Selected Public Comments submitted in response to the Proposed Renewal of the .Org Registry Agreement

A Selection of Comments Submitted in Connection with the Renewal of the .Org Agreement

These are a selection of notable comments from the over 3,000 comments submitted in response to a request for public comment on the terms of the proposed renewal of the .Org agreement.  We have highlighted some phrases in bold and where needed fixed minor typos.

 

From a joint letter by the NPR, YMCA, C-SPAN, National Geographic Society, AARP, The Conservation Fund, Oceana, and National Trust for Historic Preservation:

— On price caps: “The reasonable expectation of .org registrants was, and continues to be, that prices would remain capped to ensure stable and reasonable domain name pricing for the millions of nonprofit organizations that have invested in a .org web presence. These organizations put their trust in ICANN as caretaker of the public interest in the .org name space.”

— Excessive Fees: “Every additional dollar earmarked for domain name registrations is a dollar that is not available to advance the public interest purpose of nonprofit registrants that use the .org name space.”

— Unsound policy basis: “ICANN has articulated no compelling policy basis for this proposed change. Instead, ICANN has represented that the intent is just to bring the .org Agreement into conformity with the base registry agreement used by ICANN with respect to other gTLDs not set aside for organizations that serve the public interest. This strikes us as conformity for its own sake. ICANN should not disregard the public interest in favor of administrative convenience.

 

From a comment by the National Council of Nonprofits:

“The National Council of Nonprofits is a trusted resource that advocates for America’s nonprofits nationwide. Through its network of state associations of nonprofits and 25,000-plus member charitable nonprofits, faith-based groups, and foundations, it serves as a central coordinator and mobilizer to help nonprofits achieve greater collective impact in local communities across the country.”

“A very large share of the more than 10 million .org domains are registered to charitable nonprofits organized under Section 501(c)(3) of the Internal Revenue Code.”

“Stripped of the jargon in the proposal is the suggestion that a domain populated almost exclusively by tax-exempt, nonprofit organizations is no different from long-established and emerging commercial-oriented domains. This mindset seeks to treat disparate entities as the same, something that laws and society fully reject.

“The ICANN proposal would subject nonprofits to unpredictable and unrestricted price hikes. Unlike for-profit businesses, nonprofits typically do not have revenue flexibility to absorb new and unexpected costs or to raise prices on consumers to overcome the hit to their bottom lines.”

“If domain names are no longer affordable, nonprofits will be forced to use less substantial subdomain. Donors are much more likely to donate at nonprofit.org than nonprofit.wixsite.com. Nonprofits that are no longer able to afford to keep a domain also risk longstanding domains being taken over by others, causing branding confusion and the potential for domains associated with charitable works being used for less-than-charitable purposes.

“Quite literally, the profits derived by this unwarranted change will ultimately be paid by the people nonprofits will not be able to serve. Every $1 in increased prices on the 10+ million .org domain users would generate more revenue each year than is utilized by all but the top one-percent of charitable nonprofits. Each one-dollar hike in costs per domain would divert more than $10 million from nonprofit missions for the enrichment of the monopoly. By anyone’s estimate, this money would be better spent delivering an additional 1,600,000 meals by Meals on Wheels to seniors to help maintain their health, independence and quality of life. Or $10 million could enable nonprofits to provide vision screenings for every two- and three-year-olds in California. Or pay for one million middle school students to attend performances of “Hamilton” or “To Kill a Mockingbird”. Nonprofits should not need to choose between paying for a domain name and helping people.”

 

From a comment by the ASAE:

“ASAE, which is the largest organization in the world representing the interests of trade and professional associations, is firmly opposed to ICANN’s proposal to remove price caps on the .org top-level domain (TLD) used by most associations and other tax-exempt organizations. Doing so would subject millions of associations and nonprofit organizations to what would most likely be an unstable pricing environment, forcing them to divert valuable resources from their exempt purpose in order to protect their online brand.”

“ASAE represents more than 44,000 association professionals and industry partners. Our members manage leading trade associations, individual membership societies and voluntary organizations across the United States and in nearly 50 countries around the world.”

“There are more than 10 million .org domain names registered. Legacy gTLDs like .com, .org and .net were created through the U.S. government and entrusted to ICANN to manage. ICANN then contracted with various service providers to operate legacy gTLDs – not to own them.

“It’s true that registry operators that won the right to sponsor new gTLDs can charge whatever price they see fit, but they also paid millions of dollars in some cases to acquire all of the value in their sponsored domain names, whereas the service contractors managing legacy domain names most assuredly did not. This is a crucial difference that ICANN should take great care to enforce.

