From: 
Sent: Tuesday, 10 August 2004 3:19 PM
To: Jo Lim
Subject: Re: [announce] auDA Panel reviews domain name policy rules






Dear Mr Lim -

Thank you for the advice regarding the auDA Name Policy Review Panel. Please accept the following 
as an official submission to your panel.

1. The Salvation Army supports the existing requirement that registration of domain names with the 
".au" suffix be limited only to Australian residents, businesses and organisations.

We have had experience where a ".com" domain name has expired while in the process of being renewed, 
and was snapped up immediately by a domain name pirate in a foreign country. This left us with the 
only recourse of an expensive legal process to reclaim the domain name, which we were not in a 
position to pursue.

We believe that opening up ".au" domains to registration by individuals and businesses in foreign 
countries would enable this poaching to occur in the Australian DNS, which would be detrimental to 
domestic domain name registrants.

Further, our marketing research and experience has found that as people become skilled in web 
browsing, their first step in locating an organisation on the World Wide Web is to type the name of 
the organisation in the address bar followed by a 2LD ".au" suffix. This is called domain surfing. 
These skilled web users will only go to a search engine as a last resort.

The use of ".au" is therefore intuitive and expected within the Australian community as representing 
only Australian organisations and businesses.

2. The Salvation Army supports the proposal that ".au" domain names be available for registration on 
a 1, 2 or 3 year basis.

The current 2 year only registration policy discourages the use of a temporary domain name for a 
special one-off promotion. This would be resolved with a 1 year registration period.

Conversely, the renewing of long-held domain names every 2 years represents an undue burden that could 
be eased by allowing a 3 year registration period. This would be a compromise between keeping 
registrant details current and giving an extended registration period.

We have found in the past that some DNS hosts were unwilling to carry transferred domain names because 
of the lack of income until the next renewal. However, it now seems to be a common practice to pay the 
domain name registration fee AND an annual fee for DNS hosting. Therefore, the concern of resellers or 
registrars not being compensated for carrying domain names is being dealt with by those businesses and 
should not be an auDA consideration.

 3. The Salvation Army supports the proposal to reintroduce differentiation between ".com.au" and 
".net.au" domain names.

Because this differentiation has been relaxed or unenforced over the last few years, we have had to 
register domain names in both 2LDs because skilled web users will domain surf straight to 
"salvationarmy.com.au" or "salvationarmy.net.au" and we need to ensure we capture visitors to both. 
This duplication of cost would be unnecessary if it were implicitly understood that ".net.au" domain 
names are only used by companies in IT and telephony networks.

However, if this differentiation is reintroduced, then auDA will also need to embark on a communications 
strategy to ensure that the public, as well as resellers and registrants, know that ".net.au" is only 
for IT and telephone network businesses. The blurring of the lines over the last few years will have to 
be repeatedly clarified to the public.

4. The Salvation Army supports the current eligibility criteria to differentiate ".asn.au" and ".org.au" 
domain names.

If this differentiation is relaxed, then we will be obligated to the duplicated expense of registering 
domain names in both 2LDs to ensure we capture visitors to both, the same as we have had to do with  
".com.au" and ".net.au" domain names.

Our primary domain name, which we promote heavily across Australia, is "salvationarmy.org.au". Skilled 
web users understand and differentiate between ".asn.au" and ".org.au" domains, and we voice our 
objection to any diluting of the value of this domain.

5. The Salvation Army supports the proposal that the "close and substantial" rule and the "exact match, 
abbreviation and acronym" rule be combined. We do not have an opinion on the proposed changes to the
connection warranty, but common sense would indicate the above rules could be integrated.

6. The Salvation Army cautions auDa that unrestricted registration of ".id.au" domains for personal use 
is inherently prone to abuse, but cannot see that the current rule of checking that nicknames are 
"reasonable" is any more enforceable than the proposed deregulation of this 2LD. It has been observed 
that a number of businesses are using ".id.au" domains, which indicates that there is no current 
policing of these registrations.

Sincerely,

Michael Bouy
Internet Communications Coordinator
The Salvation Army Public Relations Department
Australia Southern Territory