[Federal Register Volume 87, Number 48 (Friday, March 11, 2022)]
[Notices]
[Pages 14006-14010]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-05121]


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FEDERAL COMMUNICATIONS COMMISSION

[PS Docket No. 22-90, FCC 22-18; FRS 75229]


Secure Internet Routing

AGENCY: Federal Communications Commission.

ACTION: Request for comments.

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SUMMARY: In this document, the Federal Communications Commission (FCC 
or the Commission) seeks comment on vulnerabilities threatening the 
security and integrity of the Border Gateway Protocol (BGP), which is 
central to the Internet's global routing system, its impact on the 
transmission of data from email, e-commerce, and bank transactions to 
interconnected Voice-over Internet Protocol (VoIP) and 9-1-1 calls, and 
how best to address them.

DATES: Comments are due on or before April 11, 2022; and reply comments 
are due on or before May 10, 2022.

ADDRESSES: You may submit comments, identified by PS Docket No. 22-90, 
by any of the following methods:
    <bullet> Electronic Filers: Comments may be filed electronically by 
accessing ECFS at https://www.fcc.gov/ecfs.
    <bullet> Paper Filers: Paper filings can be sent by hand or 
messenger delivery, by commercial overnight courier, or by first-class 
or overnight U.S. Postal Service mail.
    <bullet> People with Disabilities: To request materials in 
accessible formats for people with disabilities (braille, large print, 
electronic files, audio format), send an email to <a href="/cdn-cgi/l/email-protection#ee888d8ddbdedaae888d8dc0898198"><span class="__cf_email__" data-cfemail="761015154346423610151558111900">[email protected]</span></a> or 
call the Consumer & Governmental Affairs Bureau at 202-418-0530 
(voice), 202-418-0432 (tty).
    For detailed instructions for submitting comments and additional 
information on this proceeding, see the SUPPLEMENTARY INFORMATION 
section of this document.

FOR FURTHER INFORMATION CONTACT: For additional information on this 
proceeding, contact James Wiley of the Cybersecurity and Communications 
Reliability Division, Public Safety and Homeland Security Bureau, at 
<a href="/cdn-cgi/l/email-protection#bbd1dad6dec895ccd2d7dec2fbddd8d895dcd4cd"><span class="__cf_email__" data-cfemail="543e353931277a233d38312d143237377a333b22">[email protected]</span></a> or (202) 418-1678 or Minsoo Kim of the 
Cybersecurity and Communications Reliability Division, Public Safety 
and Homeland Security Bureau, at <a href="/cdn-cgi/l/email-protection#0e6367607d6161206567634e686d6d20696178"><span class="__cf_email__" data-cfemail="3a575354495555145153577a5c5959145d554c">[email protected]</span></a> or (202) 418-1739.

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Notice 
of Inquiry, FCC 22-18, released February 28, 2022. The full text of 
this document is available at https://www.fcc.gov/document/fcc-launches-inquiry-internet-routing-vulnerabilities.
    Ex Parte Rules. This proceeding shall be treated as a ``permit-but-
disclose'' proceeding in accordance with the Commission's ex parte 
rules. Although the rules do not generally require ex parte 
presentations to be treated as ``permit but disclose'' in Notice of 
Inquiry proceedings, the Commission exercises its discretion in this 
instance, and finds that the public interest is served by making ex 
parte presentations available to the public, in order to encourage a 
robust record. Persons making ex parte presentations must file a copy 
of any written presentation or a memorandum summarizing any oral 
presentation within two business days after the presentation (unless a 
different deadline applicable to the Sunshine period applies). Persons 
making oral ex parte presentations are reminded that memoranda 
summarizing the presentation must (1) list all persons attending or 
otherwise participating in the meeting at which the ex parte 
presentation was made, and (2) summarize all data presented and 
arguments made during the presentation. If the presentation consisted 
in whole or in part of the presentation of data or arguments already 
reflected in the presenter's written comments, memoranda, or other 
filings in the proceeding, the presenter may provide citations to such 
data or arguments in his or her prior comments, memoranda, or other 
filings (specifying the relevant page and/or paragraph numbers where 
such data or arguments can be found) in lieu of summarizing them in the 
memorandum. Documents shown or given to Commission staff during ex 
parte meetings are deemed to be written ex parte presentations and must 
be filed consistent with Rule 1.1206(b), 47 CFR 1.1206(b). Participants 
in this proceeding should familiarize themselves with the Commission's 
ex parte rules.
    Confidentiality. The Commission recognizes that some comments could 
contain information that the submitter believes should not be made 
available to the general public because of commercial or national 
security reasons. Parties may request that such information be kept 
confidential, identifying the specific information sought to be kept 
confidential, providing the reasons for the request, and otherwise 
following the procedures set forth in section 0.459 of the