“Stating that nonprofit organizations can easily switch from one domain name to another if they don’t like the pricing structure ignores the reality that established nonprofits have a longstanding Internet presence built on a .org domain name – a name and online reputation that the organization (not the registry operator) has spent decades cultivating.”

“ICANN’s mission is in part to preserve the operational stability of the Internet. Eliminating price caps and endangering the online credibility of the global nonprofit community is not consistent with ICANN’s mission.

 

From a comment by the California Association of Nonprofits:

“California Association of Nonprofits(CalNonprofits), a statewide policy alliance of more than 10,000 organizations, is the voice for California’s nonprofit community.

This proposed change to Section 2.10 of the .org renewal agreement would subject nonprofits to unpredictable and unrestricted price hikes. Unlike for-profit businesses, nonprofits typically do not have revenue flexibility to absorb new and unexpected costs or to raise prices.

Because this would be harmful to nonprofits, we strongly oppose the proposed Section 2.10 of the .org renewal agreement that would remove caps and permit unlimited price hikes on .org registrations and renewals.

Various other comments


“I’d like to offer that our religious community struggles to afford most things we do including our web presence. We focus our efforts of doing helpful things with our income and raising fees or opening up .org domain names to increased fees could be devastating to non-profit organizations.  Please don’t make it more difficult to be of service to others.

Father Thomas Clark, April 26, 2019


“I am a volunteer leader for several Scouting related groups, all of which have .org websites. We are volunteer based groups who’s leaders all spend way too much of our own money trying to help kids out. I personally pay for the renewal of our domain names simply because our groups don’t have the available money for them. If I didn’t pay for them the names, (and the associated sites), would end up going away. This is probably true for a lot of .org groups that work with youth.

Please don’t take the cap off the price increases. Every time these prices go up now it’s bad enough for me, but at least knowing they are somewhat limited helps.

Ted McLaughlin, Scoutmaster, April 24, 2019


“Many of these organizations have long-held .org domain names and a substantial percentage of their meager funding is tied to donors being able to find them via those domains. The massive potential price increases (as opposed to the moderate ones that are already possible) would prohibit smaller organizations and personal projects from having a place on the Internet. This is an anti-competitive practice aimed squarely at eliminating smaller organizations and nonprofits from having a presence on the Internet.”

Chris Raters, April 24, 2019


“The organization to which I belong is a registered nonprofit charity.  Our domain is an essential part of our identity and our ability to engage our members and raise money for our operations.  We are granted nonprofit charitable status because we bring a much needed benefit to the music and arts community.  A significant increase in the price of our domain would diminish our ability to offer these benefits and threaten our survival.”

Jerry Silver, April 25, 2019


Why, in God’s name, would anyone decide that .org domains in particular should be a market free-for-all?

Asai, an administrator of dozens of domain names for various nonprofit ministries, April 24, 2019


“I am writing in opposition to the removal of pricing caps for the .org  tld. That tld is widely used by non-profit organizations who might not
be able to afford steep increases in their URLS.  This could cause a great amount of upheaval and confusion if long standing non-profit and  community organization have to give up their tld’s and they are replaced by others with different agendas. How would low revenue, non-profit organizations be able to have a web presence if popular tld’s are only available to the affluent?  Bad idea.”

Gervase R. Bushe, Professor of Leadership and Organization Development, Beedie, School of Business, Simon Fraser University, April 26, 2019


“As a marine biologist working on many voluntary projects, particularly on marine mammal issues, it will be difficult for us if you remove the price cap. We won’t be able to afford the domain in a longer term, and we won’t be able to sustain our environmental movements for long. So, please keep the price low for us.”

Dr. Putu Liza Mustika (“Icha”), Director, www.cetasindonesia.org, April 25, 2019


This is basically sanctioning extortion, a domain name is closer to a trademark, except a company is apparently not allowed to own it… instead they must keep “leasing” their trademark from a registrar. What do I get for improving my domain name (making my business known, improving public trust, running a well known blog/ news site)? Clearly higher rent costs on that same name.”

Saevon Kyomae, April 26, 2019


“Just for the record, I’m an average guy who owns a .org domain, and I use it to provide mail services for myself and my family. I can afford $10US or $20US a year to maintain it.

HOWEVER, with the proposed removal of price caps, it’s very easy to imagine the cost of my domain going to $35US/year or even more. I may be able to afford that, but my wife would never approve the expense. It’s very easy to imagine that this proposed change would lead to me losing my domain.

Jeff Arnold, April 24, 2019


 

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