Independent Submission                                      D. Lazanski
Internet Draft                                         Last Press Label
                                                            M. McFadden
                                          Internet policy advisors, ltd

Intended status: Informational                         January 12, 2022
Expires: July 12, 2022

             Protocol and Engineering Effects of Consolidation

Status of this Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF), its areas, and its working groups.  Note that
   other groups may also distribute working documents as Internet-

   Internet-Drafts are draft documents valid for a maximum of six
   months and may be updated, replaced, or obsoleted by other documents
   at any time.  It is inappropriate to use Internet-Drafts as
   reference material or to cite them other than as "work in progress."

   The list of current Internet-Drafts can be accessed at

   The list of Internet-Draft Shadow Directories can be accessed at

   This Internet-Draft will expire on July 12, 2022.

Copyright Notice

   Copyright (c) 2020 IETF Trust and the persons identified as the
   document authors. All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents
   ( in effect on the date of
   publication of this document. Please review these documents
   carefully, as they describe your rights and restrictions with
   respect to this document. Code Components extracted from this

Lazanski, McFadden, Lear Expires July 12, 2022                 [Page 1]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   document must include Simplified BSD License text as described in
   Section 4.e of the Trust Legal Provisions and are provided without
   warranty as described in the Simplified BSD License.


   This document contributes to the continuing discussion on Internet
   consolidation. Over the last several years there have been many
   types of discussions around consolidation at a technical level, a
   economic or market level and also at an engineering level. This
   document aims to discuss recent areas of Internet consolidation amd
   provide some suggestions for advancing the discussion.

Table of Contents

   1. Introduction...................................................2
   2. Background to Consolidation Issues and the Role of Standards...3
   3. Overarching Issues Related to Consolidation....................6
      3.1. Technical.................................................6
      3.2. Economic..................................................6
      3.3. Security..................................................7
   4. Implications of Consolidation on Internet Architecture.........8
      4.1. The Changing Architecture of the Internet.................8
      4.2. The End-to-End Principle Redux............................9
   5. Implications of Consolidation on Protocol Design..............11
      5.1. Does Protocol Design Really Affect Consolidation?........11
      5.2. Case Studies in Consolidation and Protocol Design........11
         5.2.1. DNS over HTTPS (DOH)................................11
         5.2.2. Encrypted Server Name Indication (eSNI).............12
         5.2.3. Privacy Pass........................................13
         6  Potential Technical Risks...............................13
   6. Actions for the IETF, IRTF and IAB............................14
   7. Security Considerations.......................................15
   8. IANA Considerations...........................................15
   9. Conclusions...................................................15
   10. References...................................................15
      10.1. Informative References..................................15
   11. Acknowledgments..............................................18

1. Introduction

   Internet consolidation has been under discussion for the last
   several years. The 2019 Internet Society's "Global Internet Report:
   Consolidation and the Internet Economy" highlighted issues of
   consolidation and kicked started a series of discussions and

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 2]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   publications around consolidation.  Furthermore, a draft for the
   Internet Architecture Board (IAB) discussed issues of economic and
   technical consolidation. [1] Despite community interest, the draft
   expired without additional work or publication.

   Further discussions on this issue have stalled in in 2020 as we have
   been faced with the Covid-19 pandemic and all of the challenges that
   this brings to working and living. Recently, however, consolidation
   has been under discussion again on the mailing lists of the IETF and
   during several of the virtual meetings. Most notably draft-
   nottingham-avoid-internet-centralization-01 reinvigorated discussion
   on consolidation from a technical point of view and provided some
   suggestions for mitigation. This draft aims to provide another view
   on the issues of Internet consolidation and bring together current
   discussions and trends.

2. Background to Consolidation Issues and the Role of Standards

   Internet consolidation is "the process of increasing control over
   internet infrastructure and services by a small set of
   organizations." [2] Let us consider two general categories of
   concentration: "player" and "layer".  By player concentration, we
   mean the aggregating of a market to a small number of providers for
   a particular service.  Layer concentration means the combining of
   functions within a given layer. An example of "player" concentration
   would be a relatively small number of email service providers who
   offer billions of users email service. Or the number of web search
   providers or even web browser offerings. [3]

