[connect-wg] Fwd: Re: BEREC consultation: contribution

I have only partially absorbed all aspects of the BEREC document and EU 
Article61, but my impression is of some important missing elements.  In 
particular, I have not noticed references to co-habitation of multiple 
NTP in one customer site.   The subject of resilience seems missing.

BEREC has given us a simple model on which to comment, with three levels 
of NTP.  Rather than defining what an NTP must always be, I prefer to 
consider what a customer needs from the NTP regardless of its logical 
location.

Given that we are RIPE, and given the absence of any bidirectional 
Public Data Communication Network other than the Internet, I focus my 
comments accordingly.


    Summary

Whatever the point of delivery of the Network connection, there must be 
clear signalling of whether or not the provision of Network connection 
is functional.

For Internet Access the NTP must indicate the status of its connection 
to the Internet. The form of the indication is considered next for each 
of the BEREC logical Termination Points.

*BEREC connection point C:*

(Where the NTP has a routing function or NAT, IP aware)

The NTP must indicate via its customer port, using IETF standard routing 
protocol, what connections it is offering /{list of minimum customer 
selectable protocols?}/. It must withdraw those routing announcements as 
quickly as the standard allows in the event that its peer router in the 
network becomes unavailable.

*BEREC connection point B:*

(Where the connection is provided at a modem port, Ethernet or WiFi)

The network must provide signalling of its status to the user. The user 
must be provided with:

  * visibility of the adjacent router(s) by routing protocol
    announcements from the operators router(s).  The list of offered
    routing protocols being a required part of the service description.
  * the IP address delegated by the operator for the CPE, manually or by
    DHCP.
  * the permanence of the IP address delegation  (Static or Dynamic)
  * the IP address of the adjacent router(s) in the provider's network,
    to enable security filtering

*BEREC connection point A:*

(Where the connection is by wired, optical or wireless Ethernet)

The Network must offer DHCP for the customer's delegated address, and 
the address of the available Network router.

The Network may offer IP routing protocols, as for connection point B.

The physical Signal must be withdrawn at the physical layer when the 
Network is otherwise unable to communicate loss of routes ( for 
comparison consider removal of dial tone).


*Other Requirements:*

1/ In cases B and C, user-configuration of the characteristics of the 
user port must be supported. Including Local MAC address, Local IP 
address, Local default router, Local routing protocol, as applicable.


2/ It must be contractually clear whether an Internet Connection service 
at an NTP is fully open, or in some way restricted.A fully open Internet 
Connection will have a public IP address capable of end to end 
communication with any other public Internet address on the same version 
of IP.  This would facilitate the customer in supporting an Internet 
Server, if they so choose.

Restrictions that make the connection less than a fully open Internet 
connection must be disclosed in the documentation of the connection 
service, and include:

  * Network Address Translation, either in the network (CGN) or on
    supplied NTP.
  * Blocking of access to some Internet addresses (as has sometimes been
    the case for open DNS resolvers).

3/ Power Supply resilience for network devices becomes increasing 
important. Consideration should be given to regulation of common low 
power battery backup supply connection for all NTP.


    Rationale

Most homes in the EU have more than one Network by which to access the 
Internet, commonly one fixed and one or more mobile. The NTP of each 
Network must allow for the existence of others and must enable the 
customer to program decisions about which Network to use.
Automated resilience of Internet connectivity becomes increasingly 
important as:

  * home working becomes more prevalent
  * critical devices such as medical appliances and alarm systems are
    connected in the home via the Internet

Therefore resilience for Internet connectivity must be considered in 
regulation with respect to both Network selection and power supply 
resilience, as follows.


*Network selection:*

On the PSTN the existence of Dial-tone has been the indication of 
availability at the NTP.
A home can easily have more than one PSTN NTP, and more than one fixed 
line connection to the Internet in addition to mobile.
Therefore, customer owned equipment must have the opportunity to be able 
to directly determine, in an automated fashion, whether or not 
connectivity via each Internet Connection Provider is functional.
Methods are dependent on the chosen logical Network Termination Point 
and are proposed in the Summary above.

*Power supply resilience:*

Logical termination equipment (e.g. modem) may be required for some 
physical access media. If power is not supplied from the network then 
the customer's domestic supply may be used. In the latter case the 
regulator must give consideration to backup supply standardisation.

The proliferation of individual AC to DC power converters and the need 
for Inverters to get back to AC supply levels from battery backup is not 
energy efficient.

Standardisation of low power DC supply to NTP devices would reduce 
electrical wastage and could reduce the number of manufactured 
components required where devices are permanently powered with DC.

Steve Nash

Writing my personal opinions, with the Sponsorship of NETSCOUT.


