Numerous parties argued in comments recently filed with the National Telecommunications and Information Administration that the U.S. government should focus at the upcoming 2020 World Telecommunication Standardization Assembly (WTSA-2020) in Hyderabad, India, on ensuring the International Telecommunication Union’s Standardization Sector (ITU-T) does not stray from standard-setting into regulatory policy matters.
In addition to generally arguing in favor of ITU efforts that will encourage open markets, several commenters argued against the ITU-T moving forward to consider the development of a “new IP” (Internet protocol).
WTSA-2020 will set the ITU-T for the next four years and will select the leadership of the ITU-T study groups.
App develop association ACT told NTIA the U.S. government should “take all practicable steps” to ensure the ITU reduces trade barriers that “exclude goods and services from foreign markets and seek to artificially stimulate domestic industries.”
In particular, ACT encouraged NTIA to make enhancing engagement with small businesses a “specific priority,” including fostering the ability of small businesses in the digital economy to engage with the U.S. government on ITU-T issues.
ACT said NTIA should ensure the ITU-T holds to its mandate of developing and coordinating voluntary international standards for international telecommunications.
“The ITU-T has unfortunately exceeded this mandate repeatedly, launching efforts areas including data privacy, cybersecurity, artificial intelligence (AI) and other [Internet of Things] IoT use cases (e.g., financial),” ACT said.
The U.S. government should also prioritize avoiding ITU-T duplication of existing standardization efforts, such as developing a new IP, ACT said.
In addition, the group said, restructuring ITU-T working groups could be “an opportunity to enhance transparency and participation in ITU-T processes.”
The American Registry for Internet Numbers (ARIN) said NTIA should push for any standards making efforts of the ITU-T to be “well-coordinated” with other standard development organizations (SDOs).
“ARIN urges caution in that there is significant risk from uncoordinated efforts in this area,” the group said. “ARIN’s role as an RIR [Regional Internet Registry] is predicated on Internet Protocol specifications which are unambiguous, interoperable, and widely supported.”
The Center for Democracy and Technology (CDT) and Mozilla submitted joint comments saying the U.S. delegation to the assembly should “advocate for open and interoperable standards in the public interest in ways that are inclusive and transparent. We also believe that the U.S. delegation should argue against the need for a new, top-down standards architecture for the Internet.”
The proposal for a new IP “attempts to disrupt the egalitarian, multi-stakeholder, and resilient model of maintaining core internet technologies in diverse Standards Developing Organizations,” CDT and Mozilla said. “New IP focuses on a multilateral approach that is far more rigid and fundamentally incompatible with the open nature of the Internet, replacing it instead with a new 'top-down' Internet architecture.”
CenturyLink, Inc., said NTIA should work to “constrain” ITU-T's scope of work, which has “expanded in recent years into areas outside its expertise and mandate, and certain Member States and Sector Members seek to expand that scope even further, including emerging technologies. Such mission creep is neither in the interest of the U.S. nor the Internet ecosystem.”
NTIA should also work to ensure ITU-T does not duplicate the work of other SDOs and support internationally recognized SDOs, CenturyLink said.
The company was also among those that opposed efforts to create a new IP, saying it would be “both unnecessary and counterproductive.”
The Computer and Communications Industry Association (CCIA) said there is a “concerning trend” of the ITU-T’s pursuing standards that are “outside its mandate,” which duplicates work being done elsewhere.
“Duplication can lead to fragmentation of the Internet and hinder further development of new technologies,” the group said. “The U.S. should discourage the ITU-T from venturing beyond the development of technical standards applicable to its core mission.”
The Computing Technology Industry Association (CompTIA) urged NTIA to “oppose any proposal that would involve the ITU-T with changes to the fundamental technical protocols upon which the Internet is currently based.”
Proposals for a new IP “are unnecessary, would harm innovation, and would potentially enable nations to more easily restrict the ability of their citizens to freely access the Internet,” the group said. "The changes are outside of the ITU-T remit, and the evolution of the IP protocol should continue in open, industry-led standards development organizations … such as the Internet Engineering Task Force [IETF]."
CompTIA suggested the “better approach” is to “use existing tools to continue to move the Internet forward to address new use cases.”
The U.S. government should also not try to involve the ITU-T in any efforts related to 5G supply chain security, “since it would require involving ITU-T in issues with geopolitical implications and because such issues are better addressed through other national and multinational mechanisms.”
The Consumer Technology Association (CTA) said the U.S. government “should be vigilant to keep the ITU-T from taking any action, inadvertent or otherwise, that would disrupt the present successful voluntary standards environment.”
The group also argued in favor of “government actors" allowing the private sector to “take the lead on standards development, relying on consensus-based standards, not top-down regulatory frameworks, to ensure interoperability, reliability, and security.”
CTA said the ITU-T should not “duplicate, replace, or interfere with existing efforts, particularly with respect to issues outside the ITU’s core mission,” such as 5G security or supply chain security issues.
Hughes Network Systems LLC said it has concerns the ITU-T could become “involved in areas that should be market-driven and are being handled by other standard bodies with increased expertise.”
