From: Michael Clancy To: jolim@auda.org.au Subject: Consultation response Jo Thank you, for the opportunity of providing feedback. I provide this feedback particularly from the perspective of an Internet user and I am certainly no expert in the area of domain name administration or the Internet in general. However I do have a keen interest and hold a position on the management committee of Bathurst Community Website Inc., one of the One City One Site pilots. I am not in favour of lifting the restrictions my reasons for holding such a view are outlined below. Disappointment with the existing process To start off with I must say I am appalled that a reputable organisation like auDA would even be asking such questions prior to the full implementation and evaluation of its existing policy through the currently endorsed One City One Site pilot project. Not to mention the potential of inappropriately influencing submsissions by publishing the opinion of a board member as part of the consultation. As I see it this process denies natural justice to those, individuals, businesses,organisations and communities who have entered into auDA’s One City One Site pilot projects in Ballarat, Wollongong and Bathurst in good faith. By auDA asking these questions at a time when the current policy has not been fully implemented and evaluated could lead one to question the motivation of whoever is driving this agenda. It could be asserted that the real agenda has been to support the One City Project as a wedge to prise the geographic place names out of the “restricted” bucket and make them available for commercial exploitation. Even the information given on the website as a prelude to this consultation gives the impression that auDA has little commitment to its current policy, as it wasn’t agreed to be auDA but was a “hangover” from the previous organisations that administered the DNS. To intimate that the policy is some how “old hat” is disingenuous to say the least. AuDA has been receiving community feedback over the last 4 years at least relating to this policy and as late as 2003 was involved in establishing the National Reference Group overseeing the One City One Site project as a response to community feedback. auDA’s responsibility in managing the DNS As a self regulatory body endorsed by the Australian Government auDA has a responsibility to manage the industry for the public good as is indicated in the auDA constitution where in the preamble it states… “Taking the view that the Internet Domain Name System is a public asset, and that the .au ccTLD is under the sovereign control of the Commonwealth of Australia, auDA will administer the .au ccTLD for the benefit of the Australian community.” I would assert that the One City One Site Project supported by auDA is consistent with this objective. I for one, was taken to believe that auDA, through the involvement of its board members in the National Reference Group assessing the One City One Site project were doing so in good faith surely if auDA was concerned that public opinion was shifting it should have held this consultation before supporting this project. Competition and Level Playing Fields I certainly do not believe that a proper evaluation of the effectiveness of the existing policy can be carried out unless the community based websites using the locality.state.au names are actually operating and have been operating for some time. To this end my expectation is that once given the ownership of the bathurst.nsw.au name space under the “One City One Site” pilot project our organisation would be able to run this site for its initial two year agreement without interference from others using the “Bathurst” place name in the .com or .net 2LD’s. I understand the concept and value of “competition”, but I also understand the concept of “level playing field” and a commercial business operating in the well known .com 2LD competing with a non-profit organization in the virtually unheard of .state 2LD is not a level playing field. Sustainability of Community Based Portals in State Based 2 LD’s The need to restrict geographic place names from the .com and .net 2LD’s is essential to ensure the sustainability of community based portals. These portals need to have access to an income stream that will make them independent of government or other philanthropic funding to ensure their sustainability. The major asset of organizations like Bathurst Community Website is our place name “Bathurst” which is recognisable, as .nsw is a much lesser asset than .com. To lessen the value of our major asset is to place at risk our potential income, which is needed to fund our community, based activities. Currently there are commercial websites that operate as community portals, many of which are successful in promoting business in their local communities, eg “yourguide” and “xtralocal” sites. Such websites also offer a service for community organizations as an adjunct to their main business. However, unlike the business side of their websites the community based component is generally severely lacking. The commercial sector to date has not been able to provide an acceptable web presence for community organizations even when supported by large commercial businesses like Rural Press who are involved in the “Your Guide” websites. What is required is to give community organizations like ours a go at trying to provide a quality web presence for the whole community including local community based organizations. I believe the locality.state.au name space gives us the opportunity to do so but it needs access to an ongoing income base. Our organization is currently trialing a business strategy that aims to do just that. We aim to establish a business plan template that could be used by other non-for profit organisations, that wish to operate similar portals in their own locality. It relies on receiving advertising income from local businesses. In some ways we are competing with websites like “Your Guide” and “Xtralocal for the advertising dollar, however we believe we can gain enough of the local advertising dollar to support our site based on our organization having access to our main asset, the name “Bathurst”. However our research would indicate the potential for the bathurst.nsw.au name raising advertising income if there was a bathurst.com.au is nil. I certainly understand that profit oriented organizations, do not have community development as their core business. So there is no intended criticism of businesses such as “Your Guide” and “Xtralocal” who provide very good business directory services. It is organisations like ours who should be given the opportunity to put in place a system which could provide quality, whole of community websites, without having to compete directly with commercial entities in the more favourable.com.au and .net.au spaces. Dealing with anomalies One argument made in the submissions has been that by restricting place names from the .com and .net domains has had an unfortunate effect on individuals who share the same name as a geographic locality and that auDA should lift the restriction for the sole purpose of removing the anomaly. I suppose it depends on whether removing the anomaly by lifting the restriction thus allowing one Mr or Ms Windsor to claim Windsor.com.au is of greater community benefit than protecting the integrity of the locality name. I would suggest that more Internet users would be expecting to find out something about the locality Windsor, NSW when typing in Windsor.com.au than would be expecting to find out about John or Sally Windsor. As I understand it John or Sally Windsor could use johnwindsor.com.au or sallywindsor.com.au or could use windsorcafe.com.au or windsorlaundramat.com.au any of these options would in fact more clearly define what a user might expect to find at that site. The fact that users might expect to find information about a locality at freemantle.com.au is an issue of educating the community to using the new state ased 2LD’s, rather than a justification as to why geographic names should be released to the .com and .net 2LD’s Another argument has been that because there are some exceptions eg Melbourne.com the way to deal with this anomaly is again to remove the restriction. The number of exceptions at this point in time is minimal, less than 10 in total as far as I am aware. To argue that auDA should release thousands of geographic place names to the .com 2LD because there are currently a handful in this position is ludicrous. Decisions relating to the administration should be made based on an agreed principles and exceptions dealt with on a case by case situation. Using 2 LD’s to make the DNS easier to use for the public. What is required is the development of well-defined 2LD’s and I believe auDA at this point in time should be concentrating on developing stricter criteria for operation within each 2LD and educating the Australian community about the operation of the Australian Domain Naming system. The locality.state.au system sets a well-defined standard, that is, that information about a geographic location can be found at this address. AuDA should be supporting this by training the Internet using community that this is where you go to find out information about the community at that geographic location. By not allowing locality addresses in the .com and .net 2LD’s strengthens the purpose of 2LD’s. As I understand it the purpose of a 2LD is to assist the user in finding the information they want. One of the problems Internet users face is what 2LD will I type? One of the reasons they have this problem is that they don’t understand what 2LD’s are about (an issue auDA should be addressing) and that the application of the 2LD name spaces are not clear or intuitive enough for the common and more so the infrequent internet user. If auDA accepts that there is a purpose to 2LD’s and that it is a “good” to have 2LD’s clearly defined and well understood. I would assert that keeping locality names to the existing 2LD’s (including the state based 2 LD’s) is more likely to achieve this “good” than having locality names further scattered amongst the 2LD’s Michael Clancy -------------------------------------------------------------------------------- Find local movie times and trailers on Yahoo! 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