[[Page 14007]]

Commission's rules. If a party requests confidential treatment of a 
comment, it must file an original and one copy of the confidential 
version of the comment on paper, following the procedures below, and a 
public version of the filing that omits only the confidential 
information and is otherwise identical to the confidential version, 
using either the electronic filing or the filing-by-paper procedures 
below.
    Comment Filing Procedures. Interested parties may file comments and 
reply comments on or before the dates indicated on the first page of 
this document. Comments may be filed using the Commission's Electronic 
Comment Filing System (ECFS) or by paper. All filings must be addressed 
to the Commission's Secretary, Office of the Secretary, Federal 
Communications Commission.
    <bullet> Paper Filers: Parties who choose to file by paper must 
file an original and one copy of each filing. Paper filings can be sent 
by hand or messenger delivery, by commercial overnight courier, or by 
first-class or overnight U.S. Postal Service mail. All filings must be 
addressed to the Commission's Secretary, Office of the Secretary, 
Federal Communications Commission.
    <bullet> Effective March 19, 2020, and until further notice, the 
Commission no longer accepts any hand or messenger delivered filings. 
This is a temporary measure taken to help protect the health and safety 
of individuals, and to mitigate the transmission of COVID-19. See FCC 
Announces Closure of FCC Headquarters Open Window and Change in Hand-
Delivery Policy, Public Notice, 35 FCC Rcd 2788 (2020), https://www.fcc.gov/document/fcc-closes-headquarters-open-window-and-changes-hand-delivery-policy.
    <bullet> Commercial overnight mail (other than U.S. Postal Service 
Express Mail and Priority Mail) must be sent to 9050 Junction Drive, 
Annapolis Junction, MD 20701.
    <bullet> U.S. Postal Service first-class, Express, and Priority 
mail must be addressed to 45 L Street NE, Washington, DC 20554.
    Availability of Documents. Comments, reply comments, and ex parte 
submissions will be publicly available online via ECFS. These documents 
will also be available for public inspection during regular business 
hours in the FCC Reference Information Center, when FCC Headquarters 
reopen to the public.
    People with Disabilities. To request materials in accessible 
formats for people with disabilities (braille, large print, electronic 
files, audio format), send an email to <a href="/cdn-cgi/l/email-protection#45232626707571052326266b222a33"><span class="__cf_email__" data-cfemail="0d6b6e6e383d394d6b6e6e236a627b">[email protected]</span></a> or call the 
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-
418-0432 (tty).

