"I don't disagree that there are legitimate situations where LIR contract
termination could be justified, but non-compliance with a relatively
minor bureaucratic tickbox operation is not one of them."

Providing an operational abuse email inbox, to deal with a complaint about a host that is on a fibre optic connection and participating in a 500 GBPS botnet DDoS attack IS NOT A MINOR BUREAUCRATIC TICKBOX OPERATION.

It's people like this, that just don't get it & why not only should the resource be de-registered, but a fee should apply every time RIPE is required to investigate a non-responsive abuse mailbox or any other non-compliance with RIPE policy.






-------- Original Message --------
Subject: Re: [anti-abuse-wg] [policy-announce] 2017-02 Review Phase
(Regular abuse-c Validation)
From: Nick Hilliard <nick@foobar.org>
Date: Thu, January 25, 2018 1:40 am
To: Brian Nisbet <brian.nisbet@heanet.ie>
Cc: Gert Doering <gert@space.net>, anti-abuse-wg@ripe.net

Brian Nisbet wrote:
> No, it isn't. It's a statement that the process has many steps and that
> the NCC both say they do and clearly do whatever they can to not reach
> the termination point of the process. I'm not saying it could never
> happen, I'm saying that it if happens it's may have been started by
> 2017-02 but the deregistration would happen because over ~9 months the
> NCC would be unable to in contact with the LIR in any way.

Couple of things here.

Firstly, you're not denying that an extreme policy compliance
enforcement mechanism exists.

Having a policy which allows a LIR contract to be terminated is extreme,
de-facto. It is extreme because the consequences of address resource
withdrawal would be terminal for many address holders.

I don't disagree that there are legitimate situations where LIR contract
termination could be justified, but non-compliance with a relatively
minor bureaucratic tickbox operation is not one of them.

Presenting an argument about operational procedures and saying that this
hasn't been deployed in the past is a different issue.

It's akin to describing the colour of a pair of gloves and showing how
soft and how nice and even how comfortable they are, while pretending
that just because the gloves are so nice, that there isn't an iron fist
underneath.

Make no mistake, there here is an iron fist being inserted into the
policy here and the policy proposal document is - unusually for a policy
proposal - explicitly stating in the interpretation notes that this can,
and will be used if compliance is not achieved.

Again, I have no problem with a policy of LIR termination in situations
where that is justified. This is not one of those situations.

Secondly, there is no RIPE Community policy that I'm aware of which
mandates LIR termination for anything, and certainly not for minor
issues like this.

It needs to be pointed out that the RIPE NCC board has recently, and
without notification to either the membership or the RIPE Community,
substantially changed the terms of the "RIPE NCC Audit Activity"
document which is a RIPE NCC operational policy, not a RIPE Community
policy. The old policy stated that the escalation path was "further
measures may be necessary", without stating what those further measures
were. Notably, termination of the rights of resource holders was not
included. The new policy, dating from Jan 10th states that LIR
termination is now a formal and documented RIPE NCC policy. This
represents a substantial change in itself.

Confusingly, the "RIPE NCC Audit Activity" document is linked from
several RIPE Community policies without restriction, which means that we
now appear to be in the awkward situation where the RIPE NCC is
*arguably* making changes to RIPE Community policy (without reference or
even notification to the community) because existing references in RIPE
Community policy documents referred to RIPE-423 and previous versions
rather than RIPE-694. This is troubling in its own right.

What's inside the scope of AAWG is that apparently RIPE-694 now exists
and if a policy is passed which acknowledges this document content
change, then that RIPE Community policy - unlike all other previous RIPE
Community policies which acknowledged RIPE-423 - will give explicit RIPE
community mandate to termination of resource holder rights under the
terms of 694.

This marks a dramatic and substantial change in RIPE Community policy
because for the first time, the community would be explicitly giving a
mandate to the RIPE NCC to use RIPE-694 rather than RIPE-423.

With due respect to your analysis, this is a far larger issue than ought
to be dealt with in AAWG. If there is serious intent to continue with
any proposal which involves extinguishment of resource holder rights,
that discussion needs to be brought up into the context of the larger
RIPE Community and the RIPE NCC membership rather than just this working
group.

Nick