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IAB Response to the NIST RFI on USG NSSCET
statement-iab-response-to-the-nist-rfi-on-usg-nsscet-01

Document Type IAB Statement
Title IAB Response to the NIST RFI on USG NSSCET
Published 2023-12-21
Metadata last updated 2023-12-21
State Active
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statement-iab-response-to-the-nist-rfi-on-usg-nsscet-01

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Internet Architecture Board response to NIST RFI on USG NSSCET

On 2023-12-21, the IAB responded to the NIST Request for Information on Implementation of the United States Government National Standards Strategy for Critical and Emerging Technology (USG NSSCET):

The Internet Architecture Board (IAB) [IAB] welcomes the opportunity to provide input to the NIST RFI on the "Implementation of the United States Government National Standards Strategy for Critical and Emerging Technology (USG NSSCET)". The IAB provides oversight of the architecture for protocols and procedures used by the Internet and also handles the liaison management for the Internet Engineering Task Force (IETF) [IETF], the main engineering organization that works on standards relating to Internet technology.

The IETF is an open, diverse, and global community of network operators, engineers, researchers and many other stakeholders. The mission of the IETF is "to make the Internet work better" by producing "relevant technical documents that influence the way people design, use, and manage the Internet" (RFC 3935). The IETF develops, maintains, and evolves the Internet protocol suite and many related standards. The Internet Research Task Force (IRTF) [IRTF] is a closely aligned organization to the IETF with a focus on longer-term research related to the Internet.

The IETF currently works on maintaining and evolving critical core Internet protocols such as IP, TCP, DNS, BGP, QUIC, HTTP with a focus on increasing security and privacy, e.g. TLS, OAUTH, Messaging layer security (mls), while also creating new and emerging functions and services such as Supply chain transparency (scitt), Messaging Interoperability (mimi), Drone Remote Identification (drip) and Post-quantum cryptography (pquip).

The IAB has reviewed the NSSCET and is pleased to see the importance placed on participation in standards development and the commitment to industry-led open standards. In our submission we would like to provide some high-level input on how the strategy may apply to Internet standards in a way that is consistent with the core values of trust, openness, and security that underpin the underlying protocols that enable secure communication over the Internet.

We particularly focus on questions 1, 2, 4, 5, 7, 11, and 22 in the RFI by outlining the importance of actively advocating for open and global standards, investments in technology research that support innovation and excellence in standards development as well as the need for support through stable funding for industry and especially academia.

The importance of openness and inclusivity in global standards

We concur with the statement in the National Standards Strategy that links increased investment in R&D to increased participation in standards development activities. Support of a diverse set of stakeholders in participation in open standards development organizations such as the IETF ensures that global standards will take into account a broad set of viewpoints and needs. While participation from the private sector in the IETF is strong, we also value increased engagement from the research community. The IRTF provides a forum for the exchange of ideas between researchers, the standards development community and broader industry. Such exchange is crucial to ensure that the Internet technologies remain vibrant and up-to-date, and incorporate the latest innovations and ideas. It is also important to ensure that the research community is made aware of the concerns of industry and the practical challenges that affect the Internet today. This improves technical standards and supports researchers to have real-world impact from their efforts, encouraging spin-offs and technology transfer.

Encouraging engagement and investments in standards

We believe it is good for governments to have a strategy for encouraging engagement in open and transparent standards driven by the technical community. The National Standards Strategy can further this goal by coming up with government policies that promote the voluntary adoption and implementation of market-driven standards. Governments worldwide that support open and transparent standards should work to support voluntary standards participation from their countries.

There have been several initiatives across the globe where there is a push for geographically limited standards driven by governments and treaty-based organizations which fail to adequately represent the viewpoints of the industry and technical communities. In light of this, we appreciate the support by the U.S. government and other governments for industry led, open standards.

Leading economies' lack of participation in developing and using open, industry-led global standards may lead to a state where there are fragmented and incompatible standards globally. Reduced participation also means fewer opportunities to lead the technical work in standards setting. This further implies that the agenda and parameters of the discussions may be set in a way that reflects the needs of limited interests rather than those of the broader industry and users. The fragmentation in standards would lead to increased costs for the industry due to reduced economies of scale and resultant high prices for both US and global consumers in these Critical and Emerging Technologies(CETs).

We believe that participation in standards development activities requires a long-term commitment to initiate, drive and implement the necessary standards from a variety of stakeholders. In this response we address how governments can engage with industry and academia to incentivize long term R&D and participation in open voluntary standards

Even though participation in standards work is an important aspect for industry players to ensure stability and openness of the Internet as well as innovate and maximize their long-term gains, in the short term this may involve significant costs and divert resources away from their primary work products. This can lead to short term reduction in support and participation in economically challenging situations and therefore a significant impact on the standards process and continuous evolution of the Internet. Governments can support a healthy and continuously advancing standards development process by offering a range of incentives for companies to continuously participate and support open standards.

Similarly encouraging academia to work in standards as explained later in this response will not only help academia but will also help industry by developing a talent pipeline of standards competent engineers.

Several of the technologies that end up as CET standards have a long development and incubation lifecycle before they end up in that position. This means that there is a need to invest in foundational research on emerging technologies. This can be done by incentivizing industry as well as academia to kick off and sustain ideas that can lead to important innovations in these CETs, and providing sustainable funding and incentives for long-term engagement.

