Re: [Modern] Fwd: [new-work] WG Review: Managing, Ordering, Distributing, Exposing, & Registering telephone Numbers (modern)

["Richard Hill" <[e-mail]>]

Dear Jon,


Thank you for this and please see inline comments below.


Thanks and best,

Richard

 

From: Peterson, Jon [mailto:[e-mail]] 
Sent: Friday, June 26, 2015 19:43
To: Richard Hill; McGarry, Tom; [e-mail]
Subject: Re: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

 

The entire point of my raising the DNS analogy was indeed that the IETF only
creates the tools, not the policies, and that we're not proposing to do
anything else here in MODERN. We know the IETF doesn't determine numbering
policy. No one is confused about that (well, no one advocating for MODERN,
anyway). Furthermore, the overwhelming majority of the protocol decisions
that the IETF makes about the DNS aren't really matters of policy. They are
matters like choosing between two proposed ways that a particular bit-field
might be filled to enable a new application. 

 

>RH: Again, I'm not convinced that this applies to telephone numbers. I
still don't see how the things you wish to develop would not be related to
regulatory policies.

 

The application in question may not ultimately apply everywhere that the DNS
is used, and nor do we always know in advance if the application will ever
have any real impact on the world. But this is what the IETF does and where
its expertise lies.

 

>RH: For sure the IETF has expertise regarding the DNS. But I didn't realize
that it had expertise regarding telephone numbers.

 

Ultimately, it's why the IETF is the right place to do work like this,
because the proposed MODERN work is that sort of low-level protocol work. 

 

>RH: Again, I not convinced that is the case: the things that you want to do
are not, in my view, low-level protocol work and I don't think that the IETF
has lots of people who are experts in telephone numbers.  Neustar is a
member of ITU-T. What's the disadvantage to you of doing the work there,
where you could benefit from the inputs of other folks who have expertise in
telephone numbers?

 

We understand how to create protocols like this, how to encode them, how to
secure them, and we have some interested vendors willing to work on
implementation. 

 

>RH: It would be good to hear from the other interested vendors.

 

The MODERN work is not being designed exclusively with US interests in mind,

 

>RH: It would be good to hear from any of the non-US folks who would be
interested in this work.

 

but like all IETF work, it will be determined by our consensus process,

 

>RH: I look forward to finding out whether there is rough consensus to
create this working group.

 

forged from the coalition of the willing who want to do this work - we
certainly welcome non-US involvement.

 

>RH: As I said before, you are more likely to get that if you do the work in
ITU-T, or at least formally inform them of what you are doing and liaise
with them.

 

You will find the IETF and ITU-T collaboration guidelines at:

 

  http://www.itu.int/rec/T-REC-A.Sup3-201207-I 

 

That document has been approved by both entities.  I cite some portions
here:

 

"Early identification of topics of mutual interest will allow for
constructive efforts between the two organizations based on mutual respect."


 

"An IETF working group should also evaluate and identify areas of
relationship with the ITU-T and document the collaboration with the ITU-T
study group in its charter." 

 

"During the course of ITU-T and IETF collaboration, it is important to share
working drafts and documents among the technical working groups." 

 

"It is envisaged that the processes of clauses 2.5.1 and 2.5.2 will often be
used simultaneously by both an IETF working group and an ITU-T study group
to collaborate on a topic of mutual interest." 

 

Our mailing lists and process are open (see OpenStand).

 

>RH: Yes, but they are English-only.

 

Jon Peterson

Neustar, Inc.

 

From: Richard Hill <[e-mail]>
Date: Friday, June 26, 2015 at 10:15 AM
To: Jon Peterson <[e-mail]>, "McGarry, Tom"
<[e-mail]>, "[e-mail]" <[e-mail]>
Subject: RE: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

Dear Jon,

 

Thank you for the thoughtful reply.

 

Please see embedded comments below.


Thanks and best,

Richard

 

From: Peterson, Jon [mailto:[e-mail]] 
Sent: Friday, June 26, 2015 18:35
To: Richard Hill; McGarry, Tom; [e-mail]
Subject: Re: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

 

Your arguments here could equally well be applied to any important resource
on which the IETF does protocol work - like, say, the DNS. The IETF manages
the DNS protocol and publishes RFCs about it. But since national authorities
are responsible for ccTLDs,

 

>RH: The degree of involvement of national authorities with ccTLDs varies
greatly, but I'm not aware of any that regulate ccTLDs to the same extent
that telephone numbers are regulated. Further, the protocols and policies
for the DNS were mostly developed before anybody thought that there should
be any government involvement. And today ICANN develops most of the
policies, even if the IETF is developing the protocols. So it is not an
appropriate analogy.

