From:           Michael Fincham, Hotplate Labs
Received:     31 May 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
There is no apparent problem that doing this would solve, but there are definite problems that would be created if it were allowed. We already have for taxonomy free domain registrations and it is almost completely unused (0.3% of the .nz space is in The only argument I can see for allowing direct .nz registrations would be as an aesthetic improvement over, which seems like a pretty weak argument.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
It would be good to see a solid explanation of how allowing direct second level registration would be beneficial to users of the .nz zone grounded in something objective like statistics or novel example usages which are not currently possible with the existing hierarchy.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
Does anyone actually want this?

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
It is also not clear what this would do to improve over the existing system. It seems just as likely to give a false sense of security given that: a) DNSSEC will be available on all existing .nz 2lds anyway b) Phishing seems to be successful regardless of whether the phisher has a plausible sounding domain name or not

Question 5. Should the registration of some names such as or, be prohibited at the second level to minimise potential confusion? What names, if any, should be prohibited?
All names that are not carefully allowed, given the near impossibility of trying to think of all the possible things to blacklist. That this question even needs to be posed should demonstrate one of the inherent reasons not to allow direct second level registration.

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 views on this.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
If second level registrations were to go ahead then I don't see why this needs to be treated different to existing domain disputes regarding intellectual property etc.

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)
Should be solved in the same way existing domain disputes regarding intellectual property as solved, as in Q7.

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?
That this question even needs to be posed should demonstrate one of the inherent reasons not to allow direct second level registration.

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
No views on this, though this seems like a really difficult definition to properly grok: Generic Word means a word or phrase that describes a class of product, service, profession, place or thing. For example: .toy; .shop; .cleaner; .lawyers; .Wellington; .sparkling-wine;

Question 11. Are there any other comments you would like to make relating to this consultation?
Please demonstrate how this proposal would actually be beneficial. As it stands it seems that this proposal solves no problems yet raises a number of them. I have not mentioned in this survey a number of other problems that come immediately to mind such as hard coded lists of valid 2lds / domain structures mis-parsing new .nz zones, broken e-mail systems rejecting mail, broken e-mail validator regexes, the Mozilla document which clarifies cookie permissions based on which zones allow 2ld registration not being up to date in many browsers, etc. There are lots of not very fanciful problems which can be easily imagined as stemming from this proposed change.