New Zealand Government comment on proposed measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes [UNCLASSIFIED]
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 www.govt.nz - your guide to finding and using New Zealand government services Any opinions expressed in this message are not necessarily those of the Ministry of Business, Innovation and Employment. This message and any files transmitted with it are confidential and solely for the use of the intended recipient. If you are not the intended recipient or the person responsible for delivery to the intended recipient, be advised that you have received this message in error and that any use is strictly prohibited. Please contact the sender and delete the message and any attachment from your computer.