I hope that ICANN will reconsider this issue.
For affiliated providers, ICANN is proposing to charge another
registrar-level ICANN fee for absolutely no extra work, since most
of the requirements were modeled on the privacy proxy spec to the
RAA. As previously discussed, affiliate provider accreditation
should be linked to the registrar accreditation at no additional
cost.
But this does not end here, as the fees for non-affiliated
providers are also way out of proportion. You are essentially
pricing smaller providers out of the ability to provide the
service at reasonable cost. Many providers are offering this
service as part of the overall domain registration fee and are
eating the costs of the service. Free whois privacy - standard in
many parts of the world - would become an untenable business
proposal.
If this is what ICANN is really planning to do, I am afraid that
we will not achieve consensus for the implementation work.
Anything beyond a nominal one-time fee is unacceptable.
With the accreditation program ICANN is already increasing the
costs to providers by adding new costly requirements that need to
be fulfilled for a service that is usually a loss-leader, not a
profit center. Adding another accreditation fee justified only by
the removal of the ability to do business as usual with their
partnered registrar smells like mafia-style pressure to me: "If
you want to be able to continue to offer your customers this
service, you better pay the protection mon...err accreditation
fee!", just with the difference that the mafia actually offers
some form of protection, whereas ICANN offers...what?
The entire concept of an application window is also
ill-considered as it basically locks out current providers that
may have missed the notice or the fact that this policy actually
applies to them. Providers will have to have the ability to apply
close to instantly and at any time.
The application process is overly complicated and bureaucratic.
You should only be asking two questions: a) are you a legally
established company in your country of residence and b)
self-certify that you are able to comply with the requirements of
this policy. Everything beyond that is superfluous and
overdesigned considering the nature of the service being provided.