Hi Amy, thank you for providing a brief moment of mirth amongst all the GDPR sadness these days. I appreciate the effort of ICANN finance trying to brighten our days with a little humor. With all due respect though, this document is comparing apples to oranges when they use registrar accreditation as a basis for the costing efforts. The businesses of a registrar, where the accreditation fees are a miniscule fraction of the benefits derived from the business arising from the accreditation, cannot be compared to the business of a privacy proxy service, which usually works on a break-even level or even below that (certain large services being the exception). I also regret that none of the arguments we made over the past months are even remotely considered by the drafter of this document. Here are the fees I would see as appropriate: Affiliated providers: 1000 USD accreditation fee, zero USD annual fees Non-Affiliated providers: 1500 USD accreditation fees, 500 USD annual fees. Any shortfall would be covered by the ICANN budget, resulting in the community paying for what they asked for. Further cost reductions can be achieved by: PP Application Evaluation Ops: 192,531 USD for internal evaluation of applications? With staff that is already being paid? Please detail what this cost comes from precisely. -Cutting the background check (the WG never made a recommendation requiring such a check, so if ICANN wants it, it should pay for it itself - providers get no benefit from these checks). There, I just saved you 631,790 USD. No need to thank me, gladly done! - Cutting overhead to 5%: ICANN should operate a bit more frugally. Waste costs should not be borne by providers. - Compliance: Compliance has publicly stated they do not expect to hire additional staff for this as in many cases registrar complaint ressources would be shifted to this. Stop adding cost where the team benefitting from it said it does not need it. I just saved you another 19,423 USD. - Renewals cost: Make the term of the accreditation agreement longer, set it to auto-renew unless terminated or do not set an end date at all with more open termination rules. - PP training: Create webinars and FAQs that can be viewed at leisure. - PP data escrow: Similar to registrar data escrow, this hit is taken out of the ICANN budget - community wants it, community pays for it. - Billing and collections: Can likely be taken on by existing staff as part of their daily routine work. Another 7,800 USD saved. I also note that contrary to the presentation at the last ICANN meeting, per unit prices would now fluctuate greatly depending on the number of accredited providers. I specifically asked whether there would be an impact depending on whether only 5 providers joined or 10,000 providers joind and was told there would be no effect. Seems that position has now changed? If ICANN goes forward with this plan, it will result in one of the biggest wastes of community time and the largest failed program as the number of providers that will undergo this program will be minimal (maybe countable on one hand), because GDPR is already providing most benefits to registrants that they would get under a privacy or proxy service. Godaddy has already announced it will no longer provide privacy services to those customers that they consider to fall under the GDPR protections, and Ia assume others will follow. So the need for a registrar or reseller to provide such a service will be significantly less urgent and demand for such services will significantly shrink. So by making it harder and costlier to operate such a service, ICANN has achieved the goal of encouraging domain registration service providers to stop offering these services and instead opt for providing maximum GDPR protection for free for all of their customers. This plan reads to me like an attempt to price smaller ppsp's out of the market. Enough already! Back to the drawing board! Best regards, Volker Am 22.05.2018 um 22:20 schrieb Amy Bivins:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
Best,
Amy
*Amy E. Bivins*
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org <mailto:amy.bivins@icann.org>
www.icann.org <http://www.icann.org>
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