Oppositon to proposed changes
I am writing to respectfully voice my objections to the proposed changes as written.
I can only assume, despite the timing and lack of publicity surrounding these proposals, that the intent behind them is honorable. However, the wording of these documents presents a slippery slope that leaves the system open to abuse and to pricing practices detrimental to organizations, small businesses and other interests lacking unlimited funds in their domain budgets:
1) Removal of the price caps could lead to a scenario where established organizations and businesses with "desirable" names would be effectively forced to relinquish the domains upon which they have build their brand, due to inability to plan for or afford the increased renewal fees.
Small businesses, organizations and individuals stand to be the most heavily affected by the increases in domain renewal and registration prices which removing the price caps would allow. They are the ones most likely to have their websites and livelihoods running on .org, .info or .biz domains.
2) Removal of the price caps could also set the stage for a form of censorship, whereby websites with content or political viewpoints which the registry found objectionable could, in theory, be priced out of business.
3) The provision allowing for "making commercial use of, or collecting, traffic data regarding domain names or non-existent domain names" for purposes which include "promoting the sale of domain names" is also deeply troubling for the reasons stated above. Will traffic data be used to set renewal prices? Non profit organizations frequently have sites which see a good amount of traffic yet are run by volunteers and on a tight budget.
Furthermore, I fail to see any justification as to which shortcomings in the current system make these changes necessary.
I respectfully ask that you reconsider and remove the objectionable clauses regarding lifting of price caps, tiered/variable pricing, and the collection and commercial use of domain traffic data from these contracts.