   The Internet is being consolidated at all layers, from the
   application layer to the network layer. Large companies, like
   Facebook and Google, account for a significant amount of the content
   and applications that are used online today. However, several of
   these large companies are dominating the development of protocols
   which fundamentally changes the way in which the Internet works and,
   ultimately, drives the traffic - and data - into the hands of a few
   companies. For example, Google has 81% of all searches online and
   94% of all mobile searches as of 2020. [4]

   Market consolidation is not limited to the Internet.  It happens
   when economies of scale provide highly aggregated firms an
   advantage.  For the last three decades, we have witnessed
   concentration occurring not only in telecommunications, but in the
   financial sector as well, just to name one other example.[5] The
   acceleration of consolidation has been assisted by "cloud"
   technologies, such as occurred with email.  In the case of email,

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 3]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   the service providers make use of SMTP to exchange messages, IMAP to
   provide those messages to a user interface, and HTTP, HTML, and
   JavaScript to present those messages directly to a user's browser.

   In other market consolidation cases, fewer Internet standards are in
   play.  In the case of home assistant tools such as the Amazon Echo
   or Google Home Assistant, communication from these devices to their
   respective clouds is largely proprietary in nature.  In particular,
   the information models and schemas they use are not exposed to the
   outside world.  This is because the bulk of the service is performed
   by the cloud, with relatively little processing occurring in the
   home.  This two-sided model eliminates the lengthy standards
   development process, thereby permitting faster service improvements.

   On the Internet over previous decades, numerous Internet Service
   Provider (ISP) markets were subject to deregulation, disaggregation
   of customers by regulatory requirement, consolidation, and to some
   extent, re-regulation.

   Standards have been viewed as a means to prevent barriers to entry.
   During the 1980s, AT&T was required to abide by standards as part of
   the consent decree that resolved antitrust litigation, leading to
   the ability of anyone to connect a telephone to its network.  By
   1994 standards were recognized as a means to prevent technical
   barriers to trade (TBT) during the Uruguay Round of the World Trade

   As mentioned, both the Internet Society and participants of the IETF
   have recently published on the subject of consolidation. At the
   IAB's Design Expectations vs. Deployment Reality in Protocol
   Development Workshop 2019 a handful of the participants discussed
   concentration and consolidation. [4] Andrew Sullivan looked at three
   types of concentration in open protocols; web services, network
   services and standardisation. Both Christian Huitema and Julien
   Maisonneuve noted concentration, which leads to consolidation, as an
   effect of economies of scale and network effects in business models
   in the implementation of business practices. Jari Arkko discussed
   the impacts of consolidation on the Internet infrastructure in a
   document for the IETF[6], with the document identifying issues
   including loss of resilience and increased risk of surveillance.  It
   goes on to note that "it seems prudent to recommend that whenever it
   comes to Internet infrastructure services, centralised designs
   should be avoided where possible".[7] From networks to applications,
   the overarching theme was that consolidation is taking place from
   one end of the Internet to the other. Additionally, the Journal of
   Cyber Policy published a special edition on Consolidation of the

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 4]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   Internet. Topics in this special issue included market concentration
   and security, DNS consolidation, supply chains, interoperability and
   Internet architecture. However, much is still yet to be discussed on
   consolidation at most layers of the Internet stack. [8]

   Recently, the US has scrutinized Internet platform services. The
   release of report Investigation of Competition in Digital Markets in
   October 2020 [9] showed that both concentration and consolidation in
   the online marketplace has left consumers with little choice, again
   at the application layer. Additionally, the US Justice Department
   announced it is suing Google for Antitrust violations on 20 October
   2020.[10] Both the report and the lawsuit show that concentration of
   power of Internet platform services has alarmed the House of
   Representatives and the Department of Justice to the point of
   investigation and possible criminal charges. None of this would have
   happed without consolidation of the application layer. The EU has
   been investigating the 'gatekeeper' status of big tech. [11] Recent
   reports reveal that the EU is considering ex ante solutions to the
   issue of the dominance of certain, large platforms. Such remedies,
   being discussed in the European Commission to date, include
   mandatory data sharing and/or mandatory interoperability
   requirements.[12] Such remedies seek to address the dominant market
   share of application layer services by American tech companies in

   The rhetoric and discussion of consolidation primarily focuses on
   Internet services and data. However, it is important to draw
   attention to the issues and risks of consolidation at other layers
   of the Internet beyond just the application layer. The application
   layer is directly user facing and, as a result, is what users
   experience. But the underlying infrastructure and protocols are also
   going through consolidation as they develop. The complete end to end
   encryption model forces data into endpoints which consolidates data
   into and handful of companies. Furthermore, protocol standards are
   facilitating this consolidation.

