Ms Jo Lim
Chief Policy Officer
AuDA
107 Faraday Street
Carlton  VIC  3053


Dear Ms Lim

I am writing on behalf of the ACT government in response to the proposed 
recommendations by the New Names Advisory Panel to the auDA Board concerning 
Geographic 2LDs – state/territory.au published on the auDA website.

I wrote to you on 27 September on behalf of the ACT government, in response 
to the Geographic 2LDs Discussion Paper.  In that letter, I stated our 
support for the proposal submitted by One City One Site (OCOS) Working Party 
in favour of creation of the state/territory.au domain and the retention of 
the prohibition on the use of geographic names in the net.au and com.au domains.  
I am pleased to see that the Panel supports the creation of the 
state/territory.au domain.

I am disappointed though that the Panel has chosen to recommend that the 
restriction on geographic names in the net.au and com.au domains be lifted, 
especially as it is clear that the Panel is not unanimous on this matter.  
It is also worth noting that the majority of submissions on the subject posted 
on the auDA website are in favour of retaining the restriction, and this is 
also the stance of the Geographic Names Board.

The arguments for lifting the restriction advanced by the Panel in its proposed 
recommendations are, in my opinion, not convincing.  In particular, the Panel’s 
claim that having city.com.au and city.state.au will not cause confusion is not 
supportable, especially as city.state.au domains become more common.

The Panel also claims that the Dispute Resolution Procedure will provide a 
mechanism for a community to bring a complaint about bad faith use of geographic 
names.  This may well be the case, but it would be better to avoid such disputes 
in the first place.  In the opinion of the ACT government, a sufficient case has 
not been made for lifting the restriction and it should therefore stay in place.

Yours faithfully



Michael Vanderheide

Director
ACT Information Management

6 November 2002