From: Peter Shilling 
Sent: Tuesday, 21 September 2004 1:40 PM
To: jo.lim@auda.org.au
Subject: Submission for the competition panel

Jo,

 

Please find below a submission in response to the First Public Consultation Report, September 2004 

 

As a registrar, I have some concerns about the draft paper that has been released by the current Competition 
Panel.

 

The panel seems to be going to again propose that multiple registries in the .au name space is a viable option.

 

What concerns me is that while this may be idealistic thinking, the actual logistics of this are not workable.

 

With the evidence still being that com.au represents the vast majority of the market; it would be unreasonable 
for registrars to have to carry the expense of connecting to another registry to support lesser domain names.

 

A good, real world example is the pending release of Geographic based domain names (xxx.nsw.au). There are 
concerns already about the viability of such domains; their success will be hampered more if registrars don’t 
agree to support them. If the cost of supporting them includes interfacing and dealing with a separate registry, 
we cannot seeing it succeeding. This leaves even more concern for auDA, who wants to release new names under .au 
but cannot successfully to it due to fundamental flaws in the registry - registry model.

 

I would like the panel to consider that the vast majority of registrars are relatively small businesses, and 
added overheads to support minor domains would impede our willingness to operate on these domains. 

 

Take for example the following:

 

•     Maintaining separate cash accounts with multiple registries.

 

•     Entering into and maintaining multiple contractual relationships

 

•     Programming and supporting interfaces to each individual registry.

 

Each of these points multiplied by 2, 3 or more (for each registry that we have to connect to) means a more work 
and expense for little if any benefit.

 

If anything, multiple registries could well produce less competitive industry, specifically for the small 2TLDs, 
with registrars deciding not to support them as they are simply not economical. 

 

I think it important that the panel consider these real word facts when making changes to its current position.

 

 

Peter Shilling

TPP Internet