April 2019 - comments-org-renewal-18mar19@icann.org

[Comments-org-renewal-18mar19] Costs do not increase that fast!
by Warren Gish April 28, 2019

April 28, 2019

The current limit to a 10% increase in registration fees per year is surely beyond the actual cost increases for managing .org. But you may have heard the saying, “Nonprofit doesn’t mean no profit!” PIR should be taken to the woodshed for seeking such over-profitability when managing the singular, precious, original .org TLD. If they don’t like the job, please hand it over to someone else who would!

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by John Starich April 28, 2019

April 28, 2019

I am a .org registrant. ICANN does not seem to recognize the difference between a legacy extension created with the support of the US government, that predates the existence of ICANN and that has millions of existing users and the brand new extensions that started off with a new set of rules, in particular no price controls, and no existing registrants. They have completely different characteristics, history, and ownership structure. It is not acceptable for ICANN to ignore these differences and to propose that they be treated the same. Removing price caps is not fair to .org domain owners. Many of them have websites that they have used for years. If price caps are removed, the cost to renew their domain names may become too expensive, and they could be forced to give up websites that are important to them. The Uniform Rapid Suspension policy is too new and untested to apply on domain names that may be 20 years old or more. With the URS, the domain names could be taken down in a matter of days with little notice. ICANN should be doing more to protect owners of .org domain names. Why is ICANN trying to remove price protections for .org domain owners, so many of which are non-profits, so that they can be overcharged for their domain names? Thank you, John Starich

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Joshua Bonsu April 28, 2019

April 28, 2019

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[Comments-org-renewal-18mar19] Maintain the Guardrail
by Jay Chapman April 28, 2019

April 28, 2019

The purpose of the price guardrail is more relevant than ever today - when current organizations utilizing .org are folks with longstanding online brand, identity, and/or location via their .org domain names. It's a deep, intrinsic value. Like other legacy domains, a .org domain name is hardly an easy-come/easy-go commodity service such as deciding who your mobile phone provider is every couple of years. These domains are people's pre-existing property. Countless people work on the ground with, support and volunteer for small businesses and organizations - hardworking ones with worthy missions, whose hearts are large and budgets are not. The thought that cost concerns might be mitigated by locking in present rates for 10 years might lessen an immediate sting, but substantively kicks the can down the road, and could be a huge issue regardless of when. While possible that the registry might not raise prices, people and attitudes within the registry (board, management and/or operators) might change. And without guardrails, a registrant/business/organization's online identity, brand and/or location could be thrust into chaos in short order. For an organization who's goal is stability, reliability and security, ICANN should avoid such a tumultuous prospect. ICANN's critical responsibility as overseers suggests it avoid taking precarious bets on behalf of registrants/businesses/organizations (and the exponential number of beneficiaries of those organizations). The fact that the .org registry has had the opportunity to raise prices up to 10% per year but has not always done so is, indeed, admirable - and it is also another strong indicator why the guardrail should stay in place. Clearly, the registry works quite well within its current structure. Ultimately, the existing pricing structure for the .org registry (and the other legacy tlds) is a necessary guardrail - it protects the public, registrants, the registries and the internet as a whole - including ICANN itself and the community. It provides stability and security. It aligns with ICANN's mission. Thank you. Sincerely, Jay Chapman Digimedia.com, L.P.

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[Comments-org-renewal-18mar19] Personal Comments of Ayden Férdeline on the Proposed Renewal of .org Registry Agreement
by Ayden Férdeline April 28, 2019

April 28, 2019

To Whom It May Concern: I am submitting this comment in my personal capacity as a domain name registrant. I have two concerns regarding the proposed changes to the .org Registry Agreement. Firstly, I strongly oppose lifting price caps on .org domains. I would not object to the current price cap being raised by a reasonable figure of up to 10 percent, however a price cap must remain in place in order to offer registrants protection from exploitation. I make this comment generally and I am not insinuating that the Public Interest Registry would seek to exploit registrants. Many registrants of .org domains are tax-exempt organizations or bodies operating on shoestring budgets. Many advocacy-based non-profits, which are out there on the front lines defending civil liberties, have a large portfolio of .org domains which they use to run campaigns and to raise public awareness of important issues. They do a lot with very little and cannot afford to pay significantly more for their domain names. Indeed, many receive free services, such as free web hosting, from large infrastructure providers in recognition of their important societal contributions and difficulties in raising funds. To exploit these organizations and to have them paying substantially more every year to maintain their domain names would have a detrimental impact on the public's ability to obtain information and services, and could see smaller non-profit organizations either stop renewing their domain names altogether or moving away from the Domain Name System to proprietary platforms like Facebook. Secondly, ICANN staff should not unilaterally impose Uniform Rapid Suspension provisions onto legacy Top Level Domains when that precise issue is what is being examined by the GNSO working group that was chartered to review this issue. ICANN draws its legitimacy through its bottom up, multistakeholder model, and I oppose efforts in the strongest terms to undermine this. Thank you. Yours sincerely, Ayden Férdeline

