Jo Lim wrote:
> 
> 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.

The point is that for a voluntary Internet community-based registry
there would be no costs *other* than the domain name fee, and the
application fee, because all of the other costs can demonstrably be
covered through volunteerism and donation.  To say as you have that a
$15 000 up-front fee constitutes "no barrier to entry" is, with respect,
an affront to common sense to say the least.

The key question is whether auDA's need of funding from the small
handful of non-commercial domain registrants outweighs the registrants'
interest in retaining the present efficient, community-based,
volunteer-run service, complementary indeed to the ethos of most (not
all, admittedly) of those organisations and individuals themselves.

There is nothing to stop the registry from accepting money from
registrars who wish for a premium service (and this could offset such
costs of the registry as are absolutely, absolutely essential) but there
should not be such an impediment as a $15000 up-front fee plus $12 per
domain name to the registry facilitating the continuance of the present,
best-efforts, volunteer-based regime.

Those who wish to avail themselves of a guaranteed service can pay. 
Those who are content to rely on the goodwill of the registry need not. 
This is an analogue of the divide between open source software and
commercial software.  Consumer protection concerns are more likely to
arise when commercial registrars and registries are involved, because a
non-profit registry will have no incentive for sharp practice.  We
return to the open source analogy: it is ironic that open source
software is very often *better* suited to the needs of its users than
commercial software.

I do not argue that auDA has no regulatory role to play in overseeing
the operation of volunteer registries, but the role is a very limited
one in my view.  The last thing that the non-profit registries need is a
"fat cat" regulator.  Such registries did not ask for and do not need
hundreds of thousands of dollars spent on promotional and educational
campaigns on their behalf.  All they require is a regulator who will
decline to renew their licence after its four year expiration (or
perhaps terminate it early) if they are clearly not meeting their
obligations.

-- 
JEREMY MALCOLM <Jeremy&#167;Malcolm.wattle.id.au> http://malcolm.wattle.id.au
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