New Zealand Government comment on proposed measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes [UNCLASSIFIED]

[Nicola Treloar <Nicola.Treloar@xxxxxxxxxxxx>]

To whom it may concern,

The following comment is in response to the consultation regarding the proposed 
measures for avoiding confusion in the release of two-letter second-level 
domains in gTLDs.

The two-letter country code for New Zealand is "nz" which is also the commonly 
used abbreviation for New Zealand. While the New Zealand Government does not 
wish to prohibit uses of the "nz" at the second level in principle, we are 
concerned that in some instances the use of "nz" at the second level may cause 
confusion for consumers.

To date, the New Zealand Government has engaged in the RSEP process to raise 
concerns about potential confusion with its country code, and has only raised 
concerns with three domains.

We are concerned that the proposed measures to avoid confusion are not 
satisfactory. They focus on requiring governments and ccTLD managers to 
register the country code themselves to manage this risk. We do not consider 
that requiring Registry Operators to implement a 30-day period when domains are 
exclusively available  is the most appropriate mechanism for resolving the 
issue. Governments should not have to purchase potentially expensive second 
level domains themselves in order to avoid confusion.

ICANN and/or registry operators can facilitate the use of the country code in 
ways that minimise consumer confusion. For example, the GAC Helsinki 
Communiqué's suggests that Registry Operators engage with GAC members when a 
risk is identified. We consider that a constructive and good-faith relationship 
between the Registry Operator and the GAC member is the most appropriate way of 
resolving any concerns, and that ICANN should not put in place a process which 
bypasses that relationship.

We would also note concerns raised by the .nz country-code manager that this 
policy has been developed without consultation with the ccNSO despite ccTLD 
managers being a key part of this proposal. Their views are reflected in a 
separate submission.

The New Zealand Government supports a mechanism which will facilitate the use 
of two-letter second-level domains in gTLDs, including country codes. However, 
in light of the above concerns we do not support the proposed measures.

Nicola Treloar
ICANN Governmental Advisory Committee Representative for New Zealand
Communications Policy | Building, Resource, and Markets Group | Ministry of 
Business, Innovation & Employment | NEW ZEALAND




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