Second Level Domains Policy Review Submission

From:		Jonathan Ah Kit
Received:	10 November 2003


1.
Q:  Are the twelve second level domains still appropriate for their communities 
of interest? 
A: Firstly, I am of the view that once a 2ld is there, it should stay.

Of the current 2lds, I have never had a problem with any already there.

2.
Q: Should any of the open 2LDs be moderated? (.ac, .co, .gen, .geek, .maori, 
.net, .org, .school)
A: yes
comments: .school.nz and .ac.nz, despite actually being unmoderated at the 
moment, does tend to give an appearance of looking official. The cat may be 
out of the bag and down the road as I once said, but I think closing them off 
to unmoderated registrations would send a clear signal what its intention was.

3.
Q: Is there any need for the rationalisation of the current 2LDs? 
A: Again, I said in 1 that I do not favour rationalising any of the current 
2lds, unless (once again) moderating .school.nz and .ac.nz counts.

    	3.1
    	Q: If so, what process should be used for the removal or closing of 
	   existing 2LDs?:
	A: If we do find ourselves in that position, I'd like to see the 
	   process meaning all registrant rights protected until the last 
	   domain in [1] that 2ld (should it ever get that far) is 
	   deregistered, [2] registrations suspended then [3] further 
	   discussion before the deed is done, so to speak.

           A third way could be to allow new registrations but not new 
           registrants.
    
        3.2
       	Q:  Should any such process be included in the 2LD policy?:
       	A: Yes.
 
4.
Q: What criteria (types of criteria and specific examples) should be applied 
to the creation of new 2LDs?
A: I think the existing criteria provide a good balance between the 
frivolous applications, so I don't advocate much change there

5.
Q: Is the current process for creating new 2LDs too simple, too complex 
or about right? 
A: too complex
comments: Most people I talked to during the .geek.nz and .maori.nz 
processes assumed after the first council vote they could get their paws 
on either domain straight away. Either the process needs to be publicised 
more, or one needs to simplify the process.

In that respect, I'd like to see one 'will we do it?' vote that will be 
final. There could be further votes at a further council meeting, but only 
for implementation matters. [*]

[*] I'd put in a derider here, 'exceptional circumstances' or new evidence 
(i.e. fraud, etc) coming up that may affect the basis on which the 
application was judged.

6.
Q:  How much, if anything, should an application for the creation of a 
new 2LD cost? 
A: NZD1000 seems to be a modest sum to prevent 'silly' applications that 
may pop up from time to time, yet allow serious applicants to proceed. 
Raising it more would be nice to cover costs, however.

7.
Q: Who, if anyone, should be able to block the creation of new 2LDs? If 
so, why and how? 
A: I think objectors' concerns should be enough during the consultation 
process, though I think they should be encouraged to note clearly in any 
submissions they make that they find it offensive, or whatever, and why.

This process could also be used for people to object to their 2ld being 
possibly confused with a possible new one, i.e. .com.nz vs .co.nz or 
.gov.nz vs .govt.nz, etc.

8.
Q: Should there be different criteria or processes for the creation of 
moderated as opposed to open Second Level Domains? 
A: Yes. For example: if .maori.nz had been moderated, as I recall it was 
briefly discussed, I would have demanded more detail in the processes that 
would have been put in place for it.

9.
Q: Is the level of public input in the process adequate; excessive; or 
inadequate?
A: inadequate
comments: I realise it's hard to publicise such a dry topic, but one can 
only but try. At least there's multiple opportunities to provide input.

10.
Q: Are the methods currently used to seek public input (submissions; 
discussion period; straw poll) the best available, or would you suggest 
other/additional methods? 
A: While it's cumbersome and rather drawn out, I agree that the current 
2ld process it does give multiple opportunities to contribute as per what 
I said in 9.

11.
Q: Do you think direct public registrations should be accepted at the 
second level?  
A: no

	11.1
	Q: Why?  What are the advantages or disadvantages of such an 
           approach?
	A: My main concern is people registering similar 2lds to .co.nz 
   	   (.com.nz, .corp.nz) and then trying to sell registrations there. 
	   Too much confusion and mayhem, I smell.

	   I'd like to see maybe some limits to prevent these things 
	   happening. But of course one can't limit registrants' rights to 
	   subdelegate any domains they have to someone else.

12.
Q: If direct registrations are allowed at the second level, what kinds of 
transition arrangements would need to be put in place for existing third 
level registrants? 
A: I suspect the best way is to open up to open slather. As for my answer 
to 11, my first gut feeling is that I think the best way to prevent .com.nz 
to be registered would be to only allow registrations of domains at the 
second level where the domain is 4 or so characters or more.

Alternatively, for non-colliding registrations, an idea: maybe those 
could be reserved for 30 days, while waiting to see if they want it.

13.
Q: What is the best way to deal with any conflicts between existing third 
level registrants if the second level is opened? 
A: Well, if they don't agree, maybe open slather. Alternatively, one could 
see a simple drawing lots system.

I'd like to see off any auctioning or tender system if we can.

14.
Q: Should registration fees be different (higher/lower) for Second Level 
domain registrations if they are opened directly to the public?
A: Personally, I think there should be, as the 2ld levels are effectively 
devalued in some way. However, I also see advantages in having a uniform 
(registry) pricing system for all domain names, though we can't be sure 
domain registrars will charge less, same or whatever for 2ld registrations. 
:)

15.
Q: Are there other options around the future of the Second Level that the 
working group should consider? 
A: Personally, I see no value in opening up the 2ld space at this time. The 
2ld system appears to have served .nz well, with little complaint as we 
(appear to) have a transparent creation process at the moment.

16.
Q: Are there any other issues you think the Working Group needs to consider 
in the course of the review? 
A: I think the working group need to come up with options on macrons in 
domain names; it's more of a technical issue, but with Te Reo Maori's 
influence growing in ICT and education, as well as life generally, we need 
to avoid those umlauts as much as we can. ;)