Second Level Domains Policy Review Submission

From:		David Zanetti
Received:	1 October 2003


1.
Q:  Are the twelve second level domains still appropriate for 
their communities of interest? 

A: For moderated 2LDs, they appear to be largely still appropriate, 
with the exception of "cri". For unmoderated, there is obviously 
some lack of use of the appropriate namespace (eg, companies 
routinely register .net.nz names, many individuals register .co.nz 
instead of .gen.nz or now .geek.nz and .maori.nz), but none-the-less 
no other system would be any more useful.

2.
Q: Should any of the open 2LDs be moderated? (.ac, .co, .gen, .geek, 
.maori, .net, .org, .school)

A: yes
comments: .ac.nz and .school.nz should be moderated to reflect their 
institutions. Typosquatting in .school.nz could be embarassing to 
InternetNZ. As the holder of sex.school.nz, I do firmly believe that 
theese namespaces don't serve a lot of purpose if made open-slather, 
.org is just as appropriate in that case.

3.
Q: Is there any need for the rationalisation of the current 2LDs? 

A: .cri.nz and .mil.nz are of debatable value being moderated and 
very small. 

    3.1
    Q: If so, what process should be used for the removal or closing 
of existing 2LDs?:
    
    A: Automatic removal if a namespace remains empty of registrations 
for x months, voluntary removal of the namespace and names if x% of 
nameholders agree to it's removal.
    
    3.2
    Q:  Should any such process be included in the 2LD policy?:

    A: Yes, it should be clear why and how a 2LD is removed. While 
it is true it is unlikely to ever ocurr, it should none the less be 
something for which there is a clear process to follow.
 
4.
Q: What criteria (types of criteria and specific examples) should 
be applied to the creation of new 2LDs? 

A: - Non-confliction with existing namespaces (eg, .com.nz should 
     be rejected as it obviously overlaps with .co.nz)
 - For unmoderated namespaces, a community must be large and all-
   present and not merely existing. For moderated namespaces, the 
  criteria depend on it's policy of moderation, but I see it 
  being much more relaxed about the community of interest's size. 
  Moderation policies must be explicit, objective, and reasonably 
  enforcable (eg, content-based moderation is probably out, as 
  it's neither objective nor enforcable).

5.
Q: Is the current process for creating new 2LDs too simple, too 
complex or about right? 

A: too complex
comments: - Reduce the repeated parts of the process, down to:
  + Base criteria check by DNC/InternetNZ
  + Published, submissions
  + Straw poll
  + Assuming it passes poll, final decision by InternetNZ

6.
Q:  How much, if anything, should an application for the creation of 
a new 2LD cost? 

A: With a simplified process, and with lower percentage requirements on 
straw poll, I would support raising the application fee, but the fee is 
really about covering costs, not as much a barrier (except to truely 
trivial applications).

7.
Q: Who, if anyone, should be able to block the creation of new 2LDs? 
If so, why and how? 
A: No, it should only be blocked by either failing base principles, or 
by court order.

8.
Q: Should there be different criteria or processes for the creation of 
moderated as opposed to open Second Level Domains? 

A: As noted above, I believe there are slightly different criteria 
for moderated vs unmoderated domains. Moderated domains should be 
tested on their expected volume and moderation policy, unmoderated 
based on very broad commonality and community, not merely that it 
exists.

9.
Q: Is the level of public input in the process adequate; excessive; 
or inadequate?

A: excessive
comments: As noted above, two submission rounds is a little much. 

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: It's about as good as it'll get. 

11.
Q: Do you think direct public registrations should be accepted at 
the second level?  

A: no
Comment: 

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: The only sane course of action would be to do what .ca did - nuke 
the space, and start from scratch. Not only is the registration date 
data from Domainz incorrect and can't therefore be used to arbitrate 
between competing names, but the only way to ensure confusion is kept 
to a minimum is to scrap all existing 2LDs.

13.
Q: What is the best way to deal with any conflicts between existing 
third level registrants if the second level is opened? 

A: Not to have them. I don't think InternetNZ or the DNC wants to 
end up in court over a three-way battle to "paradise.nz" because 
there's "paradise.gen.nz" (a good friend of mine), "paradise.net.nz" 
(the ISP) and "paradise.co.nz" (the rental car company) and I think 
each one of them as an equal right to the name. There are enough 
conflicts to end up in the courts for a long time.

14.
Q: Should registration fees be different (higher/lower) for Second 
Level domain registrations if they are opened directly to the public?

A: No, there should be no registration at two different levels. Either 
it's all registration at the 2nd level (and therefore the same fees as 
today), or there's only registration at the 3rd level.

15.
Q: Are there other options around the future of the Second Level that 
the working group should consider? 

A: None really, the choices are simple:
- Status quo
- Status quo with simpler requirements
- No 2LDs

Anything else is simply going to cause more problems than it's worth

16.
Q: Are there any other issues you think the Working Group needs to 
consider in the course of the review? 

A: Much of the "get rid of 2LDs" argument is a solution looking for a 
problem I don't believe exists. Just because other namespaces operate 
without 2LDs doesn't make them any more or less correct than those 
which do. 

The choice was made, wrongly or rightly, when the space was set up. 
The costs to play around with it could be beyond just every business 
having to reprint and change all their URLs, it could end up in the 
courts, and send a very clear message that, no offense, a small group 
of people decided what was best for the community for academic reasons.

Does the namespace work now? Yes it does. Sure, .co.nz is bloated, but 
.com is as well, and no-one is proposing we dismantle all the gTLDs 
because of it.

There also seems to be this love of flat namespaces which goes against 
the effort to get the Internet away from having one. The DNS was 
implemented specifically to remove the unmanageable flat namespace 
which existing before it. Why some people want to head back to that 
as a utopia seems blind to the very good arguments for creating the 
DNS in the first place.