   The QUIC protocol is an example of the consolidation between layers
   of the Internet - and not at the application layer. Designed and
   deployed as a transport layer protocol, it effectively replaces TCP
   at the network layer while also adding improved security. The result
   is the merging or consolidation of three layers. QUIC should improve
   efficiency and delivery of applications, but also forces all data to
   be managed at the endpoint, which in this case is a browser, making
   it more difficult to manage traffic at the network layer.

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 5]

Internet-Draft Protocol, Engineering Effects of Consolidation January

3. Overarching Issues Related to Consolidation

  3.1. Technical

   Consolidation has led to the development of a few, large Internet
   companies which consumers are using by way of platform
   consolidation, as mentioned above. But consolidation also has led to
   the development of a protocols which are developed and used by these
   few, large Internet companies to control traffic flow and data
   capture as well.

   Overarching technical issues related to consolidation include an
   over-reliance on one or two entities and a handful of protocols.
   Large stakeholders who have developed and implemented these
   protocols control the rollout of upgraded versions without
   competition of even knowledge of it due to the lack of diversity in
   the market.

   For example, over 80% of the web browser market is held by two
   browsers: Chrome and Safari. Chrome alone accounts for 65% of the
   market overall [13] The makers of Chrome and Safari, Google and
   Mozilla, have dominated the development of protocols recently and
   the development QUIC, DoH and TLS.

   "Did the IETF create a better internet when it approved DoH? There's
   a lot of disagreement about that, but what has upset many is that
   DoH was a surprise - the IETF standardised it without consulting
   some who it was likely to affect," it says in RFC 8890 [14] However,
   there was little multistakeholder consultation and discussion prior
   to the adoption of DoH. This was more of a rapid development and
   deployment process, without the market driving the use cases and
   uptake. But what did drive the rapid development was the need for
   Google, with 65% of the browser market, to ensure that the data
   coming into and onto their services remained there. By forcing the
   concentration of the data at the endpoint, the data is consolidated
   into the service provider at that endpoint. Does this make a better

  3.2. Economic

   According to the Internet Society's 2019 report Consolidation In the
   Internet Economy the Internet economy is broadly defined as,
   "àeconomic activities that either support the Internet or are                                                                       fundamentally dependent on the Internet's existence."[15] Internet
   applications, service infrastructure and access provision are the
   primary three areas of economic activities on the Internet.

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 6]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   One focus of consolidation is around the concentration of power -
   consumer, technical and financial - into a handful of large Internet
   companies. The first point of engagement with any of these
   companies, including Facebook and Google, is through consumer
   applications. The ability to easily understand consolidation at an
   application layer, because of the widespread and common use of
   Facebook and Google, has caused the focus of consolidation and anti-
   competitive issues from policy makers and politicians to be at the
   application layer.

   However, consolidation doesn't always have its downsides.
   Consolidation allows for economies of scale, investment in
   infrastructure and the ability for small and medium enterprises to
   buy and use services, like cloud storage, content distribution
   networks and security technology, without having to build them from
   the ground up every time. However, the lack of market diversity
   means a lack of competition which, in turn means a lack of
   innovation and a lack of consumer choice.

   Amazon offers affordable cloud services and Cloudflare is one of
   only a handful of companies that are content delivery networks at a
   large scale. So large, in fact, that a substantial amount of
   Internet traffic transits through Cloudflare's servers, though there
   are many thousands of small CDNs. Rather than each and every
   Internet application company create their own storage and content
   delivery network, it is easier and more affordable to outsource both
   to other companies. Because of the cost of CDNs at scale, few
   companies offer these services.

