If no, please explain

Section 6.7.1 indicates that ICANN want to help applicants to “to assess the risk of Name Collision” before application submission. The section then outlines that quantitative and qualitative factors will be considered. The section also warns applicants not to assume that “a low volume of Name Collision occurrences” does not mean a string will be assessed as safe. Section 6.7.2 goes on to expand the Name Collision Initial Assessment and identifies specific examples of quantitative data sets: “root server logs, and DNS recursive server logs, using both volume and diversity of queries, origins, query names (labels), and query types; Identifier Technologies Health Indicators (ITHI)”. The section then states “and qualitative evidence that can help deduce the severity of harm”. However, the section does not list any examples of qualitative evidence which will be gathered. If ICANN wants to help applicants to assess their risk pre-application submission, examples and sources of qualitative evidence should be described and made available to applicants prior to, and in a reasonable amount of time before the opening of the application window, similar to the quantitative information. The end of Section 6.7.2 states: “ICANN will publish an Initial Assessment report describing the assessment, its methodology, and findings, once completed. A Public Comment period will be carried out for the report to allow the community to provide feedback on the methodology and findings.” This statement comes right after the sentence: “The Initial Assessment will take place following the String Confirmation Day.” It is unclear whether the Initial Assessment report describing the assessment and methodology will be available to applicants prior to application submission. Based upon ICANN’s stated desire to “help applicants to assess the risk of Name Collision”, it is incumbent upon ICANN to provide the Name Collision Assessment methodology prior to submission and it should be described in the AGB with sufficient detail as other string evaluations such as Community Priority Evaluation. ICANN has announced that strings designated High-Risk Name Collision will be charged $100,000 – 150,000 in additional fees for a High-Risk Mitigation Plan Evaluation. Combined with the application fee of $227,000 an applicant may be facing $377,000 in ICANN fees as well as a lengthy delay if their applications receive such a designation. ICANN must provide adequate pre-submission Name Collision Assessment data, both quantitative and qualitative and the evaluation methodology so that an applicant can reasonably understand whether their string is likely to be designated High-Risk. The methodology should be presented soon with the opportunity for public comment prior to the application window opening.