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. Please withdraw this proposal and come back with something more acceptable. We have set out to create better rules for an existing service/product, not to regulate it out of existence. Or better yet, provide us with your document in editable from and we'll change it for you. Best regards, Volker Am 11.09.2017 um 13:29 schrieb Michele Neylon - Blacknight:

Amy

Thanks for sharing this.

I have several concerns.

Firstly the fees that are being proposed.

I cannot understand why or how ICANN can justify charging $4k / year for this to a provider.

From our perspective this makes zero sense, as there is no value being provided by ICANN and the cost is very high – you’re essentially doubling how much I pay ICANN per year.

Background screening – this seems to be complete overkill for an “affiliated” provider.

In our case for example ICANN is going to be dealing with the same person you’ve always dealt with.

If you insist on subjecting us to this kind of scrutiny I don’t mind, but I just see it as being a waste of resources.

6.5 – I thought there was no clear agreement on different labelling of whois privacy in whois?

8.3 – where on earth did that come from?

Regards

Michele

--

Mr Michele Neylon

Blacknight Solutions

Hosting, Colocation & Domains

https://www.blacknight.com/

http://blacknight.blog/

Intl. +353 (0) 59  9183072

Direct Dial: +353 (0)59 9183090

Personal blog: https://michele.blog/

Some thoughts: https://ceo.hosting/

-------------------------------

Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty

Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845

*From: *<gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Friday 8 September 2017 at 14:55 *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *[Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting

Dear Colleagues,

Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it.

On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you’ll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We’ve also added a fees proposal.

Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list.

Have a great weekend!

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>

_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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