[SubPro-IRT] [Ext] Re: RSP fee

Tue May 28 11:02:43 UTC 2024

Hi All,

I have been meaning to make a contribution to this discussion, but work pressure has simply not allowed me to do so. I have, however, raised a few of my concerns directly with some of you on this list.

For those that may not know me, I represent an African based RSP, currently involved with several existing gTLDs and an African based ccTLD. We have been involved in the registry technical environment for over 30-years and, more recently, since the last nTLD round in 2012 (i.e .africa). 

I also appreciate a good analogy, but must point out that in the current (Marika) example, RSPs having their own bus means very little on its own. An RSP without a TLD (or the prospect of a TLD) to support is simply a waste of time and money—like being all dressed up with nowhere to go . A more fitting analogy for the 2026 nTLD round is that RSPs are not mere passengers needing a seat or even their own entire bus. Instead, RSPs are actually responsible for providing, driving, and maintaining the bus that nTLD applicants (the passengers) will use. ICANN’s role is to ensure that the bus provided and maintained by an RSP is roadworthy and fit for purpose - in the best interests of passengers and other road users. To complete the analogy, in the above scenario ICANN simply provides the roadway and ensures that road users stick to the rules.

Indulge me as I take this analogy a step further. In relation to the 2026 nTLD round, most (if not all) the RSPs will use the exact same (approved) bus that they used during the 2012 nTLD round and still use today. In 2012 ICANN conducted a 'roadworthy check' on the same bus for every passenger ticket issued, a method that was neither efficient nor cost-effective for ensuring compliance and uniformity. For 2026 we are moving towards a single certification for the RSP’s bus, irrespective of the number of nTLD passengers who will request a seat. It’s the same roadworthy validation process as in 2012, but without the repetitive checks. So why does it now suddenly cost us more? It's the same bus, largely the same route, and more or less the same type of passengers. 

Even if it does cost more this time round, why is this simply not funded from the proceeds of the 2012 nTLD round? - I realise I may be opening a can of worms here :-| 

The crux of the matter is that I don’t think this proposed US$92,000 RSP pre-evaluation fee is going to encourage diverse participation in the next nTLD round, especially from developing regions. It’s a new financial barrier to entry that previously was not there and it will almost certainly hamper participation from developing regions in the next nTLD round. We for one, an established RSP from Africa, will need to carefully consider our participation in this pre-evaluation process. Not because we don’t have the skills, experience  or willingness to participate, but rather that the costs are prohibitive for what may be a limited return on investment. This is not an ideal scenario as our role (as an RSP and Technical partner in Africa) should be to encourage and support broad participation from Africa.

Lastly, some of you may suggest that we simply do not participate in the pre-evaluation process but rather only when the nTLD round opens. The problem with this is that being on a pre-evaluated RSP list will certainly help create much needed visibility of our services and expertise in a region that is in dire need of it (especially leading up to the 2026 nTLD window). Its a matter of "damned if you do and damned if you don’t".       

I hope to join the Zoom call later today, but I do have a conflicting meeting with the local regulator. 