   The market should be a regulating factor in consolidation. New
   entrants and competition in a market creates options for consumers
   that potentially pulls them away from popular websites and
   applications. When a market is not competitive or viable, regulation
   and anti-trust measures can intervene to remedy a consolidated
   market which is tending towards or has achieved monopoly status.
   Legal and regulatory intervention, however, tends to create its own
   set of issues as seen through several decades of EU intervention in
   big tech starting with Microsoft in 2004.  Unintended consequences
   with regulatory or legal intervention may skew the market even

  3.3. Security

   Consolidation of protocol development which has facilitated the
   secure, end to end encryption of information going over networks in
   recent years. New technologies such as DNS-over-HTTPS (DoH) and DNS-

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 7]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   over-TLS (DoT) standardised through the IETF process allow for
   confidential look up of DNS queries. However, it has forced updates
   onto many DNS servers and operating systems. This change in the look
   up process is forcing the technology to develop in a way which has
   narrowed the ability for companies and small industries to do DNS
   look ups without updating out of date hardware and software, thereby
   disenfranchising developing countries and smaller companies without
   big budgets. This is a form of market consolidation based on
   development choices by several large companies. These development
   choices are often technically opaque without transparency of what
   happens when updates take place, resulting in more difficulty when
   trying to troubleshoot security issues.

   The development of these protocols, while providing increased
   privacy and addressing issues concerning government surveillance,
   have forced other unintended consequences which is promoting

   Consequences of the security of the global Internet are evident. On
   June 8, 2021, a global outage of Fastly, a content delivery network
   (CDN), was caused by a software update which included an
   undiscovered bug. [16] While this was resolved within a working day,
   one of the main causes of the outage was a dependency on the limited
   number of CDNs running services in the cloud. Other CDNs, which
   resolved traffic via Fastly for redundancy, were also taken down as
   a result of the Fastly outage. This dependency is caused by
   consolidation and a concentration of infrastructure. A highly
   consolidated CDN network facilitates a less secure environment
   because of the weakening of resilience [17]

4. Implications of Consolidation on Internet Architecture

  4.1. The Changing Architecture of the Internet

   The phenomenon of consolidation may be in the eyes of the beholder.
   A government may see market failure or a need for regulation. [18] A
   civil society advocate may see it from the point of view of privacy
   or free speech. For the purposes of this draft we view it from the
   perspective of the underlying architecture of the public Internet.

   Consolidation in the Internet's architecture is not a new
   development. The approach of providing intermediaries to deliver
   service or content rather than the more traditional end-to-end
   approach has been in place for more than a decade. However, it is
   possible to argue that the architecture of the Internet has changed
   dramatically in the last decade.

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 8]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   The architecture of the Internet is always changing. New services,
   applications and content mean that the market creates new ways to
   deliver them. Consolidation clearly has economic, social and policy
   issues, but it is important to understand how consolidation affects
   the underlying architecture of the Internet. The impact of
   intermediaries on architecture is often not obvious.

   The use of intermediaries in the Internet's architecture may include
   the use of third parties to provide services, applications or
   content. In the early days of the Web, this was evident when
   rendering a web page that included content from multiple sources. In
   today's Internet the intermediaries are not so obvious.
   Authentication servers, content distribution networks, certificate
   authorities, malicious content protection and DNS resolution
   services are all examples of tools provided to the Internet by
   intermediaries - often without the knowledge or approval of both

   Having intermediaries embedded in the architecture is a different
   effect from having them embedded in the service structure. The
   domination by a few companies of the content and application layer
   is largely an economic effect of scale. On the other hand, there is
   a prevalent belief that the Internet puts intelligence at the edge.
   While that may have been true in the past, it is hard to argue that
   this is a feature of the contemporary Internet.

   There is a suggestion that the network simply provides for the
   transport of data. There are almost no network connections like that
   in today's Internet.  A consumer's view of the Internet is limited
   by unseen intermediaries of many types - some delivering positive
   services, others not. In either case, a consumer on the Internet
   seldom makes choices about those intermediaries: they are simply
   part of the fabric that makes up the Internet.

   It is into just consolidation from the perspective of a consumer.
   Almost all important parts of the architecture have been affected by
   consolidation: DNS resolution, access service, transit provision,
   content distribution and authorization. Consolidation in these areas
   has a direct effect on engineering and protocol design.

  4.2. The End-to-End Principle Redux

   The end-to-end principle is the idea that reliability and
   trustworthiness reside at the end nodes of networks rather than in
   the network itself. In other words, the idea was that the network
   itself was dumb and intelligence was at the edge or end. However,

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 9]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   Internet architecture is evolving in such a way that this principle
   is changing.

