From:           New Zealand Police, Nicholas Butler, Manager Online Communications
Received:    27 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
It will make it harder to maintain the benefits to website users and registrants that are delivered by the closed third level domains, especially .govt. The .govt domain is moderated to preserve the authoritativeness of government websites and email addresses. Under the proposal, second level domains related to government activities could be registered but users would not be able to determine the credibility of the sites based on the .govt domain. To mitigate the risks this would cause, government agencies would need to put time and money into monitoring and attempting to manage or obtain these domains. Costs would include the registration of existing third level domains at second level and the need to purchase more digital certificates. More time would go into maintaining website functionality (website access, email contacts etc) across the multiple domains. For Police these risks have significant public safety and confidence implications. Domains that the public might associate with Police could be registered and misused. For example, a site could provide misleading and dangerous advice.

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 or
No Response

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
If the proposal is adopted, those relating to Police activities will either need protection (i.e. their use prohibited or reserved for Police) or moderation.

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?
If the proposal is adopted, any of the currently registered Police domain names would need protecting at the second level. Additionally there is the potential for a number of domains not yet registered to be perceived as legitimate Police addresses. To avoid confusion these domains would either need to be prohibited in advance or reviewed to avoid potential misuse. Both options would be labour intensive.

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?
The Sunrise period will help limit disputes and the Consultation period will help limit cybersquatting. The Sunrise period should be for more than 2-3 months however.

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 the proposal is adopted, those with moderated third level domains registered should be allowed to register the domain name at the second level.

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?
If no registrants have a moderated third level domain, conflict should be resolved by consent.

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?
If the proposal is adopted

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?
The issues around the .govt domain would benefit from an all of government perspective. Thank you for the opportunity to provide feedback. on this proposal.