Regards

Neil Dundas
DNS Africa Ltd

> On 28 May 2024, at 11:09, Jothan Frakes <jothan at jothan.com> wrote:
> 
> Thank you. 
> 
> I loves me a good analogy, because that is the style I use a lot.  I got a little confused in the bus/chicken as to how to represent the fees when asked by folks less close to our ICANN world who are not following things closely like us.
> 
> The main 2 questions on the next round that I field are, "how much? / when can I apply?"
> 
> [If I had a nickel for how often I am asked those two specific questions.... ]
> 
> For the "how much?" question, I find laying it out clearly works best, and doing so with worst case scenario amounts, so that they can obtain budget approvals or raise funding as needed.
> 
> @Marika Konings <mailto:marika.konings at icann.org> can you confirm...
> Related to the application pricing, it sounds like ... well, I think you are saying that a new entrant TLD applicant with a new platform should budget for an additional 92k above their (estimated) 250k fee, or an estimated 342k. This number might improve (give or take some refundable differences in the event of as of yet to be measured volume).
> 
> Is that accurate?
> 
> I always caveat these figures are estimates and identify them as being finalized closer to October when communicating them, but I try to keep folks up to date on what to expect.
> 
> -Jothan
> 
> 
> On Tue, May 28, 2024, 1:21 AM Marika Konings <marika.konings at icann.org <mailto:marika.konings at icann.org>> wrote:
>> Thanks, Jothan for that question. When we present the gTLD evaluation fee, we plan to show the savings that were made compared to 2012, but also the additional costs that need to be factored in (e.g. inflation, new evaluations). However, as indicated yesterday, comparing the costs for technical evaluation from the 2012 round is not identical to the RSP program so you will not see a reduction of 92K. Some have referenced the evaluation costs that were part of the 2012 fee, but it is important to remember that those just represent the external expenses. Other costs, such as staff support, implementation, etc. were included in other buckets that made up the 2012 evaluation fee.
>> 
>>  
>> 
>> As I know Lars likes using the car analogy, maybe this is a way of looking at it: in 2012, technical evaluation paid for a seat on a very big bus which included a lot of other evaluations and aspects of the program. Per the SubPro recommendations, for the next round technical evaluation was taken off that bus and had to get its own. As part of that, it is not only the costs of the seat that needs to be covered, but also the new bus, the insurance, gas (e.g. RSP system development, RSP handbook, system maintenance, staff support). As said previously, comparing technical evaluation of the 2012 round with RSP is comparing apples to oranges, but bringing in MSA is like comparing it with chickens because that is part of ICANN’s operations which is structured and funded in a very different way compared to the next round.
>> 
>>  
>> 
>> As indicated, the team will be sharing more details on the RSP budget so that will hopefully provide some further insight into the different parts that comprise the development, implementation and running of RSP and for which the costs need to be recuperated per the policy recommendations.  
>> 
>>  
>> 
>> Best regards,
>> 
>>  
>> 
>> Marika
>> 
>>  
>> 
>> From: Jothan Frakes <jothan at jothan.com <mailto:jothan at jothan.com>>
>> Date: Monday, 27 May 2024 at 18:31
>> To: Marika Konings <marika.konings at icann.org <mailto:marika.konings at icann.org>>
>> Cc: Rubens Kuhl <rubensk at nic.br <mailto:rubensk at nic.br>>, "subpro-irt at icann.org <mailto:subpro-irt at icann.org>" <subpro-irt at icann.org <mailto:subpro-irt at icann.org>>
>> Subject: [Ext] Re: [SubPro-IRT] RSP fee
>> 
>>  
>> 
>> Hi Marika
>> 
>>  
>> 
>> I realize we are still expecting some reveals on the pricing for an applicant, but wanted to ask a clarifying question.
>> 
>>  
>> 
>> Is the anticipation that this $92,000 RSP fee would reduce the application fee (ie, est 250k - 92k = est 158k), or is this $92k on top of the est $250k such that a new entrant would be needing to contrast the 2012 round $185k all-inclusive against an estimated $342k all-inclusive?
>> 
>>  
>> 
>> -Jothan
>> 
>> 
>> Jothan Frakes
>> Tel: +1.206-355-0230
>> 
>>  
>> 
>>  
>> 
>> On Sun, May 26, 2024 at 11:20 PM Marika Konings <marika.konings at icann.org <mailto:marika.konings at icann.org>> wrote:
>> 
>> All, as my US colleagues are out today for a US holiday, I thought I would jump in to try and avoid any confusion. The link that Rubens shared is NOT the cost estimate from the 2012 round but for a Material Subcontracting Arrangement (MSA) change. This is an ad-hoc, individual request review. My understanding is that the estimated costs of technical evaluation in 2012 were between $40,000 and $50,000 per application (not per RSP). Regardless, as Gustavo also pointed out on the call, focusing on the difference between 2012 and RSP is to a certain degree comparing apples to pears as per the SubPro recommendations, a separate program has now been created with its own application system as well as RST 2.0, that will evaluate RSPs only once. Gustavo and team will be sharing more details on the cost breakdown of implementing and running RSP as requested by the IRT, but as a reminder, per policy recommendation 6.8, the program is expected to be cost recovery with those seeking evaluation funding RSP.  
>> 
>>  
>> 
>> Best regards,
>> 
>>  
>> 
>> Marika
>> 
>>  
>> 
>> From: SubPro-IRT <subpro-irt-bounces at icann.org <mailto:subpro-irt-bounces at icann.org>> on behalf of Rubens Kuhl via SubPro-IRT <subpro-irt at icann.org <mailto:subpro-irt at icann.org>>
>> Reply-To: Rubens Kuhl <rubensk at nic.br <mailto:rubensk at nic.br>>
>> Date: Sunday, 26 May 2024 at 21:18
>> To: "subpro-irt at icann.org <mailto:subpro-irt at icann.org>" <subpro-irt at icann.org <mailto:subpro-irt at icann.org>>
>> Subject: Re: [SubPro-IRT] RSP fee
>> 
>>  
>> 
>>  
>> 
>>  
>> 
>> Em 26 de mai. de 2024, à(s) 14:26, Hickson, Nigel (DSIT) <nigel.hickson at dsit.gov.uk <mailto:nigel.hickson at dsit.gov.uk>> escreveu:
>> 
>>  
>> 
>> Rubens 
>> 
>>  
>> 
>> Good morning; like yourself I was on IRT Call when this came up, but had not appreciated what the cost in 2012 round was; this is indeed a significant increase.  I am sure the GAC will be very concerned as to how this impacts applications from underserved regions.  
>> 
>>  
>> 
>> Hi Nigel. 
>> 
>>  
>> 
>> Note that this does not applied only in 2012(actually 2014 since this is only charged when a gTLD changes RSPs); this is 2024 current fee to be an RSP for 2012 gTLDs. Org can’t blame inflation on this one, since it’s a comparison of current fees. 
>> 
>>  
>> 
>>  
>> 
>> Rubens
>> 
>>  
>> 
>>  
>> 
>> _______________________________________________
>> SubPro-IRT mailing list
>> SubPro-IRT at icann.org <mailto:SubPro-IRT at icann.org>
>> https://mm.icann.org/mailman/listinfo/subpro-irt
>> 
>> _______________________________________________
>> By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
>> 
> _______________________________________________
> SubPro-IRT mailing list
> SubPro-IRT at icann.org
> https://mm.icann.org/mailman/listinfo/subpro-irt
> 
> _______________________________________________
> By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://mm.icann.org/pipermail/subpro-irt/attachments/20240528/430b2b06/attachment-0001.html>