<html><body style="word-wrap: break-word; -webkit-nbsp-mode: space; -webkit-line-break: after-white-space; "><div><blockquote type="cite"><div>"A community network is a generic reference to any network that is<br>operated by a group of people living in a particular local area<br>organized for the purposes of delivery or provision of network services<br>to the residents of an incorporated or unincorporated regional<br>municipality, city, town, village, rural municipality, township, county,<br>district or other municipality or other such geographic space, however<br>designated. The network must be operated in a not-for-profit fashion,<br>and for the general good of the designated community to which its<br>services are provided, while providing avenues of participation for said<br>community."<br><br></div></blockquote>First, under this description, virtually any organization has enough wiggle</div><div>room to qualify. Second, avenues of participation != level playing field,</div><div>so, there could be very little ability for the community served to influence</div><div>the operation of the network under this definition. I don't think that's</div><div>adequate.</div><div><br><blockquote type="cite"><div>I'm hesitant to get more specific than that. It seems like some people<br>want tighter restrictions on organizational type, and some want less. I<br>think this provides a clarification without restricting the internal<br>structure of the group or organization that operates the network.<br><br></div></blockquote>I don't care so much about organization type, but, I don't believe that</div><div>geography is the best definition and I do believe that it should be a</div><div>hard requirement to be operated by the community for the community</div><div>and governed by the community. Further, I believe the community</div><div>must be non-exclusive.</div><div><br><blockquote type="cite"><div>I agree with your assessment of the technical vs. administrative<br>structure of community networks, as this is the crux of the problem. A<br>community network applying for address space from ARIN is turned away<br>because they don't fit the policy. They are not just an end-user,<br>because they provide services. But they can't show that they're an LIR,<br>because they have no customers. That's what I'm trying to address, by</div></blockquote><div><br></div>Existing policy makes only exemplar reference to "customer". It does</div><div>not require customers:</div><div><br></div><div><span class="Apple-style-span" style="font-family: Arial; line-height: 18px; "><h4 style="margin-top: 0px; margin-right: 0px; margin-bottom: 0px; margin-left: 0px; padding-top: 0px; padding-right: 0px; padding-bottom: 0px; padding-left: 0px; border-top-width: 0px; border-right-width: 0px; border-bottom-width: 0px; border-left-width: 0px; border-style: initial; border-color: initial; line-height: 1.5em; color: rgb(0, 0, 0); font-size: 13px; font-weight: bold; ">6.2.4. Local Internet Registry (LIR)</h4><p style="margin-top: 0px; margin-right: 0px; margin-left: 0px; padding-top: 0px; padding-right: 0px; padding-bottom: 0px; padding-left: 0px; border-top-width: 0px; border-right-width: 0px; border-bottom-width: 0px; border-left-width: 0px; border-style: initial; border-color: initial; font-size: 1em; margin-bottom: 1em; line-height: 1.5em; ">A Local Internet Registry (LIR) is an IR that primarily assigns address space to the users of the network services that it provides. LIRs are generally ISPs, whose customers are primarily end users and possibly other ISPs</p></span></div><div>The subsequent policy in section 6.5.1 also references "other organizations" and</div><div>does not reference "customers".</div><div><br></div><div>As such, I think this portion of the argument is somewhat moot.</div><div><br></div><div><br></div><div><blockquote type="cite"><div>whatever method. There are probably many ways to shoehorn them into the<br>policy; the method suggested to me by ARIN staff when I started this<br>process was to add a third category, which was what I decided to pursue.<br>I think this has some benefits, as opposed to expanding the LIR policy.<br>Although not all LIRs are ISPs, most are. In a time when municipal</div></blockquote></div><div><blockquote type="cite"><div>networks are under fire from ISPs for being anti-competitive, the last<br>thing that most community networks want is to be regarded as a direct<br>competitor to local ISPs, who in many cases are the ones from whom the</div></blockquote><div><br></div><div>Interesting. I'm surprised to hear this was a staff recommendation, but,</div><div>I'm even more curious as to how you see the differentiation between</div><div>a community network and an LIR from a policy perspective being meaningful.</div><div>IOW, how do you define the difference such that they aren't just another</div><div>organization receiving resources from ARIN and passing them out to</div><div>their subscribers/members/customers/whatever you want to call them?</div></div><div><blockquote type="cite"><div><br>community network is receiving their connectivity. Community networks<br>are predominantly providing services where traditional ISPs aren't, or<br>providing alternative services besides just internet access. But if they<br>are classed as LIRs, they may be regarded as ISPs, and will have more<br>difficulties with trying to fit in with commercial ISPs. Or such is my<br>perception. It also serves to prevent diluting the LIR policy, making<br>its rules more lax in what might be perceived as a disservice to those<br>organizations who have already qualified under that policy.<br><br></div></blockquote>I don't think that making them LIRs will necessarily create the perception</div><div>that they are ISPs. I think that the term LIR was specifically adopted to</div><div>address the fact that there are needs for IRs which are NOT ISPs, such</div><div>as is the case here.</div><div><br></div><div><blockquote type="cite"><div>On the other hand, changing the LIR policy to allow community networks<br>may be a simpler modification, a consideration that might override any<br>perceived benefits from the other route. Hopefully I can make this<br>version of the policy sufficiently acceptable to everyone, but maybe<br>that'll be something to try next time if this one doesn't get passed ;)<br><br></div></blockquote>I look at it this way. To do what you are describing, there is benefit to the</div><div>community at large if the community network is providing accurate information</div><div>about the redistribution of addresses through the SWIP process. If the</div><div>community network is given an assignment, then, that is not possible.</div><div>If they are treated as an LIR, otoh, this is easy.</div><div><br></div><div>Could you please point out the parts of existing 6.5.1 that you think are</div><div>incompatible with community networks?</div><div><br></div><div>Thanks,</div><div><br></div><div>Owen</div><div><br></div></body></html>