From: Sam Bauers 
Sent: Thursday, 30 January 2003 2:02 PM
To: jo.lim@auda.org.au
Subject: Comment - Process for future consideration of new 2ld proposals

Dear Jo,

I have read through the proposed process for future consideration of 
new 2ld's and must say that I am impressed with the overall structure 
that is outlined.

Users on an international level have been crying for a process like 
this from organisations like ICANN forever, so I am glad to see an open 
and transparent process being proposed for Australia's domain space.

I have only a couple of very minor criticisms that I hope are 
constructive:

1. Under section [2], sub section [Submission Process] the following 
point:
	"A proposal will not be considered if it is materially the same as a
	 proposal that has been rejected by the auDA Board in the past 12 
months."

This may not go far enough to stop a persistent organisation trying to 
force an unwanted 2ld into .au
A 12 month period, although seemingly reasonable, is really only a 
superficial and arbitrary length of time. If there were some way to 
gauge an actual change in the market the 2ld was being proposed for, 
then that should be the basis for resubmission of a previously 
considered 2ld.

I would propose that rather than accepting a full resubmission after 12 
months, the panel should consider a smaller document first before 
accepting a full submission. This document would be required to outline 
how the proposed 2ld user base and/or the nature of the internet and/or 
it's usage differs at the time of the new proposal as compared to the 
last proposal (whether the proposal is from the same entity or not).

This would provide the panel and AuDA with the following benefits:
- No verbatim resubmission of 2ld proposals would be possible that 
would require due process and waste time
- A shorter public consultation process for these submissions in general
- The flexibility to accept resubmitted 2ld's in less than 12 months

2. Under section [3] (advisory panel):
	"The Panel recommends that auDA appoint a standing New 2LDs Advisory 
Panel
	 rather than a series of ad hoc Advisory Panels, for reasons of 
administrative
	 efficiency and policy continuity."

This panel would certainly be an important one and a policy for 
rotating this panel should be outlined. I would suggest 2 year periods 
with half the panel members being replaced every year so as to keep 
continuity. A new chair could be appointed every year from those panel 
members that are entering their second year on the panel, or the chair 
could simply be a permanent AuDA representative.

3. General:
A provision for consultation with independent experts should be built 
into the process. These consultants would be actively sought by the 
panel apart from the public consultation process. The public 
consultation process would rarely and only coincidentally invite the 
opinion of an independent expert in the given 2ld's interest group or 
target market.

Thanks for the opportunity to comment on this process, and overall, 
well done.

Regards, Sam Bauers

--
Sam Bauers
Viveka Web