Comments on Introduction to New gTLDs Application Process, section 1.5, Fees and Payments
We've made prior comments, as have others, on the issues of fees and payments. We commend staff for its work incorporating our suggestion for the annual fee, which, in the v1 text, presented the greatest threat to ongoing operations by registries. We would like to see the estimated cost breakdown for the functional boxes in the process flow chart. The $185,000 fee is too high for well crafted responsible applications brought by experienced applicants with registry operations experience and resources, but we've no way to show this unless we can put costs on the boxes avoided, on the contention paths not taken. We appreciate the adverse assumptions about applicant behavior, application quality and registry operations, that are implicit, or explicit, in both versions of the GFA, but low cost to process applications should not subsidize high cost to process applications, and it is in the present round applicants' interests, as well as future round applicants interests, to know the real cost of their application, and it is in staff's interest to manage the applications with a process who's costing staff understands. In sum, publish a first guess at the major element costs and rephrase the application fee as some sufficient initial commitment, and a variable fee corresponding to the choices the applicant knowingly makes to get the outcome the applicant knowingly seeks, similar to the way the RSTEP costing is handled. I work for CORE, CORE will submit applications, so this interest in the outcome should be included in my comment. Eric Brunner-Williams |