Synopsis

    1. The Commission plays an important role in protecting the 
security of America's communications networks and critical 
infrastructure. The Commission, in tandem with its federal partners, 
has urged the communications sector to defend against cyber threats, 
while also taking measures to reinforce our Nation's readiness and to 
strengthen the cybersecurity of vital communications services and 
infrastructure, especially in light of Russia's escalating actions 
inside of Ukraine. Today, the Commission builds on those efforts. With 
this Notice of Inquiry (Notice), the Commission seeks comment on 
vulnerabilities threatening the security and integrity of the Border 
Gateway Protocol (BGP), which is central to the internet's global 
routing system, its impact on the transmission of data from email, e-
commerce, and bank transactions to interconnected Voice-over Internet 
Protocol (VoIP) and 9-1-1 calls, and how best to address them.
    2. BGP is the routing protocol used to exchange reachability 
information amongst independently managed networks on the internet. 
These independently managed networks (also termed ``domains'') loosely 
map to one or more ``Autonomous Systems'' (so termed because the 
administration of the network is the sole responsibility of a single, 
independent entity). BGP's initial design, which remains widely 
deployed today, does not include security features to ensure trust in 
the information that it is used to exchange. BGP was designed at a time 
when the number of independently managed networks on the internet was 
low and the trust among them was high. As a result, a bad network actor 
may deliberately falsify BGP reachability information to redirect 
traffic to itself or through a specific third-party network, and 
prevent that traffic from reaching its intended recipient. When a bad 
actor directs traffic to be dropped in this way, it is commonly 
referred to as a ``blackhole.'' These ``BGP hijacks'' expose U.S. 
citizens' personally identifiable information, enable theft, extortion, 
and state-level espionage, and disrupt otherwise-secure transactions. 
The Commission uses the term ``BGP hijacking'' to refer to any 
deliberate injection of routing information away from the optimal (or 
most secure) route, including both false route origination and path 
interception attacks.
    3. Congress created the Commission, among other reasons, ``for the 
purpose of the national defense [and] for the purpose of promoting 
safety of life and property through the use of wire and radio 
communications.'' To obtain ``maximum effectiveness from the use of 
radio and wire communications in connection with the safety of life and 
property,'' the Communications Act of 1934, as amended, directs the 
Commission to ``investigate and study all phases of the problem and the 
best methods of obtaining the cooperation and coordination'' of such 
systems.''
    4. The Commission has taken targeted steps to protect the nation's 
communications infrastructure from potential security threats. Most 
recently, the Commission encouraged communications companies to review 
cybersecurity practices to defend against threats to critical 
infrastructure, sought comment on how the Commission can leverage its 
equipment authorization program to encourage device manufacturers to 
consider cybersecurity standards and guidelines, and acted in the 
public interest to deny and revoke the section 214 authority of certain 
carriers to provide telecommunications service in the United States.
    5. Independently managed networks are essential to the daily 
functioning of critical infrastructure such as transportation, gas and 
electric power, water, and financial markets. These networks can be 
vulnerable to attack if they deploy a version of BGP at their borders 
that cannot verify the integrity or authenticity of routing 
information. These vulnerabilities have two main causes: (1) Validating 
a route's origin; and (2) securing and validating the correct BGP path 
to a given destination. BGP's vulnerabilities allow a network operator 
to accidentally or maliciously misconfigure its BGP routers to falsely 
advertise that its network contains the intended destination for 
certain internet traffic, or is on the path to that destination. By 
advertising incorrect routing information, a bad actor could spread 
incorrect information to other networks and cause traffic intended for 
the advertised destination to be misrouted to, or through, the bad 
actor's network. Causing internet traffic to depart from its most 
efficient path is termed ``BGP hijacking.'' Although BGP hijacking can 
occur anywhere on the global internet, the Commission has an interest 
in minimizing or eliminating opportunities for it within its 
jurisdiction because it can potentially harm U.S. citizens, commerce, 
and public safety operations.
    6. Russian network operators have been suspected of exploiting 
BGP's

[[Page 14008]]

