1. auDA Domain Name Fee (DNF)
The DNF, as explained in the Registry RFT documentation released last week,
is $11.00 per domain name, to be paid to auDA by the Registry Operator for
the Designated 2LD on a monthly basis. The purpose of the DNF is to cover
auDA's costs of managing the .au DNS (including operation of the root
server, industry regulation, consumer protection, policy and industry code
of practice development, etc). The DNF was one of the key recommendations of
auDA's Competition Model Advisory Panel.

auDA expects that the DNF will be collected from registrars, who in turn
will collect it from registrants. However, there is nothing in the RFT
documentation (jncluding the Registry Licence Agreement) that forces the
Registry Operator to collect the DNF from the registrars. auDA's draft
Registrar Agreement does not make any reference to collection of the DNF.

The reason for this is that the Competition Panel recommended that the
registry tender process should not exclude any type of proposal: "Proposals
may be submitted by for-profit or not-for-profit entities, single firms or
consortia, commercial operators or community-interest groups." (para 2.3.6
of the Panel's final report). Accordingly, the RFT has been written so that
it is possible for a tenderer to submit a proposal that absorbs the DNF
within the costs of operating the registry, and does not pass it on to
registrars. auDA has deliberately set the initial licence fee for the
traditionally non-commerical 2LDs (asn.au, id.au, org.au) much lower than
the commercial 2LDs (com.au, net.au) for this very reason.

2. asn.au and org.au
It is worth noting that many of the entities that hold domain names in these
2LDs are not charitable organisations. Registrants in asn.au in particular
are likely to be sporting clubs and industry associations. Many of these use
their domain name to carry on commercial activities (even though they're not
supposed to, under a strict interpretation of the policy rules).

It is also worth noting that auDA has received overwhelming feedback over
the past 12-18 months from people who have had difficulty registering or
redelegating org.au domain names, that they would be only too happy to pay
the same as for a com.au domain name (ie. $137.50) if it meant that they
received a similar quality of service.

3. Consumer protection
auDA has a very important consumer protection role. As the DNS list knows
very well, recent events have reinforced the need for auDA to introduce
robust consumer safeguards that serve to protect the integrity of the
industry as well as the interests of consumers. The only way that auDA can
do this is to accredit registrars and enter into contractual arrangements.
To allow "volunteers" to operate in certain 2LDs undermines auDA's ability
to ensure a consistent level of service and consumer protection across the
.au domain. This is not to say that the current volunteers are not doing a
good job. However, consumers have no guarantee that those individuals will
continue to provide an acceptable level of service into the future.

As pointed out above, auDA's draft Registrar Agreement does not make any
reference to the DNF. If a registrar wishes to operate a free service, that
is entirely acceptable to auDA provided that they can meet the accreditation
criteria and pay the requisite fees. Again, auDA has deliberately set its
registrar accreditation and licence fees very low (as compared with ICANN
and other ccTLDs) in order to ensure that there are no barriers to entry.

Jo Lim
Chief Policy Officer
.au Domain Administration
ph 03 9226 9495
fax 03 9226 9499
mob 0410 553 233

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