If no, please explain

The Review Procedure for Geographic Names and described role of the Geographic Names Panel are similar to the procedure and role described in the 2012 AGB. The language from the 2012 AGB has been maintained in the Draft language on the Geographic Names Review published for public comment on 1 February 2024. However, the Draft AGB introduces an estimated fee of 18,000 to 25,000 USD for the Geographic Names Review. Such a fee was not specified in the Draft language on Topic 15: Application Fees that was published for comment on 14 February 2025. Moreover, there is no Board-approved recommendation to add this fee. While the Draft AGB states that the Geographic Names Review fee is ‘payable to cover the cost of the panel’s review of the application (currently estimated between $ 18,000 USD and $ 25,000 USD)’, it is highly unclear what specific costs such a fee covers and who is expected to pay. Module 6, section 6.5.3.2 Geographic Names Review, clarifies that ‘A Geographic Names Panel (GNP) will determine whether each applied-for gTLD string represents a Geographic Name’, and further adds that in case a gTLD string ‘is a Geographic Name requiring government support or non-objection, the GNP will confirm that the applicant has provided the required documentation from the relevant governments or public authorities, and that the communication from the government or public authority is legitimate and contains the required content.’ This description creates significant ambiguity and raises serious concerns: a) As the Geographic Names Review and Panel are tasked with evaluating each applied-for gTLD string, it is reasonable that a portion of their cost be distributed across all applicants. b) The stated amounts for the conditional fee to verify, where required, the documentation for geographic name strings, are disproportionately high relative to the task, especially considering that the draft AGB suggests simple and straightforward verification methods, such as ICANN asking relevant diplomatic authorities or GAC members to confirm. c) Charging an additional fee for geographic TLD applications constitutes an unequal treatment and discourages applications for geographic TLDs, particularly in cases where the geographic name TLD is proposed for non-commercial purposes, or to serve a geographically limited community. Moreover, such TLDs are often managed by smaller registries and typically have more limited potential in terms of scale and revenue. This does not align with the next round’s aim to ‘give businesses, communities, and other organisations the chance to create an online space tailored to their audience, culture, or region,’ a tagline used by ICANN. Given the above concerns and ambiguities, we urge ICANN to review relevant sections and in the final version of the Applicant Guidebook: 1) Confirm a baseline scenario for the Geographic Names Review covered by the general application fee (as was the case in 2012), including a detailed list of required documentation that would allow a Geographic Name application to pass the review without additional cost. 2) Further detail and elaborate on possible verification methods for assessing the relevance and validity of submitted documentation that are simple, straightforward and incur neglectable costs. 3) Clearly identify exceptional cases, if any, where an additional fee may be justifiable, along with detailed cost estimates for such scenarios.

If no, please explain

See answer on module 2

If no, please explain

We urge that Appendix 2 be updated to include a detailed checklist of requirements and required documentation for the baseline scenario of the Geographic Names Review, which is covered by the general application fee (as was the case in 2012). This update should ensure that a Geographic Name application that fulfils the requirements and provides the documentation can pass the review without incurring additional costs. (See our response to Question 2 for further details.)