From: Nathan Jones 
Sent: Wednesday, 7 January 2004 5:18 PM
To: jo.lim@auda.org.au
Subject: Submission: Community Geographic 2LDs (registrar options)

Dear Jo Lim,

This message is in response to your call from submissions relating to Community Geographic 2LDs. 
There are two documents open for public comment.


1. Domain Name Policy Rules and Guidelines

I am pleased to see a strong focus on ensuring that domains are only used for community websites that 
truly represent the community. I agree with the eligibility criteria and the requirement that 
eligibility be demonstrated at the end of each two-year period.


2. Registry / Registrar Options

Five options have been identified. My preference is for a single registrar for all 2LDs, allowing 
consistent application of the policy and its eligibility criteria. Ideally, the registrar function 
would be performed by a community minded not-for-profit organisation.

In regard to the various options:

+ Multiple registrars for all 2LDs.

Having multiple registrars is appropriate for more open namespaces, such as com.au and net.au. For 
community 2LDs, however, it may be more appropriate to have a single body that has community interests 
at heart.

Having a large number of registrars may increase the risk of the policy not being applied as carefully 
as it should.

Additionally, the document mentions using the existing 19 auDA accredited registrars. It is possible 
that not all registrars would want to handle community 2LDs, because:

- The market is of limited size.
- Deployment may require initial development work.
- A much more rigorous set of eligibility criteria must be enforced,
  which equates to greater administrative costs than for other .au 2LDs.

+ Single registrar for all 2LDs.
+ Single registrar for each 2LD, or group of 2LDs.
+ Combined registry/registrar for all 2LDs.

Any of these options would be suitable. I don't think there is any benefit in splitting the namespace 
so that individual 2LDs or groups of 2LDs be handled by different bodies, however it could be split if 
a prospective registrar operator does not wish to manage all geographic namespaces.

Regarding the combined registry/registrar option: this is acceptable (as stated, due to limited the 
number of available domain names and the not-for-profit status of registrants), but does not need to 
be specified up front when tendering for a registry operator. I suggest that interested parties be 
invited to tender for operation of the registry, registrar, or both. It may be that the most suitable 
registry operator may not want to act as registrar and vice versa.

+ State/territory governments act as registrar in their own 
+ jurisdiction.

Governments already do this for *.gov.au domains, each with their own policy. In this case, the policy 
is already set and there is no advantage to having domain registration handled by government departments.

-- 
Nathan Jones