My registrar, and as far as I know all registrars who support this at all, lease the 2LD forwarding address as an addon to the 3LD itself, and at rather a steep rate at that.
"2.1. What effect, if any, will the proposed service have on the life cycle of domain names?
None. There will not be any effect on the life cycle of domain names.
...
2.3. Explain how the proposed service will affect the throughput, response time,
consistency or coherence of responses to Internet servers or end systems.
There will be no effect on the throughput, response time, consistency or coherence of responses to Internet servers or end systems."
My registrar is also suggesting that they are going to just keep the money I pre-paid for years of registration, which is a minor annoyance compared to the loss of my entire online identity but an annoyance nonetheless.
Since ICANN is a non-profit that is required to operate in the public interest I do hope there can be some pushback on this. I will be writing to the CA AG myself.
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