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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

Name: Mohamed Tijani BEN JEMAA
Date: 1 Apr 2024
Affiliation: Fédération Méditerranéenne des Associations d'Internet
Email: tijani.benjemaa@topnet.tn
Original Public Comment: Review of the Draft Applicant Support Program (ASP) Handbook – New gTLD Program
1. Do you believe that Section 1 (“Introduction”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
2. Do you believe that Section 2 (“Overview”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
No, ASP handbook does not accurately reflect policy recommendations

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

Since this round is meant to be a remedial one after the total failure of the 2012 one in terms of supporting applicant from underserved regions and communities and bringing diversity into the DNS industry, the floor fee reduction proposed to be 50% won't make the ASP program successful, especially that the application fee which is not yet known seems to reach USD 250 000, while in 2012, it was USD 185 000 only and the reduction was of 75%. The minimum fee reduction shouldn't be less than the reduction proposed for 2012, so, I propose that in section 2.1 bullet 5, it becomes "A 75-85% reduction in ......"

3. Do you believe that Section 3 (“Applicant Support Program Timeline”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
Yes
4. Do you believe that Section 4 (“Reduction of New gTLD Program Application and Evaluation Fees”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
No, ASP handbook does not accurately reflect policy recommendations

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

4.2 table 2: New gTLD Program Application base fee reduction "At least 75% up to 85%"

5. Do you believe that Section 5 (“Applicant Eligibility and Evaluation Criteria”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
No, ASP handbook does not accurately reflect policy recommendations

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

Only one of the 5 possible entries to the ASP concerns applicants from the global south and 4 of them permit the support for applicants from the global north. And even the one that concerns applicants from global south is not exclusive to the underserved regions and countries. We may end having a good number of supported applications, most (or all) of them from the global north. Would it be a successful ASP in this case????

7. Do you believe that Section 7 (“ASP Application Evaluation”) of the ASP Handbook accurately reflects the relevant policy recommendations on Applicant Support?
No, ASP handbook does not accurately reflect policy recommendations

Please provide the suggested language change or an explanation of any inconsistencies, and provide alternative language where possible.

7.5 bullet 5 :"A 75-85% reduction in New gTLD Program application and evaluation fees for qualified supported applicants Minimum and Maximum Fee Reductions: It's not fair that all applications are evaluated in case of exhaustion of the allocated fund (not yet known). The fund should be sufficient to support all the qualified applicants after evaluation of all applicants.

Other Comments

To be successful, the ASP must support applicants from the underserved regions and communities and bring diversity in the DNS industry. Failing this goal, the program wouldn't be successful even if it supports a big number of applicants.


The minimum fee reduction couldn't be less than the one proposed for the 2012 round (75%).

Summary of Attachment

none

Summary of Submission

Only one of the 5 possible entries to the ASP concerns applicants from the global south and 4 of them permit the support for applicants from the global north. And even the one that concerns applicants from global south is not exclusive to the underserved regions and countries. We may end having a good number of supported applications, most (or all) of them from the global north.

Since this round is meant to be a remedial one after the total failure of the 2012 one in terms of supporting applicant from underserved regions and communities and bringing diversity into the DNS industry, the floor fee reduction proposed to be 50% won't make the ASP program successful, especially that the application fee which is not yet known seems to reach USD 250 000, while in 2012, it was USD 185 000 only and the reduction was of 75%. The minimum fee reduction shouldn't be less than the reduction proposed for 2012