From:           Paul Hayward
Received:    Friday, 26 July 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
No, If you look at most established domain systems around the world (specifically I’m thinking of Australia/UK) they are all based around a hierarchy of fixed 2nd level domains. The domains that are open at 2nd level are generally smaller, less economic nations.

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
For 20+ years people have been taught that NZ companies use .co.nz, government departments use .govt.nz. People are comfortable with these addresses and use them freely.

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
Most definitely. I believe there are many .co.nz domain holders that would want to protect their brand from being hijacked by someone else. I also believe that many will feel they don't have a choice but to register their co.nz domain as a .nz domain, and incur the ongoing costs associated with it.

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

No
I have not read the draft amended policies as I hope this does not go ahead.

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
Kinda yes, kinda no. If you have different registrants of a .co.nz and .net.nz domain name, who gets the priority? The one being blocked could also have a legitimate reason for wanting the domain.

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
2 years is appropriate if there is only 1 current 3rd level holder, however if there are multiple holders (who all might have legitimate uses) then 2 years is too long.

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

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

Yes
Opening up the 2nd level creates a possibility of abuse of the domain system. If you look at some of the countries that have opened their 2nd level (Greenland and Libya are the first 2 that spring to mind), the most known address there is goo.gl and bit.ly. Nz at the end of a word is easily replaceable for ns, so I'm sure someone will register domai.nz or bighor.nz or bur.nz or some other combination like that.