From:           Glen Eustace, GodZone Internet Services
Received:    Tuesday, 4 June 2013

Question 1. If you consider registering a .nz domain name in the future, would you like anyname.nz to be an option rather than a name under just the second levels, e.g. anyname.co.nz?

No
I am not in favour of opening the 2nd level and believe that .co.nz should continue. If the proposal however is successful, then it may be better in the longer term to close the current 2nd levels but that will have an impact on the moderated 2nd levels.

Question 2. Would likely short term confusion over a transition period be an acceptable consequence for offering a long term option of allowing .nz registrations at the second level?

No
I cannot see any significant benefit in opening the 2nd level. Had .nz's 2nd level been open from the start as is the case with many other ccTLDs, there would be no confusion but having opted to follow the .uk and .au models it will just become a mess.

Question 3. Do you agree that existing .nz registrants should get a priority right in obtaining their name at the second level if this proposal proceeds?

Yes

Question 4. Do you agree with the approach in the draft amended policies if we proceed with this? What, if anything, would you change?

Yes
But I don't think that the issues that will arise from having to deal with conflicts and disputes are worth any perceived benefit in opening the 2nd level in the first place.

Question 5. Do you support the proposal that a current registrant of a .nz name at the third level should be able to reserve that name at the second level for no cost if they wish to block others from registering it but not actually utilise it themselves?

No

Question 6. Is two years an appropriate time to wait before reviewing policy to allow a reservation at no cost? Should this time frame be longer?

Yes

Question 7. Is two years an appropriate time to wait before reviewing the policy to extend the Dispute Resolution Service to sub-domains of second level registrations? Should this time frame be longer?

Yes

Question 8. Do you see any benefits from allowing registrations at the second level which have not been covered in this paper?

No
And I don't really think the benefits suggested are worth it. If more choice is the goal, then relaxing the rules associated with the creation of new 2nd levels would be more appropriate and create options and choice within the existing structure. I don't believe having a flatter structure just because other ccTLDs have such a structure is an appropriate reason to change .nz

Question 9. Do you see any detrimental effects from allowing registrations at the second level which have not been covered in this paper?

Yes
How is Joe Public going to be able to distinguish between school.nz and kindergarten.nz ? Names at the 3rd level of .school.nz can be registered through any approved registrar with a well defined set of Terms and Conditions (and policies). Names at the 3rd level of .kindergarten.nz would be at the whim of the existing registrant being prepared to delegate sub-domains and they could set whatever Terms and Conditions they feel like with no protection for the 'person/organisation wishing to use the sub-domain at all.