Brett the geographic domain names was always a solution to a problem that
didn't exist - you simply do not need your own top level domain space to
achieve any of the good outcomes described in that grand mission statement
below. I did mention that at the time this was mooted and now some years
later you highlight the total waste of money it has been. The fact that the
money has been spend is no reason to keep it running so I hope your
submission gets up.

BTW for supporters of it the proof is in the pudding - look at all the
community/council/special interest groups etc  OUTSIDE the CGDN - for
thousands of business and interested groups there is absolutely no point
being pigeon holed under broome.wa.au or whatever. 

This is madness? If you want to have a think about this look at broome.wa.au
and compare this to www.broome.com.au  or any others and honestly what has
been achieved by a CGDN? An " intuitive, standardised naming system" with
absolutely no relevance to anyone actually wanting to use it!

Doug



-----Original Message-----
From: dns-bounces+doug=psy.uwa.edu.au§dotau.org
[mailto:dns-bounces+doug=psy.uwa.edu.au§dotau.org] On Behalf Of Brett Fenton
Sent: Friday, 26 November 2010 1:41 PM
To: DNS Mailing List
Subject: [DNS] CGDN review

As you might be aware there is currently a review of the CGDN policy by
auDA.

Comments for this close December 3rd, I've submitted my thoughts which I've
copied below. 

Basically this program has resulted in 200 registrations at a cost of around
$2M - or $10,000 per domain registered. The original funding for auCD came
from the funds auDA received when the geographic domains were released. That
funding is exhausted, and the program is now being funded as part of the fee
auDA collects on each domain registration. 

I feel strongly this is a gross waste of money for zero actual benefit as
per my comments. I would encourage any stakeholder in the .au space from
both the demand and supply sides, to look at this program, and at least ask
questions as to why this is continuing, if not to contrbiute to the public
comment process. 

---Begin 

Dear Lujia,

Thank you for the opportunity to express my views of the CGDN policy.

These comments represent the view of the Online Growth Solutions Ltd group
of companies, which includes Netregistry Pty Ltd, Hostess Pty Ltd,
PlanetDomain Pty Ltd, MDWebhosting Pty Ltd and TPP Internet Pty Ltd, all
companies are accredited Registrars in a range of spaces including the .au
and gtld. 

I shall reserve all of my comments to the following clause in the policy:

"2.1 auDA has created the CGDNs in order to preserve Australian geographic
names for use by the relevant local community. The aim is to provide an
intuitive, standardised naming system to enable better access to local
community, tourism and business information and to facilitate social and
economic benefits to Australian communities."

As at todays date communities have been able to register in the 3th level
for the past 4 years. 

During that time a total of just over 200 domains have been registered, at
an expense in excess of approximately $2,000,000. 

That is in simple terms some $10,000 per domain registered. 

Clearly by any measure, this program has been an abject failure.

>From the cgdn.org.au website:

"The auCD company was wound up on 30th June, 2010 at the project funds end
and auDA is continuing to support the initiative within their operations as
part of their community engagement and education activities."

I question not only the logic of auDA absorbing these ongoing costs, but
also the fact we have an open policy review process, however the decision to
bear those costs, didn't seem to follow the same open decision making
process where any stakeholder comment was sought. 

Every domain name registrant currently registering a domain in the .au space
is continuing to fund this program, by way of the auDA fee, and has every
right to be concerned that that money is continuing to be grossly wasted,
with no business case, no expected social outcomes and generally no
oversight into the proposed benefits of the program.

The aim of the policy as stated is clearly not being met, there is no demand
for this space, no uptake by local communities and therefore no increased
access or economic benefits to local communities. 

I would call for:

1) The existing domains to be "grand fathered" for a fixed period of time
(of which there is precedent in the space); and

2) The immediate cessation of any new registrations; and

3) auDA providing assistance to transition existing Registrants to a domain
in an existing .au space (org.au).

Regards,
Brett Fenton
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