GCA Comments on Potential US Government Rules for Routing Security

Last week, we filed comments in response to the United States Federal Communications Commission (FCC) Notice of Proposed Rulemaking (NPRM) on Reporting on Border Gateway Protocol Risk Mitigation Progress. 

The NPRM proposes that nine major US Internet service providers draft “BGP Plans” primarily covering (1) efforts to create and maintain Route Origin Authorizations (ROAs) and (2) the extent to which they have implemented Route Origin Validation (ROV) filtering, and confidentially report those plans to the Commission.

We note that:

  1. Routing security is improving significantly already.
  2. Any reporting requirements must be lightweight, flexible, and aligned with current industry-accepted best practices.
  3. There is no silver bullet to improve routing security. It is a complex, global system that requires commitment and collaboration that transcends national borders.
  4. Better than regulation: Collaboration and the availability and sustainability of open-source tools, data platforms, and community efforts are essential for advancing routing security.

We’re proud to be the secretariat of Mutually Agreed Norms for Routing Security (MANRS) and we fully believe in the ability of the international community of network operators to work in a coordinated and collaborative way to continue improving routing security practices.

Better coordination of discussions and practices, along with collaboration between stakeholders in the Internet ecosystem and beyond, is necessary to ensure a fully functional — and safer — Internet of the future. Collaboration is the way forward.

If you’re new to the world of routing security, MANRS explainers on routing security and US Government activity related to it may help. 

You can also read our past comments here and here

Our full response to the NPRM: https://www.fcc.gov/ecfs/document/10717968220696/1