vulnerability to hijacking, including instances in which traffic has 
been redirected through Russia without explanation. In late 2017, for 
example, traffic sent to and from Google, Facebook, Apple and Microsoft 
was briefly routed through an internet service provider in Russia. That 
same year, traffic from a number of financial institutions, including 
MasterCard, Visa, and others was also routed through a Russian 
government-controlled telecommunications company under ``unexplained'' 
circumstances.
    7. Over the past two decades, internet stakeholders have developed 
new standards, specifications, and best practice recommendations 
intended to address the security risk that BGP poses. The Internet 
Engineering Task Force (IETF), the principal authority responsible for 
internet standards, has finalized several standards to reduce BGP 
vulnerabilities, including BGPsec, an extension to BGP that provides 
security for the path through which reachability information passes. 
The National Institute of Standards and Technology (NIST) has released 
a practice guide proposing a method of validating routes' origins and 
recommendations for resilient exchange between independently managed 
networks. In 2017, the Internet Society launched Mutually Agreed Norms 
for Routing Security (MANRS), an organizational initiative with 
membership including over 700 network operators, Internet Service 
Providers, and enterprises, which aims to reduce or prevent route 
hijacking and denial of service attacks by requiring network operators 
to implement available tools and applicable IETF Best Common Practice 
standards. MANRS focuses on improving routing security by filtering 
routing advertisements to include only those likely to be relevant to 
the customer BGP router; enabling source IP address validation for 
customer networks; coordinating and sharing contact information for 
network operations center contacts through regional internet 
registries, and enabling routing information to be validated on a 
global scale. MANRS offers a tool called ``MANRS Observatory'' that 
aggregates data from trusted sources into a dashboard to help network 
operators improve the security of their networks. Similarly, the 
Commission's Communications Security, Reliability, and Interoperability 
Council (CSRIC) has reported on best practices and recommendations to 
improve the security of BGP. The roman numerals following the name of 
federal advisory committee, ``CSRIC,'' enumerate the successive years 
during which the Commission has chartered CSRIC to provide 
recommendations on selected topics. CSRIC III recommended that network 
operators ensure that BGP routers' internet routing registries are 
accurate, complete, and up-to-date, and that network operators use a 
standards-based approach for providing cryptographically secure 
registries of internet resources and routing authorizations, a Resource 
Public Key Infrastructure (RPKI). In this connection, the FCC sought 
comment on the implementation and effectiveness of the CSRIC III 
recommendations and/or alternatives that stakeholders have developed 
since the time of the CSRIC's original work to address these 
challenges. CSRIC VI recommended that network operators support MANRS 
and IETF Best Common Practice standards. Notwithstanding this work, 
available information suggests that the voluntary adoption and 
deployment of such measures has been such that many of the 
independently managed networks that comprise the internet remain 
vulnerable because they have not taken advantage of these measures.
    8. Scope of Inquiry. In this Notice, the Commission seeks comment 
on any steps that the Commission should consider taking to help protect 
and strengthen the nation's communications network and other critical 
infrastructure from vulnerabilities posed by BGP, and how the 
Commission can best facilitate the implementation of industry standards 
and best practices to mitigate the potential harms posed by these 
vulnerabilities. In order to better understand the BGP ecosystem, the 
Commission seeks comment on the extent to which Internet Service 
Providers, public Internet Exchange Providers, and providers of 
interconnected VoIP service have deployed BGP routers in their 
networks. Do content delivery networks, and providers of cloud services 
operate BGP routers in their networks as well? What other types of 
entities operate BGP routers? The Commission recognizes that there are 
entities that do not operate BGP routers, but that are otherwise well 
positioned to support the development and implementation of BGP 
security practices. For example, there are several regional, national, 
and local internet registries that manage the allocation and 
registration of internet number resources, and support RPKIs. As an 
example, one such regional internet registry, the American Registry for 
Internet Numbers (ARIN) supports the roles of a digital certificate 
authority and acts as a repository for routing information and as a 
validator of RPKI data. Additionally, the Internet Corporation for 
Assigned Names and Numbers (ICANN), through its affiliate, Internet 
Assigned Numbers Authority (IANA), has responsibility for coordinating 
the internet's unique identifiers. The Commission seeks comment on what 
role these and other entities, including vendors of BGP routers or 
other networking equipment, have in supporting the development and 
implementation of BGP security practices. What threats to internet 
routing should the Commission consider within the scope of this inquiry 
in addition to BGP hijacking? For example, to what extent could BGP 
security measures prevent pervasive monitoring?
    9. Measuring BGP Security. The Commission seeks comment on whether 
industry has defined metrics for identifying BGP routing security 
incidents and for quantifying their scope and impact. To what extent 
are available tools, such as NIST's RPKI Monitor, Automatic and Real-
Time dEtection and Mitigation System (ARTEMIS), BGPstream, BGPMon, 
Kentik, and Traceroute, able to rapidly and accurately detect BGP 
hijacks or router misconfigurations? To what extent do these tools 
distinguish malicious routing changes from accidental ones? Do 
artificial intelligence and machine learning tools promise advancements 
in this area?
    10. Deployment of BGP Security Measures. The Commission seeks 
comment on the security measures that have been developed and deployed 
by industry to secure BGP. In addition to the measures recommended by 
CSRIC III and VI (RPKI, MANRS, and applicable IETF Best Common Practice 
standards), BGPsec, and the NIST practice guide, what other standards, 
specifications, or best practices have been developed to address 
potential attacks that exploit BGP vulnerabilities? The Commission 
seeks comment on the extent to which network operators have implemented 
any of the available BGP security measures developed by industry. How 
effective are these measures in practice? The Commission seeks comment 
on how to assess, measure, demonstrate, or increase the effectiveness 
of these security measures. To the extent that network operators have 
not implemented security measures, the Commission seeks comment on why 
such measures have not been implemented. To the extent that network 
operators have implemented security measures, how effective have they 
been at mitigating

