From:           Martin Kealey
Received:    27 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
see detailed response to question 11

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
No Response

Question 3. Should new second level domains be created to cater for particular interest groups, such as .wine.nz or .sport.nz?
Yes

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as .bank.nz?
No Response

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?
No Response

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?
No Response

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
No Response

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?
No Response

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?
No Response

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
No Response

Question 11. Are there any other comments you would like to make relating to this consultation?
I have looked at this issue from the sidelines for a month or so, and have been rather disquieted by it. On Wed, 30 May 2012, Campbell Gardiner wrote: > In what could amount to a major extension to New Zealand’s domain name space, the Domain Name Commission Limited (DNCL) has launched a consultation on whether registrations should be permitted directly under the .nz country code. Firstly, why is the *DNCL* proposing this change? Surely that's exceeding their operational directives? And what's with publishing press releases before there's a consensus among members? (This is effectively tying the membership's hands by making us seem like "meanees" or "ludites" if we disagree with the proposal.) Secondly, I believe the press release is playing loose with the truth. The assertion that registrants are "limited" to the 14 current second level domains is quite disingenuous. If this proposal goes ahead, then: 1. The ability to ease the "restriction" by creating additional parent domains will cease in any meaningful sense -- all suitable terms will very likely be seized very quickly after open registration begins. 2. New registrants will effectively be limited to just one parent domain - .nz - as anything else will soon be seen as "dubious" as people lose track of which 2LDs are controlled by InternetNZ and which are controlled by other entities. (We'd go from having one level of registration to two, thus creating the very confusion which was half the reason that .ca moved to flatten its namespace.) So if we're contracting from 14 parent domains to one (viable) one, how in all honesty can this be promoted as an "expansion" of the domain name space?!? And why, really, are we promoting this? If it's to solve a "congestion" problem, then we're lying to ourselves: it will make the problem worse, not better. If it's to look out for the interests of future registrants, see above. If it's to look out for the interests of existing registrants, how are they going to be better off having to pay double their current registration costs? (And as for subsidizing existing registrants; if we're going to do that, what's the point?) If it's to appease those who just "don't see why not", it's up to them to prove a case (and "more registrations" is arguably a point against, not a point in favour; see below). If it's to appease those who think "co.nz" is "clunky" or badly matched to their identity, well maybe they should be using "ltd.nz" or "takeaways.nz" or "rentals.nz" or "club.nz" instead. Or "hates.nz". Or "com". If it's to "look like other TLDs" then fine, let's argue it on that basis. But the point of .nz at all is to identify with us as New Zealanders, not to "compete for market share" among all the TLD's. (And while we're at it, let's remember that a key feature of NZ culture that differentiates us from, e.g. the US, is that we tend to cherish "fairness" even more than "freedom".) If it's the ego boost of "look, I made something important happen", then we need to look at our personnel appointment process. If it's to increase the revenue stream for InternetNZ then we should take a long hard look at ourselves. Let's focus on our founding mission: an open and uncapturable Internet, and remember that "openess" and "unfettered freedom" are not synonyms. -Martin