From: Peter Shilling 
Sent: Friday, 8 October 2004 9:24 AM
To: 'Jo Lim'
Subject: Submission for the Name Policy Review Panel Public Comment

Jo,

Please add this submission for the Name Policy Review Panel Public Comment

I would like to focus in this submission on the issue of registration terms, a topic that has 
been looked at by the panel.

Currently in .au we only accept registrations for a 2 year period. There has been a discussion 
around this topic both at this panel and registrars and resellers alike.

I believe that .au should be altered to allow registration periods between 1 and 10 years, in 
much the same way as the gTLD space, (and others; TPP Internet is a registrar in New Zealand 
where they also accept 1 to 10 year
registrations) 

I note that one of the main objections to longer period in other submissions that you have 
received, raise the issue of maintaining current data for registrants over this period of time. 
This is an issue for registrars regardless of the period of registration and renewal. When a 
registrant renews a domain name now, it is quite probable that they don't confirm their details, 
meaning even though there is a new period granted the data may contain inaccuracies. 

TPP Internet has adopted the approach of sending annual notices to registrants to request they 
update their data. This process has been well received by our customers. I suggest that to 
counter the panel's concern on this issue that you recommend this as best practice to 
registrars.

In your draft recommendations, you suggest other issues.

"potential for registrants to hold desirable domain names without using them for a long period" 
-- this is not something that is directly relating to longer periods of registrations. In the 
current system there is nothing to stop such a registrant from simply sitting on a name and 
renewing it each two years. I hardly think this is a just cause to rule out longer terms and 
miss out on the benefits of a change.

"potential for registrars and resellers to go out of business in 5 or 10 years"

Again, I can not see how this directly relates to the longer terms. An auDA registrar must 
renew a domain name in the registry if they receive a renewal request from the registrant. If 
the registrar goes out of business, the process that auDA currently has to handle this 
situation would handle the situation. auDA takes the names over and begins a process to have 
the registrants transfer to another registrar.

I can not see the impact of longer periods on this process.

"possible negative impact on registrar market competition at a relatively early stage of 
industry development"

Agreed that if 10 year registrations were available in 2002 this may have had an impact; 
registrants would not have had a reason to move between registrars. I believe that the market 
has matured enough to cope with this now. It is well recognised that registrants taking up 
longer periods of registrations would be the minority; this is certainly the case in our 
experience in both the gTLD space and in New Zealand. This would have no negative impact on 
the ability of our industry to remain competitive. 

Kind regards,

Peter Shilling
TPP Internet