[anti-abuse-wg] Decision on Proposal 2017-02

Dear colleagues,

Please allow me to provide some clarification in regards to "relevant
RIPE Policies and RIPE NCC procedures" for this proposal, and some
details around how these have changed over time.

Since 2003, the RIPE IPv4 policy has stated that the RIPE NCC can close
LIRs for reasons such as policy violations and unresponsiveness. This
wording has not changed in the past 15 years (section 12.0):
https://www.ripe.net/publications/docs/ripe-288/at_download/pdf

The RIPE Policy "Contractual Requirements for Provider Independent
Resource Holders in the RIPE NCC Service Region" contains similar
requirements for independent number resources since its creation in
February 2009 (section 2.0):
https://www.ripe.net/publications/docs/ripe-452

Within this policy framework, the RIPE NCC developed the procedural
document: "Closure of Members, Deregistration of Internet Resources and
Legacy Internet Resources".

The relevant section of this document for members, "1.2.1.1 Violation of RIPE
Policies and RIPE NCC Procedures", has been active since March 2011.
Over the past seven years, mostly editorial changes have been made to the
wording of this section:
https://www.ripe.net/publications/docs/ripe-517#a1211

The most recent change to this procedure, in February 2018, was not
directly related to the proposed policy change. It was primarily around
suspension of the membership (i.e. voting rights) once the closure
procedure has been activated.

The following link shows the differences between the current document
and the previous version. It shows that no significant changes were made to section
1.2.1.1:
https://www.ripe.net/publications/docs/ripe-676/@@diff-items?id=ripe-697#a1211

As outlined in the impact analysis, the RIPE NCC has been investigating
reports of invalid abuse contacts under the current policy framework for
several years now. The only difference made by the policy proposal is
that it would cause us to proactively undertake this validation rather
than waiting for reports.

Until today, all of the abuse contact cases we investigated were
resolved without ever needing to trigger the closure and deregistration
procedure. However, making unresponsive resource holders aware of the
possibility of closure as a final resort has helped to ensure their
cooperation.

Please let me reiterate that the RIPE NCC will not activate the
closure procedure simply for failure to maintain the "abuse-mailbox:"
attribute.

The closure procedure could be activated if the resource holder refuses
to provide correct abuse contact information or is unresponsive over a
longer period (during which the RIPE NCC will have made several attemps
to contact the resource holder via different channels). If the closure
and deregistration procedure is triggered, the resource holder will
still have an additional three months to resolve the problem.

Kind regards,
Marco Schmidt
Policy Development Officer
RIPE NCC

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