From:           Colin Foster, Zen Solutions Ltd.
Received:     7 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example yourname.nz?
No
This the worst idea I have heard in some time. It is breathtaking in its ignorance of how and why second-level domains were created in most national domains, and would cause enormous confusion and uncertainty. The existing tiered scheme provides a degree of knowledge and certainty about a domain, for example, everyone knows .govt.nz is an official government address and (ignoring issues such as spoofing and phishing) gains confidence from that. Allowing almost anything to appear at the second level would lead to dangerous confusion and even fraud - what say are people to make of ".gov.nz", ".doc.nz", ".ird.nz" or ".workandincome.nz"? You can't police all possibilities, and from what I've read in the proposal you aren't even willing to try. Perhaps most importantly, the present arrangement is simple, well-known and provides a known and consistent structure to domain naming in NZ; as a web developer I can only shudder at the thought of how software can meaningfully parse "new model" names of arbitrary structure - for a start, making this change will break most existing simple verification algorithms which rely on simple parsing using something like a RegEx. Perhaps I could be persuaded of the need to endure all these drawbacks if there was a clear need to make such a change, but there just isn't! It ain't broke, so don't try and fix it - if the only concern is to enlarge the namespace, there are better ways of doing that (such as Q2 below). There is also the issue of cost - the proposed change will certainly be of great financial advantage to DNC and to the detriment of every existing domain registrant, by adding at least one more "must have" (and "must pay for") name to any business's collection. This has the smell of a grubby money-making exercise - please wake up and realise not only is this going to be a practical nightmare, it isn't going to look good for you.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
No
Just don't do it.

Question 3. Should new second level domains be created to cater for particular interest groups, such as .wine.nz or .sport.nz?
Yes
If there really is such pressure on the namespace,then this is the way to go - a greater level of "official" segregation means everyone still knows where they stand when they look a domain name - the is always a second-level, which continues to provide an indicator of a site's nature.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as .bank.nz?
Yes
It works well for existing moderated domains, and I see no reason not to extend it. Again, there are obviously concerns around the possibility of a "false sense of security" and spoofing/phishing, but we have to be clear that is an entirely separate issue, and can affect any "trusted" domain name, however structured.

Question 5. Should the registration of some names such as .com.nz or .gov.nz, be prohibited at the second level to minimise potential confusion? What names, if any, should be prohibited?
Yes
But that's the problem, isn't it! You can't catch them all! By even asking this question, it is clear you understand the confusion and possible consequences your changes will cause. So think it through all the way - duh!

Question 6. Do you agree with the rationale for the Sunrise Period that would enable existing .nz domain name holders first chance to register names at the second level? Why?
Agree
Again isn't it blindingly obvious?! If you really must go through with this nonsense, it's clear that the likes of "microsoft.nz" or "ibm.nz" are going to be very popular... :)

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Again the existence of this question provides its own answer. Or should!

Question 8. Assuming only persons with a conflicting third level domain name may apply, how should that conflict be resolved? By consent? Or some other mechanism?
Other (below)
If I apply for "ibm.nz", I can't see IBM being happy at having their application blocked forever by my refusal to "consent"... Ooh it's going to be soooo good for lawyers too, isn't it?!

Question 9. Should the Domain Name Commission consider extending its Dispute Resolution Service for a limited period to cover particular sub-domains when considering whether a name registered at the second level infringes a complainant’s rights?
Yes

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
No
At first sight, it looks too restrictive. But really, I'm still hoping sanity will prevail and I'll never need to read it again in detail...

Question 11. Are there any other comments you would like to make relating to this consultation?
I think I've made my point :)