Hello All,

While I am in general support of the proposal’s ideas, I have several concerns with regards to the specific implementation.

While the idea of an a complaint form (with teeth) sounds appealing, I do not believe submission should be open to everyone. Only the party holding rights (as registered in a RIR) should be able to file a report regarding their own IP space. If everyone is allowed to do so, we run several risks, namely that individuals with no knowledge of the situation (beyond that viewed in the public routing table) will file erroneous reports based on what they believe to be the situation (which may not be accurate, as some forms of permission for announcement are not documented in a way they could feasibly see). Allowing for competent complaints (with teeth) to be filed is a good idea; needlessly permitting internet vigilantes to eat management time based on a flawed view of the situation is not.

Additionally, while the policy does define a difference between accidental and intentional hijacking, it does not differentiate between the two with regards to policy violations. While some discretion should be left up to the expert, it seems odd to include this differentiation without simultaneously explicitly stating that accidental hijacking should generally be treated less severely. I am by no means attempting to state that constant, unlearned-from mistakes should be overlooked; I am merely stating that the odd one-off event should be explicitly prohibited from bringing down an entire LIR. Fat fingering happens.

Finally, how does the proposed policy apply to sponsored resources (ASNs and PI space)? Is an entire LIR to be held accountable for sponsoring the resources for users who are otherwise supposed to be independent? 

Jacob Slater