Michael & Geoff,

>I also call for expressions of interest to act as registrars within
>ASN.AU. Interested parties should email me directly, with an intention
>to add a small number of new registrars to ASN.AU by the end of
>this month, in order to adequately test the software in a true
>multi registrar environment.
>
>MM
>
>I have not discussed this with Michael yet, but I too
>am willing to put the second level domains I look after
>through Michael's process as well, and add a number
>of registrars into these domain as well.
>
>(Thinking aloud) Perhaps the best move is to see this
>asn.au proposal through, and by June, if this has worked
>for asn.au in Michael's assessment, we can do the same
>for a few more second level domains.
>
>Geoff

May I ask a couple of questions about these plans to enable
multiple Registrars to operate in .asn.au, .edu.au, .gov.au, etc?

Question 1.
Will there be any restrictions on who the registrars are?  ie, is it
ok if one of the new Registrars is a shell company registered in 
Sarajevo and beyond any Australian court jurisdiction?

Question 2.
If there are to be any restrictions on who can be a Registrar,
how will this be enforced/applied?  ie, having rules without both 
a process for administering them and sanctions for breach of
the rules, is pointless.  What is the process, and what are the
sanctions?

Question 3.
Will restrictions remain on what entities can get domain names in
the .asn.au, ..edu.au, ..gov.au SLDs, or will registrars be allowed to allocate
domain names to any entities who wish to have them?  ie., if the
Sarajevo based Registrar issues domain names in .edu.au to a
foreign company that sells for $5 nicely framed certificates for PhD's
from the non existent 'TransPacific Institute' is that OK?

Question 4.
If there are to be restrictions on what entities can get names in those
SLDs, what will those restrictions be?

Question 5.
If there are restrictions on what entities can get names in those SLDs,
what is the process for reviewing / changing those rules?

Question 6.
What is the process and what are the sanctions when a Registrar ignores
the rules restricting what entities can get names in those SLDs?  Or do
we just go 'tut tut that's not nice' and let them carry on registering names
that don't meet the rules?

Question 7.
Will there be any restrictions on what names will be allocated in those SLDs,
or is it first come first served.  ie, if a new University starts up in the suburb of
Monash, is it okay to issue monashuni.edu.au to it even though monash.edu.au
is already issued to Monash University?

Question 8.
If there are restrictions on what names entities can get, what is the process
for reviewing/changing those rules?

Question 9.
What is the process and what are the sanctions when a Registrar ignores
the rules restricting what names can be allocated in those SLDs?  Or do
we just go 'tut tut that's not nice' and let them carry on?

Question 10.
Is there any sort of code of practice that the new registrars in .asn.au,
.edu.au, .gov.au have to follow?  What happens in event of complaints,
or is it caveat emptor?  For example, is it ok for the new registrars to 
generate additional income by selling their list of customers to direct
mail merchants, etc?

Hey folks, welcome to the issues we've been working thru for the
commercial domains.

There are two options:

1.	Have no rules at all for a SLD - issue any and all names on FCFS
basis to any entity that wants them.  This is basically the way the
existing gTLDs and proposed new CORE gTLDs work.  Not a problem,
unless you are of the opinion that fuck.edu.au, nazi.gov.au, etc
perhaps shouldn't be approved in the .au namespace.

2.	Have rules relating to what entities are entitled to names, and/ or rules
about what names will/won't be approved.  In this second case you need
more than just some rough as guts rules.

* You need a public process by those rules could be changed.
* You need objective (not subjective criteria) for evaluating those rules.
 Otherwise one Registrar will approve names that other ones reject.
Eventually one Registrar will gain a reputation for 'looser' interpretation of
 the rules and get more business.
* You need a method of imposing sanctions on those who don't follow the
 rules.  Rules without sanctions to enforce them are pointless.

Good luck folks, you're gonna need it.  Its easier to shut the stable door
before the horse has bolted.  May I suggest you develop the equivalent
of the ADNA draft 'Registrar Licence Conditions' and ADNA SLD specific
 draft policy documents for .asn.au, .edu.au, .gov.au BEFORE
enabling multiple Registrars.

Regards, Mark

BTW, for those who are still fantasising that all company names and all
 registered business names are issued on a first come first served basis,
 I hate to give you the bad news, but it ain't so.  Not only are some
 names rejected, but some of the criteria used are totally subjective. 
 The week before last I went in to register a business name.  I filled
 out the form with my preferred name, took it to the counter and it
 was rejected on the grounds that is was 'too similar' to existing names.

In theory, having the Federal and State governments approve Company
 Names and Business Names respectively using subjective criteria isn't
 a problem because they have monopolies in their own areas.  If they
 enabled competition by allowing all sorts of different entities ('Registrars')
 to handle the name approval, they'd have to either come up with totally
 objective criteria AND sanctions for those that didn't follow them, or
 eliminate the rules.

Just like domain names, eh?

Actually, because they use different people in the one department to
 interpret their rules, those governments only have a pseudo monopoly.
  'Cause later on the same day, I took my business name form to a different
 person at the counter and the same name was approved.  That is what
 happens when you have multiple people trying to apply subjective criteria.