This is a comment that I've sent to ICANN about the planned new .org, .biz, .info registry agreements.
I am writing this note in my personl capacity, as a long time observer of and some time participant in ICANN. It applies equally to the .biz, .info, and .org agreements.
The apparent ability for registries to arbitrarily increase prices for domain names at the time of renewal puts one of the most fundamental factors in the DNS's success to date at risk (one might say, its very purpose): The easy availability of persistent globally unique identifiers.
Pricing on the registrar level is balanced by market forces, at every stage of a domain's life cycle: If an incumbent registrar threatens to charge an exorbitant price, the registrant will be likely to move to a registrar that offers the same registration at a reasonable price. The cost of changing registrars is low, and ICANN has -- rightly! -- made a substantive investment of time and energy in ensuring that it stays low: Ultimately, this was the entire point of the GNSO's multi-year transfers policy development effort, and the staff's significant efforts in implementing this policy.
Pricing on the registry level has a similar balance in effect when a domain name is initially registered. When a domain name is up for renewal, however, then there is no competition on the registry level. The price "that the market bears" is essentially a function of the registrant's switching costs.
These costs can be significant, and ICANN should keep in mind that changing a domain name is a cost that is not just borne by registrants: Where online resources that are identified through the DNS are part of infrastructure -- be it the Net's, the Web's, or critical infrastructure offline --, the switching cost for the registrant will be negligible when compared to the cost that the general community would incur.
ICANN must act as the guardian of these overall interests in the "stable and secure operation of the Internet's unique identifier sytems", as the first sentence of its Bylaws puts it. ICANN must make sure that globally unique, dependable, and persistent identifiers remain available, within a reasonable and predictable economic framework. ICANN must understand that economic stabilityof these identifiers is a crucial part of the overall equation.
