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Re: [soac-newgtldapsup-wg] WT 1 Fees-lower up front fee

  • To: Elaine Pruis <elaine@xxxxxxxxxxxxxxxxxxxx>, Evan Leibovitch <evan@xxxxxxxxx>
  • Subject: Re: [soac-newgtldapsup-wg] WT 1 Fees-lower up front fee
  • From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
  • Date: Tue, 18 May 2010 13:39:13 -0400

Having been part of the process for some 3 1/2 years now, this is just one of the issues where a staff decision was made, and for whatever reason was not changed. Today, staff do a much better job of explaining why such suggestions are not implemented. At the time Evan is referring to, we tossed things over stone walls and never heard back.

In the cost document, the "This approach avoids a situation..." seems to be making sure that the applicant does not shoot itself in the foot by suddenly not having the required payment. I think that your analysis is spot-on.

I suspect there are more of these gems buried in the documents - policy decisions that do not impact cost recovery, but have the (presumably) unintentional result of favouring cash-rich applicants.


At 18/05/2010 01:21 PM, Elaine Pruis wrote:
Thanks Evan. Its a concept that has been kicked around in various circles, so why hasn't it been adopted? Do you have any feedback from the correspondence? What arguments do we need to debunk to carry this forward?


On May 18, 2010, at 10:11 AM, Evan Leibovitch wrote:

On 18 May 2010 12:45, Elaine Pruis <<mailto:elaine@xxxxxxxxxxxxxxxxxxxx>elaine@xxxxxxxxxxxxxxxxxxxx> wrote:
Continuing the thread from yesterday's call.

Richard suggested that applicants that meet specific criteria for assistance may benefit from not having to pay the entire fee up front.
The language from the cost analysis paper is

"– ICANN will collect the entire application
evaluation fee at the time an application is submitted. This approach avoids a situation in which the applicant partially completes the application process, then may not have
the resources to continue. It also ensures that all costs are covered.

The ALAC response to this (which I reproduce verbatim from within the gTLD-related statement produced at the At-Large Summit in Mexico City) is:

In the place of the proposed system of refunds, we recommend a phased fee system under which an applicant would pay a portion initially and additional fees as each milestone is achieved. While ICANN will still be paid up-front for its evaluations, applicants only need pay for the stages which they are eligible to pursue.

(Page 14 of <http://www.atlarge.icann.org/files/atlarge/correspondence-05mar09-en.pdf>http://www.atlarge.icann.org/files/atlarge/correspondence-05mar09-en.pdf)

I don't see why this approach is any less valid now than it was at the time of the Summit. Each application will already be subject to review regarding its financial stability and sustainability. There is no need to use the fee structure to impose a crudely Darwinistic barrier to all but the best-funded applicants.

Besides the benefits Elaine mentions, a graduated payment system also eliminates the bureaucracy needed to evaluate and process refund requests.

- Evan

Elaine Pruis
VP Client Services
+1 509 899 3161

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