The Role of the academic community in CET standards development activities

The academic community can support standards development at the IETF for CET in three ways: (i) by providing a flow of innovative ideas into the standards community to ensure it remains vibrant and forward-looking and that innovations can be widely adopted for global benefit rather than for proprietary gain; (ii) by supporting industry in addressing near-term challenges by focused near-market collaborative research; and (iii) by providing neutral expertise to help evaluate standards proposals and ensure their technical feasibility and suitability for deployment – academia, when perceived to be acting independently, can contribute in ways that industry cannot.

The governments can support these contributions by incentivizing academia to work closely with industry and open standards organizations to ensure that there is cross-pollination of ideas between these communities. There are a lot of opportunities for technical experts to work with academic institutions to provide information about state-of-the-art solutions and to help direct academic research by talking about key problem areas. This supports an evolution cycle where academic research will lead to innovations in CET and industry adoption and deployment will lead the path to the next wave of academic research.

To support the academic community to engage with the standards development activities, it is necessary to provide long-term targeted financial support for the researcher community to be able to engage. The standards development timetable and funding requirements do not align well with the duration of typical research grants or academic promotion criteria – a combination of specific funding and encouragement to recognise the value of research impact and applied research activities is needed

IRTF as a key to incentivize academic engagement in standards development

The IRTF is composed of a number of focused and long-term Research Groups. These groups work on topics related to Internet protocols, applications, architecture and technology. The Research Groups [RGs] are expected to have the stable long-term membership needed to promote the development of research collaboration and teamwork in exploring research issues. Participation is by individual contributors, rather than by representatives of organizations.

Ever since the early days of their establishment, the IETF and the IRTF have worked in a symbiotic manner. For example, the IETF has been able to identify networking problems that could be helped by further research and communicate them to the IRTF where there might be a research group working in the problem space. In the other direction, a lot of the IETF standards have originated from the research pioneered in the IRTF and the results being sent over to the IETF when they are ready to be standardized. There are a few additional activities the IRTF and IETF have taken up to strengthen this pipeline and attract new research.

For example, the IRTF, in association with the ACM, organizes an annual Applied Networking Research Workshop [ANRW] that is an academic workshop that encourages the submission of results that could form the basis for future engineering work in the IETF, help better specify Internet protocols that could change operational Internet practices, or that could influence further research and experimentation. Further, the Applied Networking Research Prize [ANRP] is awarded to recognise and present the best recent results in applied networking and interesting new research ideas of potential relevance to the Internet standards community. These are examples that help to create awareness of relevant research to the engineering community in the IETF and also identifies up and coming researchers who are likely to have an impact on Internet standards and technologies, with a particular focus on cases where these people or ideas would not otherwise get much exposure or be able to participate in the discussion. These efforts are designed to provide incentives to the research community, considered broadly, to engage with the IRTF and IETF and provide important examples of the types of synergistic activities that can spur engagement with standards development. The key is aligning the incentives. Therefore, governments that wish to encourage researcher engagement with standards development should consider how to shift the research culture to incentivise and value such engagement.

Openness and Inclusivity as key factors for success of global Internet standards

One main way to entice broad and diverse participation in international SDOs is to minimize barriers to entry and participation in such SDOs. Openness is the basis for innovation in and on top of the Internet and key to its success. With respect to the IETF, we strive to ensure openness and reduce barriers by adhering to the following principles

  • Participation is fully open as there is e.g. no membership required to participate. We further actively aim to support a diverse set of participants, e.g., by rotating our in-person meeting over different global regions, invest in continuous improvement to remote participation that enables full active engagement, and support for new participants as well as e.g. diversity travel grants in the IRTF.

  • All IETF standards are available online at no charge, thus facilitating board adoption by e.g. SMEs or for use in research and by non-profits. In addition all records produced during the standards development process are open and freely available as well, such as email archives and intermediate draft versions of all documents, in order to maximize transparency.

  • All decisions are based on a bottom-up consensus-building process. As there is no membership, there is also no voting. Instead leadership judges “rough consensus” and ensures that all points raised have been taken into account but cannot impose decisions in a top-down manner.

Voluntary, open and industry-driven standards are the basis of the model used to create and grow the Internet. This model has been significantly responsible for the success of the Internet. Notably, with the initial support of the US government to seed this work, academia and open standards organizations like the IETF have driven the adoption, deployment, and explosive growth of the Internet. There are many similar success stories to be found such as WiFi (driven by the IEEE) and Cellular 5G/6G and beyond driven by organizations such as 3GPP/ATIS. The US government should encourage like-minded international partners to similarly support voluntary standards participation from their countries.

Making the US a more desirable location to host standards meetings and activities

The IETF as a global open standards organization is committed to a policy of rotating meetings around the world. This policy is mainly aimed at bringing about inclusivity by distributing the travel effort for existing IETF participants from around the world who physically attend meetings, and for distributing the time zone difficulty for those who participate virtually. This improves the chances that the resulting standards will represent a broad range of stakeholders and interests. With our current distribution of participants, one of our three annual plenary meetings is scheduled to take place in North America. Over the past few years, several of our key participants have been unable to participate in our North American meetings due to visa issues. We believe that US government initiatives to have an expedient procedure for visa application processing would be a very helpful step to make the US a desirable location to hold international standards meetings. This in turn would reduce barriers and costs for US-based participants in these standards meetings.

References

[IAB] Internet Architecture Board, https://iab.org
[IETF] Internet Engineering Task Force, https://ietf.org
[IRTF] Internet Engineering Task Force, https://irtf.org
[ANRP] Applied Networking Research Prize, https://www.irtf.org/anrp/
[ANRW] Applied Networking Research Workshop, https://www.irtf.org/anrw/
[WGS] Active Working groups, https://datatracker.ietf.org/wg/
[RGS] Active Research groups, https://www.irtf.org/groups.html