[[Page 14009]]

the vulnerability? What obstacles have prevented them from doing so?
    11. The Commission seeks comment on the extent to which RPKI, as 
implemented by other regional internet registries, effectively prevents 
BGP hijacking. To what extent do network operators take advantage of 
the RPKI services that regional internet registries offer by 
implementing RPKI in their networks? To what extent, if any, do network 
operators' service level agreements affect the ability of network 
operators to drop traffic that RPKI deems invalid? How do regional 
internet registries maintain the certificate authority for the RPKIs in 
a way that mitigates the risk of a single point of failure vulnerable 
to distributed denial of service attacks? How do regional internet 
registries prevent conflicts among distributed RPKI trust anchors?
    12. The Commission seeks comment on whether and to what extent 
network operators anticipate integrating BGPsec-capable routers into 
their networks. The specification for the BGPsec extension to BGP 
became available in 2017, but it appears that BGPsec has not been 
widely deployed despite BGP's known vulnerabilities. Why have network 
operators not taken more aggressive steps to adopt BGPsec? What 
particular obstacles or concerns about BGPsec have slowed their 
adoption? To what extent does the introduction of BGPsec routers 
potentially introduce compatibility issues among managed networks or 
introduce delays?
    13. For network operators that currently participate in MANRS and 
comply with its requirements, including support for IETF Best Common 
Practice standards, the Commission seeks comment on the efficacy of 
such measures for preventing BGP hijacking. To what extent do the 
network operators that participate in MANRS support both its required 
and recommended routing security actions, as well as applicable IETF 
Best Common Practice standards on which those actions are based? To 
what extent do network operators participate in MANRS' various 
programs, including its equipment vendor program, launched in 2021, 
which aims to enable routing security features on network equipment and 
provide support and training guidance to use them, or take advantage of 
the MANRS Observatory.
    14. Commission's Role. Ensuring continued U.S. leadership requires 
that the Commission explores opportunities to spur trustworthy 
innovation for more secure communications and critical infrastructure. 
The Commission has sought to promote the security of U.S. networks and 
network equipment both by drawing attention to available resources and 
through exercise of its regulatory authority. Other federal agencies 
are engaged in cybersecurity and specifically BGP security, including 
NIST, the Department of Homeland Security, and the National 
Telecommunications and Information Administration. The Commission seeks 
comment on steps the Commission, in coordination with other federal 
agencies, could take to prevent BGP hijacking or otherwise promote 
secure internet routing. The Commission seeks comment on whether the 
Commission has a role in helping U.S. network operators deploy BGP 
security measures. If so, how can the Commission be most helpful? The 
Commission seeks comment on its authority to promote the security of 
internet routing through regulation, including as it may apply to 
wireless and wireline Internet Service Providers, Internet Exchange 
Providers, interconnected VoIP providers, operators of content delivery 
networks, cloud service providers, and other enterprise and 
organizational stakeholders. The Commission seeks comment on whether 
regulatory clarity could help network operators prioritize investments 
in the security of their networks.
    15. The Commission seeks comment on the extent to which other 
nations' telecommunications regulators and multistakeholder 
organizations have issued rules, guidance, or otherwise encouraged 
network operators, network security organizations, and equipment 
vendors to implement BGP security measures and on any lessons learned 
from those endeavors. The Commission seeks comment on the extent to 
which the effectiveness of BGP security measures may be related to 
international participation and coordination.
    16. Costs and Benefits. The Commission seek comments on the one-
time and ongoing costs of implementing the BGP security measures 
discussed herein. What capital and operational expenditures attend 
their implementation? Does the availability of a protocol for RPKI keep 
implementation costs low? Would network operators need to replace 
existing routers to support the BGPsec extension? Could support be 
enabled through a software upgrade, particularly for routers that are 
not considered to be ``end-of-life''? To what extent can network 
operators support MANRS' required and recommended actions by updating 
their policies and practices, and without equipment replacement or 
software updates? What costs would consumer likely experience from BGP 
security implementations, such as higher service costs or speed 
reductions?
    17. The Commission seeks comment on whether the Commission should 
encourage industry to prioritize the deployment of BGP security 
measures within the networks on which critical infrastructure and 
emergency services rely, as a means of helping industry to control 
costs otherwise associated with a network-wide deployment. Would this 
or another phased or gradual implementation of BGP security measures be 
effective and help network operators to plan for and control 
implementation costs?
    18. The Commission also seeks comment on the national security, 
economic, and public safety benefits of more secure internet routing, 
both within the U.S. and globally. What entities are particularly 
affected by threats to BGP security? To what extent would the security 
measures discussed herein be effective in mitigating BGP hijacking? 
What is the potential impact of mitigating BGP hijacking on U.S. 
national security and the U.S. economy? Have stakeholders attempted to 
quantify the benefits that secure internet routing could convey by 
protecting critical infrastructure, sensitive communications, and 
personally identifiable information? Have stakeholders attempted to 
quantify the benefits of secure internet routing in terms of the 
potential loss of Intellectual Property, communications delays, or 
disruptions that BGP's unmitigated vulnerability represents? Have 
stakeholders attempted to measure or quantify the extent to which BGP 
hijacking poses a threat to life and property by disrupting 9-1-1 calls 
carried by providers of interconnected VoIP service? What other 
benefits could potentially accrue from this inquiry?
    19. Digital Equity and Inclusion. Finally, the Commission, as part 
of its continuing effort to advance digital equity for all, including 
people of color, persons with disabilities, persons who live in rural 
or Tribal areas, and others who are or have been historically 
underserved, marginalized, or adversely affected by persistent poverty 
or inequality, invites comment on any equity-related considerations and 
benefits (if any) that may be associated with the proposals and issues 
discussed herein. Section 1 of the Communications Act of 1934 as 
amended provides that the FCC ``regulat[es] interstate and foreign 
commerce in communication by wire and radio so as to make [such 
service] available, so far as possible, to all the

