David summarized my views on the matter rather well. I am adamantly opposed to 
trying to make reallocations out of /40 (or longer) prefixes.

Really, a /40 is 256 /48s. Any rational reallocation would be at least a /44. 
Is anyone really in need of running an ISP with only 16 /48s?

I’d rather see any such ISP that is subordinate to a community network (if such 
a construct exists) get their space directly from ARIN under this same policy 
than see us daisy chaining community networks through micro-allocations in IPv6.

I’m operating under the assumption that any ISP that has a subordinate ISP that 
isn’t a community network isn’t really a community network, though I suppose it 
might be possible under the proposed rules to engineer such a thing if one 
tried hard enough. Nonetheless, I would argue that such a construct is a clear 
violation of the spirit of the policy even if you found a way to do it within 
the proverbial letter of the law.

Owen

> On Jan 16, 2018, at 12:57 , David Farmer <[email protected]> wrote:
> 
> On Tue, Jan 16, 2018 at 11:04 AM, Jason Schiller <[email protected] 
> <mailto:[email protected]>> wrote:
> I support the proposal with the exclusion of section 6.5.9.3.
> I support the proposal with the inclusion of section 6.5.9.3.
> I ask what is the purpose of section 6.5.9.3?
> Is section 6.5.9.3 needed?
> Is section 6.5.9.3 restricting the right thing?
> 
> Without section 6.5.9.3 the policy clearly defines a community network, 
> and allows what would otherwise be an LIR  getting a /32 (or /36 upon 
> request) 
> get instead a /40.
> 
> This would reduce there fees from X-small $1,000 annunally
> (or upon request 2X-small $500 annually) 
> to 3X-small $250 annually.
> 
> Sounds well and good.
> 
> 
> Section 6.5.9.3 adds a further restriction of there shall be no no 
> re-allocations,
> suggesting they cannot have a user of their space which in turn has its own 
> users.
> 
> (for the record I think you can drop the text "to other organizations."
> and just have "However, they shall not reallocate resources.")
> 
> 
> What behavior are you intending to prevent?
> 
> Section 6.5.9.3 has two parts. 
> 
> The first part says community networks are like other LIRs, they make 
> reassignments to end-users and makes it abundantly clear that section 6.5.4 
> and 6.5.5 apply to community networks. I don't want anyone arguing that those 
> sections don't apply to community networks.
> 
> The second part is the restriction on making reallocations. This comes back 
> to a couple of arguments; (A.) If community networks can make reallocations, 
> then there is no difference between them and a regular ISP/LIR, and some 
> participants in earlier discussions were adamant there needed to be a 
> difference between community networks and regular ISPs/LIRs. (B.) From the 
> debate on ARIN-2013-3: Tiny IPv6 Allocations for ISPs, some participants in 
> that discussion were adamant that a /40 was too small of an allocation for an 
> ISP, especially if that ISP was to make any reallocations. 
> 
> Doesn't the definition already have the required limits on behavior in the 
> form of:
> 
> "A community network is deployed, operated, and governed by its users, 
> for the purpose of providing free or low-cost connectivity to the community 
> it services."
> 
> It appears what you are preventing are the cases below.  I ask is this what 
> you
> intend to prevent?  and if so why?  
> 
> Should the Colorado IPv6 cooperative be prevented from providing transit to 
> the 
> Rocky Mountain Spotted IPv6 community network because they in turn assign 
> IPv6 addresses to community members?
> 
> 
> What if this is all within one community network?  What if the Rocky Mountain 
> Spotted IPv6 community network has a part of the network that is managed by
> a group in Ball Mountain community and another part is managed by a group in
> Mount Lincoln.  Wouldn't it make sense to re-allocate some of the Rocky 
> Mountain 
> Spotted IPv6 community network's /40 to Ball Mountain community and let them 
> handle the assignments to users in their locale?  
> 
> Personly, I'd be fine with removing the restriction on community networks 
> making reallocations, but I'd still want to have section 6.5.9.3 I'd rewrite 
> is as follows;
> 
> 6.5.9.3. Reassignments by Community Networks
> 
> Similar to other LIRs, Community Networks shall make reassignments and 
> reallocations in accordance with applicable policies, in particular, but not 
> limited to sections 6.5.4 and 6.5.5. 
> 
> What do others think should community networks be allowed to make both 
> reassignments and reallocations, or just reassignments?
> 
> Thanks.
>  
> -- 
> ===============================================
> David Farmer               Email:[email protected] 
> <mailto:email%[email protected]>
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota   
> 2218 University Ave SE        Phone: 612-626-0815
> Minneapolis, MN 55414-3029   Cell: 612-812-9952
> ===============================================
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