Steve:  

I agree with the BC’s position that "if the JAS WG’s recommendation serves to give one applicant an advantage over another by providing discounts for various parts of the review process is antithetical to ICANN’s impartiality.  Once an application is submitted, each and every applicant must face the same processes and costs established in the AG to ensure a fair and equitable procedure." 

In the draft, we seem to deal with this concern in certain circumstances, but not explicitly when considering actual application fee reductions.  An applicant that gets a fee reduction shouldn't be able to use such "saved" funds in an auction against an applicant who didn't get a fee reduction.  

The benefits for applicants should be limited to only qualified entities and only to support their applications, not to give them an unfair competitive advantage against another applicant for the same string.  A system that gives one party a competitive advantage over another is a big invitation to gaming.

I offer two changes to this effect in the attached.

Thanks.

Jon