As a website owner, I regard the proposed Amendment 3 with considerable alarm.

There has been an ongoing global movement to make the web less accessible, ranging from attacks on net neutrality and the imposition of onerous regulations. Now, ICANN proposes to exacerbate that problem with a substantial price increase on the most commonly used commercial domain while asserting that this usurious increase is somehow “in the public interest.” That assertion runs directly contrary to any common sense; the net effect of the change would be to further squeeze small businesses and small operators, who are already at the greatest risk of loss in the present web climate.

I take further issue with the assertion that by structuring the increases to encourage registrants to register or renew for multi-year periods constitutes “registrant protection,” given that the entities from which registrants need such protection are the very ones proposing the rate hike. That is a remarkably cynical framing of what mainly seems like an effort to drive an increase in short-term revenues. That may be in ICANN’s interest, but it’s certainly not in the interests of registrants or the public. Many small operators, including myself, cannot afford to purchase a decade’s worth of services in advance to secure some discounted rate; the costs of poverty are a well-known economic reality. It is not that people or businesses of modest interest don’t recognize the opportunity for savings, it’s that they are simply out of reach.

The amendment alludes to ICANN’s concerns about security and stability, which are of course worthy goals. If ICANN could demonstrate that certain price increases would be necessary to achieve specific technical or regulatory compliance goals, I and the rest of the online community might regard the proposal with greater sympathy. Instead, the proposed text buries vague promises in noncommittal language: We are told Verisign and ICANN will “work in good faith” and “define … requirements” for potential future improvements.

The way this reads to the layman is that the parties are determined to raise rates now and will take their time in coming up with reasons to justify it, with no promises that the substantial increased costs will yield any tangible benefit. Moreover, the emphasis on encouraging registrants to renew for multiple years suggests that we can look forward to future rate hikes, again with only the haziest promise that it will yield any benefits to the security, stability, or integrity of the web.

I think it would be appropriate for ICANN to consider carefully its role and responsibility in the modern online world. For example, does ICANN believe it is in the public interest to preserve the accessibility of the web as well as its technical stability? Does ICANN wish to forestall the danger of the Internet being steadily reduced to a handful of channels controlled by a few large corporations, like cable television? If so, you should reconsider this amendment and the proposed rate increases, because they work directly against those ends — and against the public interest.

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