[Comments-org-renewal-18mar19] .org RA Renewal

[Alan Greenberg]

This comment regarding .ORG price caps is submitted solely on my own behalf.

In my mind, there are two salient issues:

1. ICANN's determination to have uniform Registry Agreements: this is 
reasonable from a purely administrative point of view. I will point 
out that this desire/requirement is an administrative and contract 
issue and has never, been subject to a community decision. The .NET 
agreement that just came into in 2017 did NOT follow this pattern of 
alignment with the new "standard" RA, which demonstrates that there 
are other viable options that ICANN sanctions.

2. .ORG is targeted (if not limited) to organizations that generally 
are in the public interest. There are somewhat over 10 million .ORG 
domains and it is reasonable to presume that many million of them are 
public-service type organizations that have registered under .ORG 
based on its perceived focus area but may well have presumed that the 
price they paid to start would not increase radically.

PIR has regularly raised prices in the past. Although they have not 
raised prices recently, they now have a new CEO and a new Chair of 
the Board. Given that, past behaviour is NOT necessarily a predictor 
of future actions. ICANN should take the prudent and public-interest 
path and preserve caps on allowed price increases.

Alan