From: Tizard, James (IEPO) 
Sent: Thursday, 7 December 2000 11:12 AM
To: 'jo.lim@auda.org.au'
Subject: Review of Policies in the .au second level domains


To: Ms Jo Lim, Secretariat, auDA Name Policy Advisory Panel 
Re: Comments on the 'Review of Policies in the .au second level domains' 

The purpose of this note is to provide comment on the 'Review of Policies 
in the .au second level domains' issued by the auDA Name Policy Advisory 
Panel (15 November 2000) as part of its first formal public consultation 
process. 

The Information Economy Policy Office (IEPO) does not wish to comment upon 
specific recommendations at this early stage.  However, IEPO would appreciate 
being advised of opportunities to comment upon further releases of the Report. 

The following general observations are offered in relation to the initial 
Report. 

The recommendations of the report seem to fall into two broad classes.  
The first of these affect how the Domain Name System (DNS) in Australia is 
administered and maintained as a public asset (i.e. sections 4.1, 4.2, 4.4 and 
4.5).  IEPO notes and agrees that whereas Australia is fortunate in being endowed 
with a robust, useful DNS, the unforseen growth in the size and commercial 
significance of the Internet in recent years gives grounds for review in some 
areas. 

The second class of recommendations (section 4.3) relate to the structure of 
the DNS hierarchy in Australia, both in terms of breadth (new 2LD's) and depth 
('gateways').  While recognising the diversity of views in this regard [1], 
IEPO urges caution in respect to any proposals that may affect the technical, 
informational or administrative complexity of the DNS, and would put forward 
as a general principle that the DNS hierarchy should be as 'flat' (i.e. simple) 
as possible while still allowing for efficient operation and administration.  
It seems to us that the DNS structure today is not substantially misshapen, 
and as such, does not warrant major repair.

[1]	The Management Of Internet Names And Addresses: Intellectual
Property Issues. World Intellectual Property Organization (1999). Paragraph 307 ff.


James Tizard
Senior Policy Advisor
Information Economy Policy Office
Government of South Australia