<BODY><P>I wish to comment on section 2.8, the definition of a Community Network. In my opinion, the stated definition is woefully inadequate to describe many of the community networks that exist in Canada and elsewhere. Limiting the definition to organizations with annual budgets less than $250,000 may encompass community networks in developing nations, but is far too limiting to include mature organizations in North America such as the National Capital FreeNet. NCF was incorporated as a not-for-profit community network in 1992 and our budget for 2009 exceeds $1 Million. Even the portion of our revenue that represents donations exclusively related to dial-up service is approaching this arbitrary $250,000 threshold. The fact is that we have more than 10,000 members now and continue to grow. In order to provide this much needed service in our community, we also engage in other activities beyond being a sim
ple dial-up provider in order to ensure that we can continue to offer connectivity to those who are unable to pay.</P>
<P>Nor would this definition work for many of the modern community owned fibre networks, where costs and revenues are typically higher, but nonetheless, where services and connectivity is offered to community agencies on a not-for profit basis, and by where by any other definition would indeed be community networks. </P>
<P>Limiting the definition of a Community Network by imposing a limit on budget size onerously limits the playing field to those organizations that have not grown up yet and that employ the technologies of yesterday and in some cases tomorrow, but most definitely not tomorrow. The whole reason for IPv6 is to provide for growth. Why allow growth in addresses while disregarding growth in costs and revenue.</P>
<P>Chris Cope<BR>President, National Capital FreeNet</P></BODY>