Ms Jo Lim
Chief Policy Officer
.au Domain Administration Ltd (auDA)
107 Faraday Street
CARLTON.  VIC 3053.


Dear Ms Lim

In response to your call for comments on the draft proposal of your New Names Advisory Panel for 
a submission and evaluation process, mandatory elements and selection criteria for new 2LDs, 

I bring to your attention the following suggestions made in this Department: 

• As the management of the .au domain as a national resource is a relatively minor and new industry 
with indications of a comparatively modest annual turnover and growth rate;and –
• As the Panel judges the creation of new 2LDs would require significant effort;
o a cautious approach in their introduction might be preferable;

• The Panel's recommendation that the creation of a new 2LD must be in the public interest and that 
auDA should not approve proposals for new 2LDs which primarily serve a single organisation or 
individual, could benefit from clarification before it is translated into an operational guideline, 
bearing in mind that:
o There are a wide range of interests, for instance, sectoral, community plus commercial and 
individual, which could present, at least, superficially persuasive arguments that they are contributing 
to the 'public interest', in a broad sense, i.e., to a common good, and
o On the other hand, there are different, and one would say, also inappropriate implications for auDA, 
in its role as a market regulator, if people interpret the Panel's reference to 'public interest' in 
the specific sense of government responsibility for ensuring basic rights, access and equity for all 
citizens.

• The Panel's advice of Mandatory Elements for inclusion in proposals for new 2LDs, could profitably 
be edited to give applicants more insight about the requirements for the business case and financial 
viability statement which must be essential for proving the need for a new 2LD.  The current list gives 
little insight into the relative significance and magnitude of the various items in the list.

Yours sincerely



Evan Arthur (Dr)
Branch Manager
Innovation Branch
Higher Education Group

3 February 2003