   Networks and the devices on the networks are acting as access
   consolidators. While, in the past, the network was a simple
   transporter of bits, today's networks see intermediaries
   consolidating both access and the delivery of information (e.g.
   streaming media). For example, 5G will allow for different services,
   systems and use cases at a very specific level. Network slicing in
   5G will concentrate services like video on demand into concentrated
   - and consolidation - areas on a network. [19] In other words, as
   specific types of services are relegated to a segregated part of a
   network, the availability and access of that service is limited to
   accessing a specific network. Depending on the type of device or
   maturity of the network infrastructure available at the point of the
   attempted access, options for access might be limited. If a network
   slice on 5G is where a specific service is located, for example, but
   it is only possible to use a 3G mobile network, then the service is
   unavailable. Thus, the service is only available on a consolidated
   part of the mobile network.

   Another change is how the layers of the Internet, as discussed in
   the QUIC example, are consolidating. Differentiation among layers is
   fading fast with the development of applications which require
   network access and control.

   Rapidly, the end-to-end principle is becoming the edge-to-edge
   principle. The layers of the internet are morphing into several
   consolidated layers and it is becoming difficult to differentiate
   between the end or edge, and also nearly impossible to ensure the
   reliability of the internet because of it. But the important part of
   this is the network is not dumb. Data processing, storage and highly
   evolved services (including custom data and metadata processing at
   the edge) means that the 'dumb' network is no longer dumb.

   If the number of organizations that provide those "network services"
   that we rely upon is small, our dependence is higher. In extreme
   cases of engineering, we put ourselves at risk of engineering a
   single point of failure. But also if organisations can't and won't
   enter the market, the market is left with very few options and
   choices. If the number of organizations that provide those "network
   services" that we rely upon is small, our dependence is higher. In
   extreme cases of engineering, we put ourselves at risk of
   engineering a single point of failure.

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 10]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   The trend toward highly specific and concentrated processing, as
   well as the drive for highly customised applications and services
   will drive the Internet away from an end-to-end principle. This will
   create not a network of networks, but a mesh. If the mesh is
   dependent on a small number of very large providers through
   consolidation, we will have engineered a single source of failure
   into the Internet.

5. Implications of Consolidation on Protocol Design

  5.1. Does Protocol Design Really Affect Consolidation?

   There is an idealized view of collaborative, multistakeholder
   approaches to Internet protocol development that it is democratic
   with all parties thinking about the greater good, like in the IETF.
   In reality, protocol development and standards are subject to vested
   interests, personal approaches and commercial realities.[20]
   Developing protocols, and standards more generally, takes time, much
   discussion and a bottom up approach. However, commercial
   organisations have different goals in the process of trying to
   standardize protocols. Larger organisations have more resources
   dedicated to protocol and standards development. Larger
   organisations with staff specifically dedicated to standards tend to
   have the ability to push for their proposals and their protocols.
   There is no coincidence that these companies are the ones that have
   facilitated consolidation on a commercial level and are facilitating
   consolidation on a protocol level.

  5.2. Case Studies in Consolidation and Protocol Design

5.2.1. DNS over HTTPS (DOH)

   The development of encrypted DNS, specifically DNS-over-HTTPS (DoH),
   has been driven by a desire to show full end-to-end encryption of
   network connections.  The protocol was completed and the DoH working                       groupwound up in March 2020 despite the absence of both resolver
   discovery and selection mechanisms. This may be addressed in the
   Client software is developing with interim discovery solutions which
   almost always favour the large, cloud-based resolver operators.
   This is leading to a situation where users are being presented with
   a very small number of pre-configured resolver options irrespective
   of their location - in some client software as few as three or four
   options may be presented. [22] Currently, there are many thousands
   of servers operating without DoH.

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 11]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   It is likely that most of the DNS traffic will be consolidated onto
   a handful of global operators, if multiple options for discovery
   mechanisms are not developed. The impact that such a loss of
   diversity of providers may have on the long-term resilience of DNS
   should not be underestimated. [23] Nor should the attractiveness of
   these potential network chokepoints to attack be overlooked either
   to access consolidated data or launch an attack from.
   One danger is that if DNS traffic is concentrated onto a small
   handful of global operators and turned 'automatically-on' the result
   would be default adoption by the vast majority of the Internet's
   clients.  The suggestion that there were mechanisms for users to
   opt-out would not matter in the face of statistics that regularly
   show that users almost never change default settings. Currently, the
   deployment approach for DoH is opt-in. For CDNs, DoH default-on
   would disrupt and render CDN geolocation designed to manage traffic
   flows more efficient closer to the desired delivery location. Thus,
   protocol design decisions that are enshrined in default settings
   will become the norm. In this case, default on, which facilitates
   consolidation, will become standard.

