[Comments-org-renewal-18mar19] Opposition to changes in .org pricing caps

Don Wright wricomp at gmail.com
Fri Apr 26 20:19:08 UTC 2019

- The existing agreement already allows an annual increase much higher than
the historic rate of inflation. ICANN has even decided to operate with a
fixed-fee structure that is not indexed as specified in Section 6.1. There
is no reasonable risk that costs of operation will explode.
- The current registry operator has shown no signs it is in imminent danger
of financial collapse due to the capped price. In fact, the current .org
registry fee of $9.05 plus the $0.25 ICANN transaction tax exceeds the
total retail price of registering and renewing some other TLDs. Either
those registry operators are far more efficient than PIR and the operation
of .org should be put out for lowest price bid, or the actual costs of
operating the .org registry are less than the current price and thus PIR as
a registered not-for-profit organization does not need an unlimited price
increase provision.
- The potential for abuse of the new unrestrained price increase provision
puts many worthy non-profit organizations at risk of loss of the trusted
identity they have spent years building. This is obviously against the
public interest which ICANN and PIR purport to serve.

Therefore, the provisions of Section 2.10 of the renewal agreement should
be restored to match the existing agreement without change, in order to
preserve stability in this special public-interest TLD.

Don Wright
IT Support and volunteer for several non-profit organizations
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