On 10/10/2019 17:52, Marco Hogewoning wrote:
> Dear colleagues,
>
> Earlier this week, BEREC (Body of European Regulators for Electronic Communications) announced a public consultation on their draft guidelines for interpreting the “network termination point (NTP)”. These guidelines have been designed in accordance with Article 61(7) of the European Electronic Communications Code to provide national regulatory authorities (NRAs) with guidance on how to interpret the EU directives and implement them in their national legislation.
>
> This consultation is open to the public. While the RIPE NCC has no particular position on this topic, we think it is important for the community to consider the impact of these guidelines. They could impact not only our members’ operations, but the RIPE NCC’s engagement strategy on a number of topics such as IPv6 and IoT security.
>
> We invite the Connect Working Group to discuss the proposed guidelines and, should it reach a rough consensus as determined by the chairs, the RIPE NCC is willing to submit that opinion as a response on behalf of the RIPE community. As we see pros and cons to either alternative, failure to reach consensus will mean we will not respond to this consultation on behalf of the RIPE community, but would instead encourage individual members to provide their own responses.
>
> I’ll provide a brief description of the problem space and the potential impact below, but I recommend reading the draft guidelines as they are posted on the BEREC website:
> https://berec.europa.eu/eng/document_register/subject_matter/berec/regulatory_best_practices/guidelines/8821-berec-guidelines-on-common-approaches-to-the-identification-of-the-network-termination-point-in-different-network-topologies
>
> Please note that while BEREC’s deadline is 21 November, we would need a few days to process and file the formal response and we kindly request the working group to respect close of business on 15 November as its internal deadline to reach consensus.
>
> Key Issues
>
> One of the key questions laid out in the document is whether or not the CPE or modem is part of the NTP. EU Regulation 2015/2120 states with regard to Internet access services in article 3(1):
>
>> “End-users shall have the right to access and distribute information and content, use and provide applications and services, and use terminal equipment of their choice […]”
> The 2016 BEREC Guidelines on net neutrality rules (paragraphs 26 and 27) provide further guidance on the implementation and state:
>
>> “In considering whether end-users may use the terminal equipment of their choice, NRAs should assess whether an ISP provides equipment for its subscribers and restricts the end-users’ ability to replace that equipment with their own equipment, i.e. whether it provides ‘obligatory equipment’.
>>
>> Moreover, NRAs should consider whether there is an objective technological necessity for the obligatory equipment to be considered as part of the ISP network. If there is not, and if the choice of terminal equipment is limited, the practice would be in conflict with the Regulation.”
> Not only is this subject to national definitions and implementations, it also allows for exceptions under “objective technological necessity”. Among other things, the draft guidelines go into a lot of detail with regards to the consequence of the different options that exist.
>
> As explained above, the RIPE NCC has no immediate position on which option is the better alternative. However, it could impact our engagement strategy in the longer term.
>
> There are roughly two alternative options: the modem or CPE is “obligatory” and as such will be supplied and maintained by the access provider as part of their network, or the end-user is allowed or even required to source their own equipment, which needs to be compatible with the network.
>
> The two different options would impact, for example, the RIPE NCC’s focus when it comes to IPv6 adoption. Although we have seen successful deployments under both scenarios, it is either the ISP that is in control and has to make the choice (which of course often means our members are deciding), or we need to somehow create awareness among end-users and engage more with manufacturers, importers and retailers to adopt equipment that supports IPv6.
>
> We also imagine that such a choice would impact the scale and, more importantly, the speed of IPv6 adoption.
>
> We also expect that if the prevailing choice would be to allow the end-user to select their own equipment, there will be an increased demand for strict standards and profiles to ensure interoperability. While the draft guidelines recognise that the CPE market is both competitive and innovative, we expect these discussions to lean towards additional certification requirements to ensure interoperability.
>
> In light of the current discussions about IoT security, especially in household appliances, we also see a big focus on the CPE as providing some security-related services. Several of these systems, such as SPIN and MUD/FUD, have been presented to the community. Again, a more scattered landscape where users select their own devices might make it challenging for these technologies to reach a sustainable level of adoption.
>
> More generally, we can expect that greater freedom of choice in selecting devices would come with some additional security challenges, where the increased variety could also lead to an increase in the variety of attack vectors and vulnerabilities. Also, as the CPE would no longer be in the ISP’s domain, we would lose the ability to quickly roll out patches and would instead have to trust the end-user or manufacturer to install updates in a timely fashion.
>
> Again, this is something where we would expect further discussion with regards to regulatory measures and (mandatory) certification to ensure minimum requirements are met and to protect the consumer.
>
> In either case, we trust the NRAs and the market to make an informed decision on the most appropriate approach and are happy to bring the RIPE community’s opinion forward to this consultation. Regardless of the outcome, we will continue to monitor these discussions and adjust our engagement strategy accordingly, both towards policymakers as well as the various market participants and, where necessary, the end-users.
>
> Regards,
>
> Marco Hogewoning
> External Relations, RIPE NCC
>
>
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-- 
Steve at nashfamily.me.uk is now my personal email address.
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