This proposal might be well intentioned, but as currently written is riddled with issues

1.4 Is it a listing in a blocklist or a report from a National CERT?

Why would a CERT be contacting RIPE about issues with an AS number? It potentially is an escalation of non-response, but that’s not what the document says

1.5 I don’t think the WG is really qualified to do this. While members of the WG might have deep experience in many aspects of security I cannot see how the group would suddenly morph into being arbiters of this. Same with respect to 3.2 - I’d also see this as being open to gaming

2.1 define “systematically” 

3.4 that assumes that blocklist operators will remove IP ranges in a timely fashion or following some kind of logical process. While some of the bigger ones might, some of the smaller ones might not 

3.5 “explicitly” - what does that mean?

Same with “proportionate” 

What exactly are these proposed restrictions?

These are just my initial observations

Regards

Michele