   By routing the DNS over HTTPS, it becomes much easier to track user
   activity through the use of cookies.  Therefore a protocol that was
   developed to enhance user privacy and security could actually
   undermine both: privacy through the use of cookies and security by
   consolidating DNS traffic onto far fewer resolver operators that are
   far more attractive targets for malicious actors of various types.
5.2.2. Encrypted Server Name Indication (eSNI)

   Options to encrypt the Server Name Indication (SNI) have been
   explored in the TLS working group but to date it has not been
   possible to develop a solution without shortcomings.  This flaw in
   the encrypted SNI (eSNI) options under evaluation required a rethink
   in the approach being taken.
   The solution now proposed, Encrypted Client Hello (ECH, previously
   called ECHO) assumes that private origins will co-locate with or
   hide behind a provider (CDN, application server etc.) which can
   protect SNIs for all of the domains that it hosts.[24]  Whilst there
   is logic in this approach, the consequence is that the would-be
   standard encourages further consolidation of data to aid privacy.
   What it does not appear to consider is the attractiveness of this
   larger data pool to an attacker, compared with more dispersed

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 12]

Internet-Draft Protocol, Engineering Effects of Consolidation January

5.2.3. Privacy Pass

   The Privacy Pass protocol provides a set of cross-domain
   authorization tokens that protect the client's anonymity in message
   exchanges with a server.  This allows clients to communicate an
   attestation of a previously authenticated server action, without
   having to reauthenticate manually.  The tokens retain anonymity in
   the sense that the act of revealing them cannot be linked back to
   the session where they were initially issued.

   For Privacy Pass to succeed clients must be able to acquire tokens
   that they can later redeem with greater privacy and anonymity. This
   document does not discuss the goals of privacy or anonymity.
   Instead, it identifies a problem related to the upper bound in
   number of servers that affects the Privacy Pass ecosystem.

   "Server centralization" is the strict limit or upper bound in the
   number of servers available from which a client can acquire a token
   for later redemption.

   The architecture draft for Privacy Pass specifies an upper limit of
   four for this upper bound. Four is a small number through which to
   run authorizations. There is little room for mistakes or redundancy.

   An upper bound to available Privacy Pass servers creates
   architectural, engineering and practical problems for the deployment
   of the protocol. Any successful deployment of Privacy Pass must find
   mitigations for these problems.

  6 Potential Technical Risks

There are a number of potential risks to the security, stability and
performance of the Internet and many of them are well articulated in
draft-livingood-doh-implementation-risks-issues-04, but some notable
ones are:
          1. Significant operational shift of the global Internet from a
            highly distributed to a centralised system. This would
            impact both security and resilience.
          2. Decreased stability due to the fact that a centralised
            system will have higher fragility, fewer points of failure
            and greater impact on the system when it does fail.
          3. Increased security issues caused by the reduction of number
            of recursive DNS operators. [see

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 13]

Internet-Draft Protocol, Engineering Effects of Consolidation January

            websites-and-services] Lack of distributed and recursive
            DNS creates a lack of redundancy for when security attacks
            hit parts of the Internet.
          4. Loss of security threat visibility due to degraded ability
            to use DNS blocklists and overall network management for
            malware, phishing, spam, DDoS and etc if DNS management is
            consolidated into a few operators.
          5. Reduced diversity in the Internet ecosystem. Diversity
            creates greater redundancy, resilience and agility to
            respond to attacks, outages and network issues.

6. Actions for the IETF, IRTF and IAB

   This document proposes a set of concrete actions:

   1] using MAPRG in the IRTF to attempt to establish metrics for
   consolidation. The goal would be to attempt to gain consensus on
   measurements for consolidation and a mechanism for gathering those
   metrics over time to answer the question of how much and how quickly
   the Internet is consolidating.

   2] encouraging the consideration of consolidation in protocol design
   either through the requirement of a new section in RFCs that
   addresses consolidation or thorough guidance to area director
   reviews of documents in IETF Last Call.

   3] a new IAB workshop on the Implications of Consolidation on
   Protocol Design with the goal of encouraging position papers from a
   variety of stakeholders in the protocol design and implementation

   4] potentially expanding the human rights review process for
   protocols to include examination of individual protocol design on
   markets, enterprises and society.

   5]attract and retain the participation of operators and implementors
   who may be impacted.