Hughes also said it is wary the ITU-T is “veering into regulatory policy” and that NTIA should use the WTSA-2020 event as a time to “refocus” the ITU-T on “areas more properly within its mandate.”
The company contended that a “more purpose-driven ITU-T would enable more targeted and effective participation by industry in ITU-T meetings. Areas like IoT, quantum communications, and other emerging technology areas are outside the remit of the ITU-T and are not a sound use of scarce ITU-T, Member States, or sector member resources.”
NTIA should also “promote increased U.S. leadership within the ITU-T,” Hughes said.
IBM Corp. said the ITU-T should focus on security and resiliency of time synchronization networks.
“Inaccurate time on systems can lead to a variety of issues for enterprises,” the company said. “These can include disruption of cryptographic applications, loss of data, adverse impact on troubleshooting and forensic efforts, reduced efficiency and safety in control systems, and failure to meet service level agreements and regulatory requirements for certain industries such as banking/finance.”
IBM also expressed concerns the ITU-T has expanded its portfolio beyond standard-setting to include regulatory policy.
In addition, NTIA should press for improvements in ITU-T processes and procedures, increased U.S. “presence and influence” in the ITU-T, and “explore further coordination and collaboration with other industry-led standards development organizations.”
Information Technology Industry Council (ITI) also said NTIA should advocate for consolidating ITU-T study groups and ensuring ITU-T does not go beyond the scope of its purpose by delving into Internet policy matters.
In addition, the group said, “There are many other established SDOs that are better positioned than ITU-T to develop standards in areas outside of telecommunications, especially for [information and communication technology] areas and emerging technologies such as AI, IoT, and quantum computing. ITI and our companies urge ITU-T to avoid initiating work with goals that duplicate or substantially overlap with work underway or planned in other SDOs that already have a track record of success in developing timely, high-quality, and market-relevant standards.”
Intel Corp. said that the “ITU-T should commit to focus on standardization work in its area of core competency (core broadband networks, connectivity, numbering, etc.) and should not initiate technical work and policy activity in new emerging areas, especially when those areas are already covered by other organizations.”
The Internet Corporation for Assigned Names and Numbers (ICANN) suggested ITU-T should focus on telecommunications standards and that Internet standards “should be developed within organizations that have the relevant mandate and expertise, including the [IETF], and should not be pursued within organizations such as the ITU-T, that have neither the expertise, the mandate, or relevant stakeholder participation.”
The Internet Governance Coalition (IGC) said it supports NTIA’s pursuit of a “multi-stakeholder” approach to Internet policy and ensuring interoperable communications with “minimal” barriers to exchange of information and services.
“We encourage the United States to continue to advance a forward-looking agenda at the WTSA that enables the development of new technologies and the expansion of global connectivity,” the group said. “This objective is essential to fostering United States industry leadership in the current environment that is increasingly geo-politically driven, competitive, and interdependent. … Importantly, at the WTSA, the United States should make clear to other governments and participants the great economic and social cost arising from policies that constrain the demonstrable benefits of an open and transparent digital economy.”
Juniper Networks, Inc., also cautioned against a new IP proposal, saying it would create a “top-down approach” to how the Internet is structured and governed, and would be a “significant departure from its current, independent, and free-of-government structure.”
Space Exploration Technologies Corp. (SpaceX) suggested NTIA work to ensure the ITU-T's “emphasis remains on technical and standardization matters consistent with its mandate and expertise” and that NTIA “recognize the value next-generation satellite broadband systems can bring for consumers by ensuring their interests are protected at the ITU-T.”
The ITU-T's processes and procedures should focus on standards and not policy, the company said.
“[W]hile the ITU-T is well suited to developing and supporting technical standards, its processes are not designed to achieve the same consensus-driven results required for policy and regulatory issues,” SpaceX said.
The Telecommunications Industry Association (TIA) joined those who advocated against the New IP proposal, saying it is “duplicative of existing efforts, harmful to industry, and contrary to the interests of the United States.”
The proposal would create “practical and technical challenges” brought on by amending current Internet protocols with non-interoperable protocols, TIA said.
“By introducing a separate and monolithic top-down architecture for the internet, the New IP proposal would be significantly disruptive,” the group said. “Everything from existing network operations to software, applications, and even the commerce enabled by existing TCP/IP would be impacted.”
The U.S. Chamber of Commerce said NTIA should use the assembly to “ensure that the ITU does not expand its jurisdiction and remains focused on its existing mandate and core competencies.”
The ITU is not the proper venue for advancing technical standards for emerging technologies, such as 5G and AI, the Chamber of Commerce said.
“It is critical to recognize the role of industry consortia, and other standards development organizations in the promotion of private-sector leadership on technical standards,” the group said. “Private sector leadership ensures that technical standardization issues are rooted in global, industry-driven standards and practices.”
The U.S. Council for International Business also was critical of the ITU-T for expanding its work into areas that it does “not believe the ITU has the expertise or mandate” and urged NTIA to ensure “the ITU-T’s structure and work program remain firmly rooted in its technical telecommunications/ICT standardization core competency.”
Among other things, NTIA should resist efforts for the ITU-T to duplicate work being doing by other bodies, such as those addressing the 5G supply chain. —Jeff Williams
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