From: Bruce Tonkin 
Sent: Thursday, 7 June 2001 7:01 AM
To: 'jo.lim@auda.org.au'
Subject: Updated Response to the 2nd auDA Competition Model Advisory
Panel

To:
Ms Jo Lim
Chief Policy Officer
.au Domain Administration

Melbourne IT response to the 2nd report of the auDA Competition Model Advisory Panel
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========

Melbourne IT supports the recommendations listed in the Executive Summary of the report.

The competition model proposed is essentially a re-structure of the existing Australian 
domain name registration environment to meet international best practice.

The current model was developed when the number of domains registered per day was very 
low, and possible to be administered manually by a few individuals.  Individuals have 
also managed key components of the ".au" infrastructure (such as the registry and the 
authoritative nameserver) on a voluntary basis with some minimal network and hardware 
support from their employers.  This model is now inappropriate for an infrastructure that 
forms the basis for Australia's information economy.  The problems with the current model 
have recently been highlighted by the performance problems with AUNIC over the past few 
months that have severely restricted the ability for Melbourne IT to provide 
administration services to register or update customer records for ".com.au" domain 
names, and the long delays to register or update ".org.au" records.  auDA has now taken 
the first step in reform through taking over responsibility for AUNIC, and arranging 
for the upgrade of the computer platform that runs the AUNIC software, and arranging 
for the computers to be housed in a carrier-class data centre.  This relatively simple 
change took at least 6 months of planning.

Melbourne IT seeks to have access to all the existing open second level domains (asn.au, 
com.au, id.au, info.au, net.au, org.au) as soon as possible.  This will ensure that 
Australian consumers can take full advantage of the choice already available (but 
presently difficult to access).  This could be done in advance of the final technical 
solution proposed for the registry in the report, by appointing new registrars for those 
domains that presently suffer from poor service levels, and requiring the registrars to 
provide wholesale pricing for resellers in return for the resellers providing customer 
service (as presently happens with ".com.au"). This would also require a review of the 
eligibility rules for ".info.au" (which could be made consistent with the rules for the 
new top level domain ".info), and ".id.au" (which could be changed to allow registration 
directly at the third level and fourth levels in accordance with the new rules for the 
new top level domain ".name").  auDA should take advantage of the new top level domains 
being implemented in the second half of this year (2001) to increase the awareness of 
the full range of existing second level domains within ".au", and ensure that they are 
ALL being effectively managed. ".au" should set minimum service levels for registration 
in these existing domains consistent with the service levels presently available from 
".com.au" - ie at least 2 day turn-around.

Melbourne IT seeks to begin the implementation of the changes to the Name Policy approved 
by the auDA Board on the 8 May 2001.  Consumers are already trying to register domain names 
under the new rules (including an auDA Board member!), and the inconsistencies between the 
new rules and the old rules are creating consumer confusion and are increasing the already 
high rejection rates for ".com.au" names (which have consistently been around 30% of all 
names submitted).  Consumers have been pushing for changes in the name policy for several 
years now, and there is no reason to delay these changes until the full re-structure of 
the domain name registration industry takes place.  The consumer interest in the name 
policy is shown by the number of submissions to the names panel during the consultative 
process that far outweighs submissions to the competition panel.  By implementing the 
changes to the name policy immediately, auDA will be able to work with Melbourne IT to 
convert the policy into a practical set of operating procedures well in advance of a 
multiple registrar environment where it will be harder to build and maintain consistency.  
auDA also has the chance to test approaches to managing the non-objective compliance 
checks through an independent party (see section 4.4.3 of the report) well in advance of 
a full implementation of the industry re-structure.

Melbourne IT seeks to begin implementation of the ".au" dispute resolution policy as soon 
as it is approved by the auDA Board.  This again will allow auDA to gain some experience 
and build a set of previous decisions to assist parties in future disputes, well before 
the full re-structure is implemented.

With respect to the implementation of the proposed Competition Model, Melbourne IT wishes 
to emphasize that the new technical solution be carefully implemented to maintain the 
stability of the ".au" domain space as the prime objective.  A key component of the new 
model, is the development of a new technical standard for communication between the 
registries and registrars.  auDA would be wise to learn from the experience of the new 
top level domains (".biz", ".info", ".name") which are all developing new protocols as 
consistent as possible with the directions of the IETFs provreg working group (see Section 
2.3 of Attachment B).  These systems will not be operational until November 2001 (in fact 
the development of registry systems for these new top level domains is taking on average 
around 9 months of design and development).  Melbourne IT recommends that auDA form a 
technical working group (analogous to the ACIF working groups) to develop an Australian 
standard protocol using the outcomes from the IETF working group and the introduction of 
the new top level domains.  auDA should take advantage of the intense international focus 
on developing new registry/registrar systems during the later half of this year, before 
finally committing to the design of the protocol.  In the meantime, auDA can progressively 
introduce most of the reforms from the names panel and the dispute resolution working 
group, and begin to increase the availability of the existing 2nd level domains.

Given the timing of the new top level domains, it would be appropriate for auDA to consider 
running tenders for registries for the existing second level domains as well as new second 
level domains (e.g ".name.au").  This will ensure that when the new technical solution is 
implemented, a wider range of second level domains and registry operators will be available.

With respect to foreign involvement in the Australian industry, Melbourne IT recommends that 
auDA consider restricting registry operators and registrars to those with an Australian 
presence (ie those with an Australian registered company and employing staff locally in 
Australia).  This is consistent with the requirement to have an Australian presence to 
register a domain name within ".au".  Registry operational equipment should be required 
to be located in Australia for national defence reasons (ie ensure the continued operation 
of our information economy in the event that international communication links are severed).

In section 5 of Attachment B, the report raises the issues surrounding availability of 
information from the WHOIS database (either via single record lookup, or via bulk WHOIS). 
Melbourne IT recommends that auDA establishes a separate "WHOIS" working group to consider 
the policy (e.g privacy) and technical issues associated with this important service.  
The current WHOIS information both in Australia and internationally, is often abused in 
a competitive environment (for example through unsolicited emails, phone calls, and faxes).  
Problems have already arisen in competition between resellers of ".com.au".  This is an 
important industry issue, which will only get worse if it is not addressed as soon as 
possible.  

Melbourne IT also recommends that auDA take into account the current dispute amongst 
registrars of ".com", that relates to authorisation procedures for transferring domains 
from one registrar to another.  Inadequate specification of such procedures has led to a 
range of anti-competitive practices.

With regard to industry self-regulation, a key element for auDA to achieve legitimacy is 
to have a strong membership, and strong voter turn out within the membership for elections 
of the Board.  Melbourne IT requests that auDA publish details of the number of members of 
each class compared to an estimate of the number of potential members in each class (e.g 
number of members on the supply side of the industry versus the number of domain name 
registrars and resellers).  auDA should also publish the percentage of each class of 
member that voted.  Melbourne IT recommends that auDA devote some resources to increasing 
the partication of the industry in the auDA process, as the current membership base is a 
very small component of the Internet industry.  Melbourne IT supports recommendation 4.6.3 
as a mechanism to help increase participation.

Bruce Tonkin
Chief Technology Officer
Melbourne IT Ltd