From:            Simplename, Richard Clark
Received:     4 July 2014

Simplename is fully opposed to the proposed change to the UDAI lifetime changes. The proposed "functional" change modifies the purpose of the UDAI from being the sole and authoritative token indicating current ownership of the domain, to being a temporary key derived from some other authentication.

It may not change the technical nature of the UDAI, but it is a complete reversal of the roles of the UDAI and the registrar authentication. 

Simplename believes this change will negatively impact the .nz namespace, making it more difficult for registrants to control their domain in the independent fashion that allows quick, uninterrupted migration between registrars.