   6]ensure detailed community assessment of risks and issues. In
   particular, assess the following issues:

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 14]

Internet-Draft Protocol, Engineering Effects of Consolidation January

        . What is the threat model that makes this technical change
        . What are the security and privacy implications?
        . What are the implications for stability, operations, network
           and systems administration, software development, diversity
           and etc?
        . Do the benefits outweigh any drawbacks?
        . What alternatives to the changes could be made?

7. Security Considerations

   While this document does not describe a specific protocol, it does
   discuss the evolving architecture of the Internet. Changes to the
   Internet's architecture have direct and indirect implications for
   the Internet's threat model. In another draft [25], we discuss how
   the evolution of the Internet has changed the threat model.
   Specifically, the changes to the end-to-end model (see section 4.2
   above) have inserted new interfaces which must be reflected in
   security considerations for new protocols.

8. IANA Considerations

   This memo contains no instructions or requests for IANA. The authors
   continue to appreciate the efforts of IANA staff in support of the

9. Conclusions

   This document seeks to rekindle and restart the discussion on
   consolidation. As argued above, Internet consolidation is happening
   at different places and different layers of the Internet. Though
   there has been interest in the Internet consolidation in the past,
   now is the time to start the discussions again.

10. References

  10.1. Informative References

   [1]   Considerations on Internet Consolidation and the Internet
         Architecture [draft-arkko-iab-internet-consolidation-02].

   [2]   IBID

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 15]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   [3]   Google has over at least 80% worldwide market share.

   [4]   Investigation of Competition in Digital Markets, Subcommittee
         on Antitrust, Commercial and Administrative Law of the
         Committee on the Judiciary, United States House of
         Representatives, 6 October 2020.

   [5]   Following An Unexpected Rebound In M&A, Businesses Are Banking
         On A New Kind Of Dealmaking For Growth In A Post-Covid World

   [6]   Design Expectations vs. Deployment Reality in Protocol
         Development Workshop 2019, Intern Architecture Board

   [7]   Centralised Architecture in Internet Infrastructure [draft-

   [8]   IBID page 5.

   [9]   Journal of Cyber Policy, Volume 5, Issue 1 (2020) Special
         Issue: Consolidation of the Internet

   [10]  Investigation of Competition in Digital Markets, Subcommittee
         on Antitrust, Commercial and Administrative Law of the
         Committee on the Judiciary, United States House of
         Representatives, 6 October 2020.

   [11]  Statement of the Attorney General on the Announcement Of Civil
         Antitrust Lawsuit Filed Against Google, United States
         Department of Justice, 20 October 2020.

   [12]  Digital Services Act package, European Commission, ongoing

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 16]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   [13]  Browser & Platform Market Share January 2021

   [14]  RFC 8890, The Internet is for End Users. Nottingham, Mark.
         August 2020.

   [15]  Consolidation In the Internet Economy, Internet Society, 2019.

   [16]  Fastly Blog, June 8, 2021.

   [17]  The Deeper Root Cause of the Fastly and Akamai Outages,
         CircleID, June 28, 2021

   [18]  See Google, antitrust and how to best regulate big tech, The
         Economist, 7 October 2020

   [19]  What is Network Slicing?

   [20]  Dominique Lazanski, Governance in international technical
         standards-making: a tripartite model, Journal of Cyber
         Policy, 4:3, 362-379, 2019.

   [21]  DNS over HTTPS (doh)

   [22]  At the time of writing, the Firefox browser presents a list of
         three pre-configured resolver options to North American users:
         Cloudflare, NextDNS and Comcast.

   [23]  Cloudflare DNS goes down taking a large piece of the Internet
         with it, 17 July 2020.

   [24]  TLS Encrypted Client Hello draft-ietf-tls-esni-07

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 17]

Internet-Draft Protocol, Engineering Effects of Consolidation January

   [25]  An Internet for Users Again draft-lazanski-smart-users-

11. Acknowledgments

   Many thanks to all who discussed this with us, especially Jason

   This document was prepared using

Lazanski, McFadden, Lear Expires July 12, 2022 [Page 18]

Internet-Draft Protocol, Engineering Effects of Consolidation January

Authors' Addresses

   Dominique Lazanski
   Last Press Label
   London, UK


   Mark McFadden
   Internet policy advisors ltd
   Chepstow, Wales, UK


Lazanski, McFadden, Lear Expires July 12, 2022 [Page 19]