreadsheet!!!)

Perhaps folks will not hit that limit if they limit themselves to repeatedly saying “Great work, guys” or “I agree with the comment submitted by Renee Fossen on behalf of Forum” (!!), but others with more substantial input would hit that limit (I’ve already apparently hit some limit on page 3, and haven’t even gotten to the long comments for later questions on pages 4 through 11 of the form, which I can’t even see as I can’t get past page 3 now).

In conclusion, I think ICANN will need to start over and do a complete reboot of the public comments period, as the system isn’t going to scale properly for longer surveys with detailed answers. No one apparently bothered to test things.