[soac-newgtldapsup-wg] DAG, v4 - other comments related to our work

[Karla Valente <karla.valente@xxxxxxxxx>]

Dear all,

I would like to share with you some of the DAG, v4 public comments received 
that are somehow related to our work. This is not the summary analysis I sent 
earlier today, which was specific to our public forum. I am just sharing this 
with you to give you an idea what is being said.

Kind regards,

Karla



Fee Issues

Fee standards-developing and undeveloped countries. Huge fees ($185K evaluation 
fee, US$70K-$122K and US$32K-$56K for the M&PO and community objections 
respectively) would stifle the initiative of developing and undeveloped 
countries and dampen globally balanced development of the Internet. ICANN 
should be able to set a fee standard based on the costs and adopt a favorable 
fee policy for the developing and undeveloped countries. ISC (21 July 2010).

Discounted fees--IDNs and Exact String Translations.
ICANN should significantly decrease application fees for exact translation 
equivalents of the same TLD to reflect the effort the evaluating team would 
require to process the applicant. If all TLDs fall under the same applicant, 
community, business plan, string, backend registry, etc., then ICANN does not 
need to spend additional time repeating the same evaluation step needlessly 
since economies of scale/scope are reasonably justified. .MUSIC (20 July 2010). 
dotKoeln (22 July 2010).

Each community-based applicant should be allowed to increase their utility 
within their specific community by having the option to apply for their 
respective IDN-equivalent TLDs for a nominal additional fee (per IDN or 
translated equivalent). It would not be justified to ask a community based 
applicant to pay an additional $185K for each translation to the approved 
string. BC (26 July 2010).  R. Andruff (Module 1, 21 July 2010).

Different fee models for different types of TLDs.  Given the high fees and 
costs associated with applying for and operating a new gTLD, ICANN should 
consider setting up different fee models for different types of TLD 
applications to alleviate the costs on applicants. A sensible fee model will 
greatly enhance the chance of success for the new gTLD process. CNNIC (21 July 
2010).

Reduced fees for small cities, small cultural and linguistic community TLDs.
Special consideration, including reduction of the $185K application fee and 
$25K annual fee, should be given for small cities and small cultural and 
linguistic communities which do not intend to compete with general commercial 
TLDs such as .com or new brand TLDs and for whom the current level of fees is 
not affordable.  It is understood that a lower but appropriate application fee 
is still needed in order to prevent excessive applications. JIDNC (21 July 
2010).

Special consideration regarding technical requirements and fees for developing 
country applicants representing cultural, linguistic and geographical 
communities is appropriate and consistent with the advice of the GAC in its 
Brussels communication. A. Al-Zoman (21 July 2010). Arab Team (21 July 2010).

Reduced fee for bundled variants.  ICANN should provide for a lower fee in the 
case where the TLD names are not chosen but are pre-existing (e.g. geographical 
names, many of which have more than one common name including IDN variants). 
Charging $185K for each variant seems punitive and unfair. Minds + Machines (21 
July 2010). Bayern Connect (21 July 2010).

Reduced application fee--.brand and charitable organizations.  The application 
fee is too high and could be discriminatory against certain types of applicants 
such as .brands restricted to employees of a company or charitable 
organizations. Such applicants should be eligible for a lower fee. Hogan 
Lovells (21 July 2010).

Application fee level is generally appropriate. The $185K fee is likely to be a 
realistic average estimate of ICANN's costs to manage the program. Substantial 
changes to the new TLD process as described in DAGv4 could result in an 
increase in the fee. I support practical ways to reduce costs for the discrete 
group of applicants in need, especially those from developing countries. R. 
Tindal (21 July 2010).

Terms of payment-exchange rate.  The following is suggested as addition in 
DAGv4 after section 1.5.4:  "Section 1.5.5-Terms of payment: Payment to ICANN 
may be effected in USD or in the legal currency of the applicant's country. If 
the applicant decides to use his local currency for processing payments, the 
exchange rate used shall be the one which applies on the day the applicant 
registers with TAS (refer to paragraph 1.5.1.)."  This section is justified 
because the risk of exchange rates should not be borne by applicants alone, but 
shared with ICANN. It may be fair for ICANN to acquire financial products to 
hedge this currency risk, rather than each and every applicant having to 
provide this insurance on its own. E. Blocher (Module 1, 5 June 2010).

Registry fees-not for profit organizations.   ICANN should determine its actual 
annual costs for maintaining each registry and consider a pricing structure for 
not-for-profit organizations that will ICANN to recover its actual costs 
without imposing additional overhead on the not-for-profit registry operators. 
AAMC (21 July 2010). Red Cross (21 July 2010). NPOC-FC (21 July 2010).

Registry operations-education and training. ICANN should provide greater detail 
and instruction regarding the technical requirements for operating and 
maintaining a registry, and should provide education for organizations such as 
not-for-profits that are new to ICANN activities. AAMC (21 July 2010). Red 
Cross (21 July 2010). NPOC-FC (21 July 2010).

Developing countries applicant support working group-support for initiative 
Developing country non-profit applicant financial support efforts by ICANN, 
where the applied for TLDs are for the public good, are welcome, and should 
include reduced fees for application, evaluation and the annual contract. For 
proposed gTLDs financially sponsored by certain governments, ICANN should 
consider the government's financial support commitment in place of the 
irrevocable standby letter of credit or deposit into an irrevocable cash escrow 
account, since some governments are reliable enough to guarantee sustainable 
operation of the registry(s). DNSSEC cost burdens should also be reduced and 
the application process should be made more accessible to global stakeholders. 
ICANN should provide document translations and conference simultaneous 
interpretations in six UN languages which may also help reduce costs for 
non-English speaking applicants. As for technical support,  DNSSEC support is a 
necessity. CONAC (22 July 2010).