From:           Rick Shera, lawgeeknz
Received:    20 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
I have read the proposal and background materials and have had the benefit of reading the numerous other submissions already made. Despite all that material, the best rationale for the change I can find can be summarised as "why not?" or "we can do it so therefore we should". I discount completely the "advantage" of increased fees which will undoubtedly flow to NZRS since, looked at on an NZ LIC basis this is not an advantage at all - all that would be happening is a part of that community - primarily existing registrants - paying money to another part of that LIC, InternetNZ and its subsidiaries. ie. a neutral value transfer overall. If I hark back to the creation of the current SRS and the Hine Commission report that gave rise to it, I cannot see how this is "putting registrants' interests first". However, there are clearly a number of costs and disadvantages which many submitters have exposed. In this, I can do no better than support the excellent submissions of MBIE and Ewen McNeill among others.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
n/a as this proposal should not proceed IMO

Question 3. Should new second level domains be created to cater for particular interest groups, such as .wine.nz or .sport.nz?
n/a as this proposal should not proceed IMO

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as .bank.nz?
n/a as this proposal should not proceed IMO

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?
n/a as this proposal should not proceed IMO

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?
n/a as this proposal should not proceed IMO

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
n/a as this proposal should not proceed IMO

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?
n/a as this proposal should not proceed IMO

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?
n/a as this proposal should not proceed IMO

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
n/a as this proposal should not proceed IMO

Question 11. Are there any other comments you would like to make relating to this consultation?
The proposal should not proceed IMO, for the reasons stated and referred to in my answer to question 1.