From: Bruce Tonkin 
Sent: Friday, 23 January 2004 3:03 PM
To: jo.lim@auda.org.au
Subject: Submission on community geographic 2LDs

Hello Jo,

Thank you for the opportunity to provide input on the community geographic 2LD options.

I read the paper on the domain name policy rules and guidelines, and the eligibility requirements 
are quite involved and would require some expertise to apply - E.g demonstrating appropriate 
funding, and representation of the community.   The eligibility process seems similar to the process
engaged by auDA to determine whether to create new 2LDs (where ability to fund a commuity based 2LD 
and degree of broad community representation were also considered).  The relevant auDA committee had 
great difficulty in making those determinations.

I recommend separating the role of determining eligibility to hold a particular geogrpahic community 
domain name from the role of registrars (the actual technical maintenance of the domain name itself).  
The auDA competition committee in fact recommended this model for all 2LD spaces in .au. From 
http://www.auda.org.au/docs/auda-competition-final.html, section 2.4.3:
"The Panel recommends that compliance checks for non-objective policy rules be approved by an 
independent body before a domain name is submitted to the registry. Domain name applications requiring 
approval would be referred to the independent body by the relevant registrar; the independent body 
would not have direct contact with registrants. " A single policy eligibility body would provide 
consistency, and allow multiple registrars to manage the names.

I note that auDA used a similar process in the auction of generic names. auDA ran an auction, and 
determined the party that was eligible for a particular domain name licence.  The party could then 
approach any registrar to have the name registered and managed at the technical and customer service 
level.

With respect to the paper on Registry/Registrar options, I favour option 5 for the purpose of determining 
eligibility.  This will ensure consistency within each jurisdiction (this could also be provided by a 
single entity).  This model is used for example with respect to planning approvals, where once approval 
is obtained to build a particular structure, an entity can use the competitive market place of builders 
to handle the actual construction. In the short term auDA may wish to identify a single body (e.g the 
National Reference Group) to make the initial assessments and hence provide more detailed guidelines 
and examples for potential applicants. Overtime this responsibility could be delegated to local 
government agencies.

With respect to providing registrar services I favour option 1.  Once the uncertainty of the policy 
eligibility process is removed, a community based domain name is no different from any other domain name 
from the point of view of registrar services.  The prices would probably be similar to other low volume 
2LDs (e.g asn.au, org.au etc). Registrants can then take advantage of the full range of service options 
available in the competitive marketplace.  Many community organisations may already have relationships 
with telecommunication companies or local internet service providers, which in turn often have their own 
arrangements with their preferred registrar (perhaps based on geographic location), or with existing .au 
registrars.    There is already an established competitive marketplace for registrar services that handles 
a range of different types of 2LDs (e.g asn.au versus .com.au).  A local organisation that represents a 
wider set of domains may approach individual registrars for volume discounts and other managed services
(e.g email or web hosting of multiple domain names).   

In summary I recommend that auDA stay with the original competition model that was developed with 
extensive involvement of the domain name industry.  The competition model allows for a separation between 
a body that provides independent non-objective eligibility considerations, and the competitive registrar 
marketplace.

Regards,
Bruce Tonkin
Melbourne IT