From: Cook Michael [Michael.Cook@iie.qld.gov.au]
Sent: Monday, 30 September 2002 12:23 PM
To: jo.lim@auda.org.au
Subject: Geographic 2LDs - Discussion Paper


Ms Jo Lim
Chief Policy Officer
auDA
email: jo.lim@auda.org.au
Dear Ms Lim
Re: Geographic 2LDs - Discussion Paper

Thank you for the opportunity to comment on the proposed Geographic Second 
Level Domain (2LD).  The Queensland Government strongly supports the creation 
of a system of community-based geographic 2LDs, and supports the proposed new 
structure that combines the new 2LD with new third level domains (3LDs) for 
Australian communities.  

Our Minister, the Honourable Paul Lucas MP, along with other State and 
Territory Ministers, expressed support for the concept, and in particular, 
the "One City, One Site" proposal, at the Online Council Meeting in July 2001. 
Minister Lucas emphasised the benefits in terms of reducing the potential for 
cybersquatting on town and locality names by private firms for commercial gain.

The issues raised in your discussion paper are addressed as follows:

*	National uniformity. 
	Agree that it is important to achieve uniformity across jurisdictions. 
	This would require coordination by auDA.  However, given the proposed 
	role for State and Territory governments, effective and consistent 
	administration would also require an active role for a body such as the 
	Online Council Digital Divide Forum/Regional Communications Working Group.

*	Processes.
	This is the area that will require most attention. One of the submissions 
	suggests that the overheads for State Governments are likely to be minimal.  
	Although the process may be streamlined enabled by technology, the approval 
	and dispute resolution processes will have considerable resourcing impacts 
	for State and Local Governments.  

	In addition to advisory and registration activities, the potential for 
	disputes is significant, in particular, with competing interest groups within 
	a geographical area wanting to set up community portals. 

	The proposed pilot project (refer Implementation below) may address some of 	
	these issues. However, State and Local Governments will need to be involved 
	in the development of processes, through the Online Council, to ensure that 
	the concerns of each State and Territory are considered. These concerns also 
	reflect the challenges experienced presently within the gov.au domain in terms 
	of ownership of the registration process.

*	Community portals.
	Agree that the management of community websites or portals is a separate issue 
	to the allocation of domain names. The management of community portals raises 
	further issues, not the least being the question of sustainability.  It is 
	likely that this may be an area for competitive provision as well and this 
	should be able to be accommodated.

*	Domain name structure.
	Agree that any community, based on reference to State and Territory Geographic 
	Names Boards, should be eligible to obtain a third level domain e.g. 
	biloela.qld.au, with no further hierarchy of names.

*	Registry.
	Support in principle. However, based on experience in the gov.au domain, this 
	may present challenges in practice to provide a flexible arrangement that meets 
	the needs of States and Territories. It may be useful to seek input from the 
	Commonwealth, State and Territory governments into the development of the tender.

*	Ancillary domain names and geographic names in other 2LDs.
	Many Queensland communities are looking to establish their presence on the web 
	through a community portal. The proposed hierarchy of community portals appears 
	to be a straightforward structure. It does, however, assume that each community 
	will have only one portal. The related point regarding removing the prohibition 
	in com.au on geographic names would begin to address this issue.  Hence, placenames 
	such as "Brisbane" would not be owned by any one entity, not even the community, 
	and it would open the door for businesses to use their community name within their 
	domain name. This presents an opportunity for the com.au domain to establish a 
	complementary policy that also brings it into line with the .com domain, and perhaps 
	limits the migration of Australian websites to the .com domain.

	The Online Council Digital Divide Forum/Regional Telecommunications Working 
	Group would ideally have a significant role in providing advice on establishing 
	a hierarchy of national community-based portals.

*	Definition.
	Agree that it is important to achieve uniformity across jurisdictions in this area. 
	The Geographic Names Boards of each State and Territory would be key players in this 
	regard.

*	Implementation.
	Agree that a pilot would be extremely useful in working through the process and 
	implementation issues. Communities, and other stakeholders, would need certainty 
	regarding the structure and its management before committing potentially significant 
	investment into establishing governance structures, developing applications, negotiating 
	with stakeholders, and undertaking other associated activities.

Should you have any queries regarding this submission, please contact Ms Caroline Gordon, 
Information Economy Policy, on telephone (07) 3224 6868.

Yours sincerely


Michael Cook
Executive Director
Information Economy Infrastructure

27 September 2002