[[Page 14010]]

people of the United States, without discrimination on the basis of 
race, color, religion, national origin, or sex.'' The term ``equity'' 
is used here consistent with Executive Order 13985 as the consistent 
and systematic fair, just, and impartial treatment of all individuals, 
including individuals who belong to underserved communities that have 
been denied such treatment, such as Black, Latino, and Indigenous and 
Native American persons, Asian Americans and Pacific Islanders and 
other persons of color; members of religious minorities; lesbian, gay, 
bisexual, transgender, and queer (LGBTQ+) persons; persons with 
disabilities; persons who live in rural areas; and persons otherwise 
adversely affected by persistent poverty or inequality. Specifically, 
the Commission seeks comment on how its proposals may promote or 
inhibit advances in diversity, equity, inclusion, and accessibility, as 
well the scope of the Commission's relevant legal authority.
    20. Authority for this Notice of Inquiry may be found in sections 
1, 4(i)-(j), 4(n), 7, and 403 of the Communications Act of 1934, as 
amended, 47 U.S.C. 151, 154(i)-(j), 154(n), 157 and Section 1.430 of 
the Commission's rules, 47 CFR 1.430.

Federal Communications Commission.
Marlene H. Dortch,
Secretary, Office of the Secretary.
[FR Doc. 2022-05121 Filed 3-10-22; 8:45 am]
BILLING CODE 6712-01-P


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