I think the proposal to allow a domain name renewal at any time combined
with a transfer of Registrar of Record, is better than it appears at first
glance.  What I find difficult is thinking through the implications of all
the options - trying to work out the actual effect of various possibilities
is really quite important, rather than just taking a quick decision.


In this case it isn't assisted by having a draft change of Registrar of
Record (that's actually a version of a domain name Renewal) but not having a
draft Domain Name Application and Domain Name Renewal Procedure - surely
that procedure should have been developed first.  That means we have to
guess a bit when trying to work out the implications of the change of
Registrar of Record proposal.


But conceptually, allowing a domain name renewal for a full two years to
take place at any time has some advantages:

* Entities with more than one domain name can arrange for all the renewals
to fall due at the same time, if they so wish.

* Entities with more than one domain name can arrange it so that all their
renewals don't fall due at the same time, if they so wish.

* In an odd sort of way it acts as a consumer protection measure for the
Registrant - it makes the Change of Registrar of Record a more significant
event by tying it to a renewal, which may minimise unnecessary churn.

* And the full two year renewal also is a consumer protection measure if it
stops the problem of entities charging for a Change of Registrar WITHOUT
doing a renewal.....

Think about this scenario:  Registrant is a company with 3 divisions or
trademarks and they have a domain name for each of them.  Registrar A says
to the Registrant "we're the Registrar for one of your domain names, it will
be simpler if we're the Registrar for all of your domain names - pays us a
"Change of Registrar" fee and we'll transfer the other ones for you.
Registrant pays out money and doesn't even get a renewal.

* Even the issue of 'losing' part of the registration period that's been
previously paid for isn't as straightforward as it seems.  The difficulty
here is that we have to make a few assumptions and we don't have enough
information about how the Registry / Registrars / Resellers might operate,
but.....

To minimise unnecessary churn there probably should be some sort of fee
attached to a Change of Registrar of Record.  Now, suppose we assume that
after the introduction of competition, the cost of renewing com.au domain
names settles down at $100.  And lets assume a 'Change of Registrar of
Record only' fee of $50.

If your domain name is in the first year of your two year licence period,
you may think paying the fee for a Change of Registrar that's less than the
renewal fee looks OK.  But after the first year, its actually better value
to just do a full renewal for two years and get the Change of Registrar
thrown in for nothing.  So it probably all evens out in the long run.

* The other advantage of the existing proposal - one of the reasons I've
come to think clause 3.2b in the draft is so clever - is that its elegantly
simple from a policy and administrative viewpoint.  Don't need a separate
procedure for Change of Registrar of Record.  Don't have to worry about
who's going to incur the cost of changes, will a fee have to be levied to
cover the costs by the Registry or Registrar or Reseller, etc, etc.  And
having policy and administrative simplicity counts for a lot!



Regards, Mark

Mark Hughes
Effective Business Applications Pty Ltd
effectivebusiness§pplications.com.au
www.pplications.com.au
+61 4 1374 3959