Jo Lim
Chief Policy Officer
auDA
107 Faraday Street
CARLTON   VICTORIA  3053

Dear Jo

I am writing in my capacities as:  Deputy Chair, Geographical Names Board of NSW;  
immediate past Chair of the Intergovernmental Committee for Surveying and Mapping 
(ICSM) and an original member of OCOS.

The fundamental principle embraced by all naming authorities in Australia is that 
the use of geographic names (European and indigenous) belong to the community at 
large as these names are part of our culture, heritage and landscape.

The consistent use worldwide of geographic names through unique, unambiguous systems 
is supported internationally though the United Nations Group of Experts on 
Geographical Names comprising representatives of all member nations 
(www.un.org/Depts/Cartographic/english/ungegn.pdf).

I would argue that International and National policies developed for the community 
use of geographic names appearing on maps, charts of all descriptions and in 
databases are equally applicable to the World Wide Web.

There is no doubt that the World Wide Web opens up tremendous new opportunities for 
communication and business which requires new approaches, however the major problems 
with lifting the current restrictions on geographic names as I see it are:

1 Confusion over having multiple urls incorporating the same geographic name, i.e., 
Bathurst.nsw.au;  Bathurst.com.au.  Bathurst.net.au.  All Australian governments 
have gone to extraordinary lengths to ensure all physical addresses are unique and 
unambiguous for service delivery through a national standardized approach.

2 Geographic names will potentially be assigned to a single commercial entity on a 
“first come first served” basis at the expense of the community that lives there.


3 Nothing has changed from the original proposal by OCOS, endorsed by the Online 
Council and supported by bodies including Local Government.  Australian Chamber of 
Commerce and Industry and numerous not-for-profit community groups to retain 
geographic names for community use as domain names.  Lifting the restriction after 
approving and supporting the piloting of this concept would be somewhat hypocritical 
of auDA.

The existing policy which allows unlimited and unrestricted use of geographic names 
in conjunction with a prefix or suffix, e.g., bathurstradiators.com.au provides an 
infinite number of addresses for commercial use.

In summary, on behalf of the NSW Geographical Names Board (custodians of 
100 000 NSW geographic names), there has been no compelling evidence or identified 
shift in public attitudes to lift the current restriction on geographic names.

I would urge auDA to defer this matter for a further 2-3 years until the new 2LD’s 
for community use are fully implemented.

Yours sincerely



Paul Harcombe