From:           Keith Davidson
Received:    Friday, 31 May 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 think it would be wise to "grandparent-out" the second level structure over time, and reduce confusion by seeking to collapse names into the 2nd level expediently.

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?

Yes
Recognising that many people using the Internet are not qualified typists / keyboard operators, it is logical that the shortest possible domain names and email addresses will result in fewer typographical errors, and therefore the change to 2nd level registrations increases the accuracy, resiliency and integrity of the DNS in the longer term.

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
While .nz operates on a first come, first served policy, it does appear a little inconsistent to allow a priority right. But the alternative of an open registration process would lead to cybersquatting registrations and others seeking to take advantage of the existing registered names, so it does seem appropriate to make the exception for a period of 2 years. This will allow a more orderly transition and cause least confusion in the DNS

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
The policies appear well considered and pragmatic and I cannot see any required changes

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?

Yes
This seems appropriate as long as the period of reservation does not exceed two years. This enables existing registrants a grace period to consider the usefulness of their making the transition, and attending to the changes in an orderly fashion.

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
This question is a bit ambiguous, so to clarify my response above: "Is two years an appropriate time to wait before reviewing policy to allow a reservation at no cost?". My answer = Yes "Should this time frame be longer?". My answer = No Two years gives an adequate time frame for registrants to consider all aspects of their choice to make changes or not. There needs to be an end point in the medium term at which it is appropriate to revert to the primary policy of first come, first served.

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
As with Q6, this question is ambiguous. "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?" My answer = Yes "Should this time frame be longer?" My answer = No

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

Yes
1. Reduction in the numbers of characters being typed will result in reduction in typographical errors. This will improve the overall performance of the DNS, and improve user confidence in using the Internet
2. This will help align .nz to the global trend in ccTLDs to have 2nd level registrations. With NZ's comparatively small population, there will remain a robust choice of names in the 2nd level for the foreseeable future.
3. Shorter domain names and email addresses decreases the possible fragmentation of the Domain Name space, as alternate new gTLD names are less appealing on the basis of reduced numbers of characters to type.

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

No