The great promise of the new gTLD programme is not that it will spawn dozens of .COM clones, but rather that it will lead to the creation of a global constellation of unique names embraced by specific interest groups. As an ICANN community, our challenge now is to ensure that the policy framework we’ve created to manage new gTLDs advances that vision by not penalising the very sorts of domains that the programme was designed to encourage.

The first thing we did when we started our “cultural” registry was to choose a gTLD that actually would have little appeal for 99.93% of the world’s potential consumers. That’s a suspect strategy if you’re planning to be the next .COM, but not if your goal is to provide a relevant, targeted address to the people of the country nearest your heart.

Our domain, .KIWI, is targeted at New Zealanders (fondly known as Kiwis) all over the world, who account for about 5 million of the more than 7 billion people on earth. If all Kiwis all around the world registered two .KIWI addresses, we still wouldn’t reach 10% of .COM’s global registration base. Far from being a weakness of .KIWI, we see this as our greatest strength—a clear signal of our intention to create a thriving and robust online space that serves the specific needs and interests of Kiwis.

And while .KIWI is obviously very special to us, it is not unique among new gTLDs in that it serves comparatively small communities. Indeed, it is the community-driven model that has been the poster child for selling the new gTLD programme to the world. So why are ICANN’s registry fee policies so heavily biased against smaller operators like .KIWI?

Like every other new gTLD, .KIWI pays $25,000 USD per year in ICANN fees. At our current registration totals, that amounts to more than $3 for every domain we have under management, which, by way of perspective, is 12 times higher than the $0.25 fee that Verisign pays for each .COM name.

In the future, if we are fortunate enough to reach 50,000 registrations, our policy-mandated reward will be that we only pay double what the operators of .COM, .ORG, .INFO and .BIZ pay per name. Worse yet, if we reach 50,001 names, ICANN actually penalises us by charging an additional $12,500 fee, effectively removing our extremely brief reward of paying merely double.

From a policy perspective that’s an interesting message to send to deliberately targeted and community focused gTLDs. From our perspective, it is at odds with ICANN’s publicly stated goals of fostering diversity, competition and consumer choice.

As any new gTLD operator knows, the road to launch was (and continues to be for many) a lengthy one, fraught with delays and obstacles. While some may argue that we knew full well the fee structure we were agreeing to when we put our support behind the Applicant Guidebook, most of us didn’t see that we had much of a choice and we accepted the imperfect as a tradeoff for achieving the good.

But that doesn’t mean we should be complacent about accepting policy framework in a multi-stakeholder environment that consistently advantages legacy providers over new and innovative market entrants.

Across the board, new gTLDs bear comparatively greater costs, heavier operating burdens and greater regulatory exposures than legacy gTLDs. This is not a way to create a sustainable, dynamic and most importantly, innovative expansion of the name space.

In fact, many of these additional burdens and costs were not present when ICANN set the proposed registry fees. Additionally, ICANN received many more applications than the 500 it expected. There must be some economies of scale and efficiencies that come from the additional number of registries. We’ve seen ICANN offer “forgiveness” of two-thirds of registrar variable fees for registrars that are “considerably smaller in size”, so why is the same principle not being applied for registries?

One truly progressive policy change ICANN could make without much difficulty would be to harmonize the cost of annual fees between legacy and new gTLDs. The $25,000 figure came from the very early iterations of the Draft Applicant Guidebook in 2009. We have never seen a cost basis for that number, and the meager ICANN budgetary data available suggests that it is far higher than what ICANN needs to ensure its own operational stability.

There are a lot of great stories to tell about the first nine months of new gTLDs, including exciting growth across the broadest possible range of domains, but the good news shouldn’t stop us from working to ensure that the programme fulfills the vision for which it was created.