As you might be aware there is currently a review of the CGDN policy by auDA.

Comments for this close December 3rd, I've submitted my thoughts which I've 
copied below. 

Basically this program has resulted in 200 registrations at a cost of around 
$2M - or $10,000 per domain registered. The original funding for auCD came 
from the funds auDA received when the geographic domains were released. That 
funding is exhausted, and the program is now being funded as part of the fee 
auDA collects on each domain registration. 

I feel strongly this is a gross waste of money for zero actual benefit as per 
my comments. I would encourage any stakeholder in the .au space from both the 
demand and supply sides, to look at this program, and at least ask questions 
as to why this is continuing, if not to contrbiute to the public comment 
process. 

---Begin 

Dear Lujia,

Thank you for the opportunity to express my views of the CGDN policy.

These comments represent the view of the Online Growth Solutions Ltd group of 
companies, which includes Netregistry Pty Ltd, Hostess Pty Ltd, PlanetDomain 
Pty Ltd, MDWebhosting Pty Ltd and TPP Internet Pty Ltd, all companies are 
accredited Registrars in a range of spaces including the .au and gtld. 

I shall reserve all of my comments to the following clause in the policy:

"2.1 auDA has created the CGDNs in order to preserve Australian geographic 
names for use by the relevant local community. The aim is to provide an 
intuitive, standardised naming system to enable better access to local 
community, tourism and business information and to facilitate social and 
economic benefits to Australian communities."

As at todays date communities have been able to register in the 3th level for 
the past 4 years. 

During that time a total of just over 200 domains have been registered, at an 
expense in excess of approximately $2,000,000. 

That is in simple terms some $10,000 per domain registered. 

Clearly by any measure, this program has been an abject failure.

From the cgdn.org.au website:

"The auCD company was wound up on 30th June, 2010 at the project funds end and 
auDA is continuing to support the initiative within their operations as part 
of their community engagement and education activities."

I question not only the logic of auDA absorbing these ongoing costs, but also 
the fact we have an open policy review process, however the decision to bear 
those costs, didn't seem to follow the same open decision making process where 
any stakeholder comment was sought. 

Every domain name registrant currently registering a domain in the .au space 
is continuing to fund this program, by way of the auDA fee, and has every 
right to be concerned that that money is continuing to be grossly wasted, with 
no business case, no expected social outcomes and generally no oversight into 
the proposed benefits of the program.

The aim of the policy as stated is clearly not being met, there is no demand 
for this space, no uptake by local communities and therefore no increased 
access or economic benefits to local communities. 

I would call for:

1) The existing domains to be "grand fathered" for a fixed period of time (of 
which there is precedent in the space); and

2) The immediate cessation of any new registrations; and

3) auDA providing assistance to transition existing Registrants to a domain in 
an existing .au space (org.au).

Regards, 
Brett Fenton