Second Level Domains Policy Review Submission From: Robert Gray Received: 8 October 2003 1. Q: Are the twelve second level domains still appropriate for their communities of interest? A: No Opinion 2. Q: Should any of the open 2LDs be moderated? (.ac, .co, .gen, .geek, .maori, .net, .org, .school) A: no comments: 3. Q: Is there any need for the rationalisation of the current 2LDs? A: No 3.1 Q: If so, what process should be used for the removal or closing of existing 2LDs?: A: 3.2 Q: Should any such process be included in the 2LD policy?: A: No 4. Q: What criteria (types of criteria and specific examples) should be applied to the creation of new 2LDs? A: Only that the 2ld provides open access to specific communities of interest. The process for management of the 2ld should be confirmed as meeting this requirement. There should be no criteria of usage and no subjective criteria of 'is this a good idea'. There should also not be any consultation process and certainly no vote. Any bona fide organisation representing a community of interest should have an easy run. A contract should be signed to ensure that the managing party meets and continues to meet their obligations of open access to the 2ld for the community of interest. Thus bank.nz should be a simple application from the bankers assoc or whoever and approval should thus be granted. Similarly any organisation for example real estate agents, lawyers, doctors, theatre clubs, flying clubs indeed any group with an 'umbrella' organisation would have an easy run. Also companies with unique, unambiguous, unique brands should have easy access to the 2ld. Examples are more difficult to come by here but one obvious one is amway (where there is a network of agents and it is clearly unambiguous) The DNC would need a process to hear appeals from those claiming to be in the community of interest and enforce decisions. 5. Q: Is the current process for creating new 2LDs too simple, too complex or about right? A: too complex comments: The present system is far to complex and long winded. It is also process rather than outcome driven. This should be reversed. 6. Q: How much, if anything, should an application for the creation of a new 2LD cost? A: Minimal cost to reflect the essentially mechanical nature of the application. It should equate to no more than one or two days work, say $1000-$2000? 7. Q: Who, if anyone, should be able to block the creation of new 2LDs? If so, why and how? A: The DNC/NZOC based on the 2ld being likely to cause offensive, or promoting illegal activities. 8. Q: Should there be different criteria or processes for the creation of moderated as opposed to open Second Level Domains? A: No 9. Q: Is the level of public input in the process adequate; excessive; or inadequate? A: excessive comments: The current process is far to cumbersome 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: 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: Such registrations do not allow equal access being rather first come first served. This latter approach should be reserved for the 3ld. 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: Stick with first come first served 13. Q: What is the best way to deal with any conflicts between existing third level registrants if the second level is opened? A: 14. Q: Should registration fees be different (higher/lower) for Second Level domain registrations if they are opened directly to the public? A: No 15. Q: Are there other options around the future of the Second Level that the working group should consider? A: 16. Q: Are there any other issues you think the Working Group needs to consider in the course of the review? A: