From:	Alex Blake 
Sent:	Friday, 25 September 2015 12:32 PM
To:	jo.lim@auda.org.au
Subject:	Submission on Draft Recommendations

Thank you for the opportunity to make a public submission.
 
I would like to preface my answers to your draft recommendations with this overriding 
statement.
 
auDA should maintain the status quo
 
Why change a system that not only is not broken, but is very obviously thriving, and that 
serves the needs of existing Australian internet owners so well?
 
* According to AusRegistry there are only 3,000,000 domains in Australia, of which about 
2,600,000 domains are .com.au.
 
* By contrast, there are approximately 116 million .com domains in circulation, and they 
continue to grow.
 
* If this proceeds, and looking at the best case scenario, existing domain owners may 
end up with a matching .au domain, and will have to consistently pay two renewal fees. 
For those businesses with a few domain names (particularly small businesses), this cost 
is exponentially multiplied.
 
* In the worst case scenario, they stand to lose out on their .au domain name, with the 
likelihood of two competing businesses ending up with similar domains. As an example, 
which would you trust, carloan.com.au or carloan.au? What if one was owned by the 
well-known "Car Sales" and the other by an unknown entity?
 
* The costs of introducing .au will be enormous, and the public will ultimately have to pay.
 
* The uncertainty surrounding the process is already hampering business confidence and 
development.
 
* The confusion it will ultimately generate is guaranteed to harm consumer interests.
 
It is therefore obvious that the current status quo represents the best outcome for the 
largest number of existing registrants.
 
The only people that seem to disagree with this notion are the registrars who are 
actively pumping up a "yes vote" with their mass emailings and suggestions on "how to 
vote". They do so without giving both sides of the story. We all know why that is - they 
stand to make loads of dollars if this is adopted.
 
Please listen to the little people / small businesses.
 
My Answers (With Comments)
 
DRAFT RECOMMENDATION 1A: I Vote No
 
 
DRAFT RECOMMENDATION 1B: I Vote No
 
 
DRAFT RECOMMENDATION 2A: I Vote Yes
 
 
DRAFT RECOMMENDATION 2B: I Vote Yes
 
 
DRAFT RECOMMENDATION 2C: I Vote Yes
 
 
DRAFT RECOMMENDATION 3A: I Vote Yes
 
 
DRAFT RECOMMENDATION 3B: I Vote Yes
 
With regards (1A and 1B), I do believe that individuals should be allowed to register an 
.au domain without the need for an ABN. I believe this could easily be accommodated 
within the existing .au space.
 
My reluctant fallback position would be that if direct registrations were to be seriously 
contemplated, then existing registrants of the 2,600,000 .com.au domains should be 
offered first right to these domains for a period of at least 12 months. That is simple 
common sense; and consistent with other jurisdictions.

Thank you.

Alex Blake.