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[Comments-org-renewal-18mar19] .Org comment period - Removing domain price caps
by Janae Futrell April 28, 2019

April 28, 2019

Dear ICANN representative, I hope you are doing well today. I understand that ICANN has proposed removing price caps on all .org domains. If ICANN or the Public Interest Registry (PIR) is allowed to charge increasingly more for .org domains, this would place a significant financial burden on organizations that are often nonprofit or not for profit. With so many other costs of operations, for both websites and other needs, this seemingly small issue could make a major difference in the bottom line for many already struggling nonprofits. Please do consider the repercussions of removing price caps on all .org domains, and continue with the practice of using price caps. Thank you for your time, Janae Futrell _____________________ Janae Futrell, AICP, LEED AP Founder, Civic Sphere <https://www.civicsphere.com/>& ComplexCities Nonprofit <http://complexcities.org/> Linked In <http://www.linkedin.com/in/janaefutrell/> & Professional Portfolio <http://www.JanaeFutrell.com>

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[Comments-org-renewal-18mar19] (no subject)
by Myrtede Alfred April 28, 2019

April 28, 2019

Removing the price cap on .org domain names would impose a financial burden on nonprofit organizations who rely on donations to support our missions. Nonprofits use their .org domain to lend legitimacy to our organization, secure donations, provide a means of contact, and promote events and activities. Having to divert funds, donor or federal, from our mission to pay increased domain fees does not serve the public or those specifically served by the nonprofit. Myrtede Alfred Executive Director, Marie’s Kids Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement Comment
by C April 28, 2019

April 28, 2019

While I have never made a comment on the operation of ICANN in the past, this new TLD domain agreement has moved me to do so. In Section 2.10 of the .org renewal agreement there will be a removal of the cap the operator of the .org TLD can charge will negatively affect consumers. By allowing the Public Interest Registry (PIR) to have free reign of annual increases those once manageable costs will absolutely be passed on to consumers. Let's be honest, the .org TLD is not near as popular as .com. Registration of a domain using .org is not seen as a primary choice by the vast majority of consumers (private individuals or companies). Many times it is simply done as a guard against trademark infringement. Granting PIR the ability to charge any amount they choose could very likely hurt any potential genuine increase of the .org TLD. While I understand ICANN and PIR need to make a profit to stay operational, to have no limits on increase amounts is a very dangerous slippery slope. I highly encourage ICANN to revise Section 2.10 and reinstate the 10% cap on increases. This will ensure the .org TLD a competitive place in the TLD market, reduce potential abuse of fee increases and make it a more attractive option to the .com TLD. Thank you for your time.

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Fidel Estrella April 28, 2019

April 28, 2019

ICANN staff should not unilaterally impose URS in legacy TLDs when that issue is precisely what is being examined by the volunteer ICANN Working Group who has been mandated to review this issue. ICANN policy making is supposed to be a ‘bottom up, multi-stakeholder model’. I believe that legacy gTLDs are fundamentally different from for-profit new gTLDs. Legacy TLDs are essentially a public trust, unlike new gTLDs which were created, bought and paid for by private interests. Registrants of legacy TLDs are entitled to price stability and predictability, and should not be subject to price increases with no maximums. Unlike new gTLDs, registrants of legacy TLDs registered their names and made their online presence on legacy TLDs on the basis that price caps would continue to exist. Unrestrained price increases on the millions of .org registrants who are not-for-profits or non-profits would be unfair to them. Unchecked price increases have the potential to result in hundreds of millions of dollars being transferred from these organizations to one non-profit, the Internet Society, with .org registrants receiving no benefit in return. ICANN should not allow one non-profit nearly unlimited access to the funds of other non-profits. ICANN appears to be entirely catering to registries by removing price caps. ICANN should stand up for the public interest and registrants!

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by blaine barrington April 28, 2019

April 28, 2019

I am a .org registrant. Legacy gTLDs are fundamentally different from for-profit new gTLDs and should be treated that way. Legacy TLDs are what the internet was built on. They are essentially a public trust. They are very different than new gTLDs which were created, bought and paid for by private parties. Registrants of these legacy extensions should be entitled to price predictability & stability. Advancements in technology should be driving the cost of operating a registry down, yet prices keep going up? Removing price caps is unfair to the millions of domain registrants. They will have no price protections. Every registrant will be at the complete mercy and whims of the registry. This could result in a transfer of funds from millions of non-profits to one non-profit, with no benefits to the domain registrants. ICANN is supposed to represent a "bottom up, consensus-driven multistakeholder model". ICANN should not unilaterally impose URS in legacy TLDs when that issue is precisely what is being examined by the volunteer ICANN Working Group who has been mandated to review this issue. ICANN should be looking out for the .org registrants, in particular the non-profits. There is no "public benefit" justification to these changes. It is just a handout to business at the expense of registrants’ rights and protections. Where are the protections for the millions of domain registrants that this could effect in a negative way? These changes would give way too much power to the registry. This is not acceptable for a "public benefit" organization that exists to represent many stakeholders.

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