From: Richard Archer 
Sent: Sunday, 20 May 2001 3:48 PM
To: jo.lim@auda.org.au
Subject: Response to Second Report for Public Consultation

Ms Jo Lim
Chief Policy Officer
.au Domain Administration
GPO Box 1545P,
Melbourne VIC 3001

Dear Ms Lim,

I wish to express concern over the proposed recommendations contained in the 
auDA Competition Model Advisory Panel's Second Report for Public Consultation.

In particular, the proposed Registry model seems not to be based upon either 
option 4.3 A nor 4.3 B from the draft Stage 3 report, but rather is a hybrid 
model which fails to realise the possible benefits of the either of the original 
options.

It must be realised that within the .AU domain, the only 2LD with significant 
demand is .COM.AU. For a typical business considering registration of a .COM.AU 
domain name, none of the other 2LDs of .AU are viable alternatives. The only 
realistic option for such a business would be a .COM domain or a domain within 
one of the "boutique" CC-TLDs. There is no real competition between the various 
2LDs of .AU.

Thus the Competition Model Advisory Panel cannot in good faith propose a model 
which promotes multiple registries, one per 2LD within the .AU domain, and call 
this "competition" when in fact all that is happening is a formalisation of the 
monopoly within the .COM.AU domain.

It is this monopoly which has seen little to no innovation or reduction in cost 
of registry services over the last several years within the .COM.AU domain. the 
procedure for registration, delegation and management of a .COM.AU domain is 
almost exactly as it was when Melbourne IT first launched their service. Domain 
registration charges are as they were when the service was launched, albeit 
with more responsive service levels. I cannot imagine the operator who wins 
the tender to operate this registry being any more innovative or competitive 
than we have seen from the incumbent.

It is my belief that the .AU namespace is not a good candidate for either single 
or multiple commercial entities to operate as registries.

The remaining option is to develop the existing AUNIC-based model and create a 
not-for-profit organisation chartered with the role of operating and developing 
a registry system in a cost effective and innovative manner.

This option would result in a single stable entity to take on the role of 
managing the registry services for whichever of the .AU 2LDs wished to partake. 
There would still be the option for 2LDs to continue to operate their own 
registries should they so desire (for example if they believe they can offer a 
better, more reliable or cheaper service).

The creation of a new body to take on this role, while the obvious choice, may 
be unnecessary. It seems to me that auDA would be in the best position to take 
on this role. In fact in the existing proposal in the Second Report for Public 
Consultation auDA is already committed to setting up and operating a large 
proportion of the infrastructure required to run the registry. From recommendation 
4.3:

  Registry information will be published in a central data register to
  be maintained by auDA, by replicating the registry data in a central
  repository.

  auDA will set minimum technical standards, data protocols, security
  and service level requirements for the registry operator(s).

  auDA will develop a disaster recovery plan, so that it is in a
  position to protect the .au domain and related infrastructure.

In particular, the disaster recovery plan will require auDA to maintain 
infrastructure capable of taking on the entire registry operation in the event 
that a disaster befalls the registry operator(s).

Whether auDA or another body takes on the role of registry operator, by ensuring 
the underlying registry service is reliable, innovative and cost effective auDA can 
facilitate the introduction of competition where it most matters -- at the registrar 
level.

Yours sincerely,

Richard Archer.