From: Bruce Tonkin Sent: Friday, 19 October 2012 4:24 PM To: paul.szyndler@auda.org.au Subject: Melbourne IT comments on 2012 Industry Advisory Panel - Draft Recommendations - September 2012 Hello Paul, Please find attached Melbourne IT's comments on 2012 Industry Advisory Panel - Draft Recommendations - September 2012. Regards, Bruce Tonkin Issue 1. The method of 2LD registry operator selection/appointment post-2014 ============================================================= >> Draft Recommendation 1A: >> The Panel recommends that: a) the competitive registry model should be retained b) auDA should initiate renegotiations with AusRegistry to extend contractual arrangements for 2, 3 or 4 years c) if renegotiations with AusRegistry fail, auDA should proceed to conduct a formal RFT process; and d) the auDA Board should publicly commit to undertaking a formal RFT process once the renegotiated registry agreement expires. Melbourne IT supports this recommendation. With respect to recommendation 1A (b) - Melbourne IT recommends that auDA consult with registrars with respect to input into the negotiation process. Registrars are the major users of AusRegistry services. >> Draft Recommendation 1B: >> The Panel recommends that auDA should retain the current single registry for existing .au 2LDs, while allowing the option for the introduction of multiple registries in the future. Melbourne IT supports this recommendation. In addition Melbourne IT notes that both .uk and .nz are undertaking consultations to allow registrations at the second level. Melbourne IT believes that there are advantages in .au considering a limited ability to register domain names at the second level of .au . These would need to meet stringent requirements for eligibility and secure and stable operation. Issue 2. The policy and process for registrar accreditation =========================================== >> Draft Recommendation 2A: The Panel recommends that auDA should revise the fees for registrar accreditation, to better reflect the direct costs of the accreditation process and ongoing regulation. Melbourne IT supports this recommendation. >> Draft Recommendation 2B: The Panel recommends that: a) current requirements for ASIC and ATO registration for overseas-based registrars should be retained; and b) overseas-based registrars should be required to bear the reasonable costs of a site visit by an auDA staff member during provisional accreditation. Melbourne IT supports this recommendation. >> Draft Recommendation 2C: The Panel recommends that the requirement for applicants for registrar accreditation to act as a reseller of another registrar for 6 months, or show equivalent experience, should be retained. Melbourne IT supports this recommendation. >> Draft Recommendation 2D: The Panel recommends that the registrar accreditation process and criteria should be the same for all applicants, regardless of their proposed business model. Melbourne IT supports this recommendation. Issue 3. Registrar security ==================== >> Draft Recommendation 3: The Panel recommends that the auDA Board adopt the auDA Information Security Standard (ISS) as a mandatory requirement for accredited registrars, and take appropriate steps to finalise the ISS documentation and processes and ensure its prompt and effective implementation. Melbourne IT strongly supports this recommendation. Issue 4. The status and regulation of resellers >> Draft Recommendation 4A: The Panel recommends the retention of the current .au industry model for auDA, registrar and reseller inter-relationships. Melbourne IT supports this recommendation. >> Draft Recommendation 4B: The Panel recommends that auDA develop a standardised agreement template for registrars to use as a basis for their reseller contracts. Melbourne IT supports this recommendation on the basis that registrars are free to use their own agreements that are consistent with terms of the registrar agreement. Melbourne IT recognizes that this recommendation will assist those registrars without in-house legal capabilities to develop their own agreements. >> Draft Recommendation 4C: The Panel recommends that auDA develop and implement a system for adding a reseller "contact object" to the registry database, including a "reseller contact ID", name and email address, and that auDA should be responsible for managing this mechanism for recording resellers. Melbourne IT supports this recommendation providing that the use of the reseller contact ID is optional for accredited registrars. Issue 5. The policy and process for registrar transfers ======================================== >> Draft Recommendation 5A: The Panel recommends that no changes be made to the current .au transfer authorisation process. Melbourne IT supports this recommendation. >> Draft Recommendation 5B: The Panel recommends that bulk registrar transfers be allowed with auDA approval in the case of mergers and acquisitions, and that auDA ensure that the process includes appropriate registrant protections. Melbourne IT supports this recommendation on the basis that registrants are informed in advance of the bulk registrar transfer and will have the option to choose another provider should they wish. >> Draft Recommendation 5C: The Panel recommends that bulk reseller transfers be allowed with auDA approval, and that auDA ensure that the process includes appropriate registrar and registrant protections. Melbourne IT supports this recommendation on the basis that the customers of resellers are clearly identified in the registry under recommendation 4C, and that registrars are informed in advance and have the opportunity to object to the transfer on reasonable grounds (e.g failure to pay for registrations, or fraudulent activity). Registrants must also be informed in advance of the bulk reseller transfer and will have the option to stay with their current registrar should they wish. Issue 6. The status and operation of the .au Domain Name Suppliers' Code of Practice ================================================================ >> Draft Recommendation 6: The Panel recommends that auDA assume responsibility for facilitating regular review and updating of the .au Domain Name Suppliers' Code of Practice in consultation with relevant stakeholders. Melbourne IT supports this recommendation.