 

surely the IETF is not a suitable body for managing the DNS!

 

>RH: The IETF does not manage the DNS. ICANN manages the DNS, to the extent
that it requires top level management.

 

And it isn't. But it is a suitable body for managing the protocol work on
the DNS. Other, effectively unrelated entities handle the administrative
dimensions of operating the DNS, and yes, at those bodies there are lots of
national regulators and they worry about the sorts of things you are
worrying about here. The IETF just produces tools, and that is all MODERN
proposes to do. Trying to characterize this effort otherwise is simply an
error.

 

>RH: I'm not convinced that you can develop tools that don't affect
policies.  Indeed, it seems to me that the policies will condition whether
certain tools are useable or not.

 

All work at the IETF is done by a coalition of the willing. If it turns out
that the coalition is not representative of the needs of the community, then
what happens? Well, the work built here doesn't get used. The only people
who wasted any time or effort were the members of that coalition. No
national interests can possibly be harmed by that, even if the failed work
involved ways of talking about telephone numbers.

 

>RH: That is true if nobody uses the work. It is not true if some country,
say the US, adopts the outputs and then lobbies to have them adopted
elsewhere.  That can lead to serious friction and pushback. Better to
involve all concerned parties early in the game.

 

This makes the IETF really different from places like the ITU, where the
products of work have some binding effect on the world.

 

>RH> ITU-T Recommendations are no more (or less) binding that IETF RFCs or
ISO Standards.

 

Virtually all proposed work at the IETF also faces a coalition of the
unwilling. People who aren't interested, or who think the work should be
done elsewhere, or that the work simply shouldn't be done at all. But I
maintain your "formal objection" treats the scope of the proposed work as
being different than it is, and I'd agree that if this proposed work
required regulatory oversight, that the IETF shouldn't do it.

 

>RH: I see that we agree on the principles but not the details. I don't see
how the proposed work would not have regulatory impacts in at least some
(probably many) countries, even if it has no impact in the US. Again, if the
idea is to develop tools that would first be used in the US, then the work
should be done in a US-only body. If the idea is to develop tools that would
be used in many countries, then I think that the ITU-T is a more suitable
forum. 

 

But we're just building some protocol tools. There is also related work here
for ATIS to do, and I'm sure ATIS or some other body could later take some
the protocol tools developed in the IETF and conduct an experiment with
various carriers to see if it works for that interest group or not, and that
would be interesting information. But the IETF doesn't do that part, and
doesn't aspire to do that part.

 

>RH: I still don't understand why you think that IETF is uniquely well
positioned to do this work. Surely nobody would suggest that the IETF should
develop standards for nuts and bolts, when ISO is doing that. So why should
the IETF develop standards (or tools) for telephone numbers when the ITU-T
is doing that?

 

Finally, I'm not really sure how much I would expect "national regulators"
to literally use the tools proposed in this work. They are tools for the use
of a diverse industry of enterprises, carriers, end users, and so on. Many
use cases under consideration would not have a national regulator as an
actor. This work was in part instigated by an FCC workshop, yes, and someone
associated with the FCC spoke at the MODERN BoF. But I don't anticipate that
the FCC would be propping up servers to deploy this work - surely they would
leave that to industry. 

 

>RH: That may well be true for the US, but it may well not be true in other
countries. Which is why I think that the work is better done in a forum
where you are more likely to get inputs from national regulators. If the
inputs are of the form "go ahead, we don't care", then that is fine. But if
you do the work in the IETF, you are not likely to get inputs from national
regulators.

 

Jon Peterson

Neustar, Inc.

 

From: Richard Hill <[e-mail]>
Date: Friday, June 26, 2015 at 8:09 AM
To: "McGarry, Tom" <[e-mail]>, "[e-mail]"
<[e-mail]>
Subject: Re: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

Thank you for this clarification.

 

Since the intent is to create tools and solutions that would be used by
national regulators, presumably they should be involved in the development
of the tools.  


As far as I know, national regulators from most countries don't normally
participate in the IETF, for a number of reasons, including the IETF's
decision-making process and the fact that the IETF works in English.
National regulators do participate in ITU-T, for a number of reasons,
including the ITU's decision-making process and the fact that documents are
translated into the six UN languages before they are formally approved (and
some discussions takes place with interpretation in six languages).

 

If the intent is to develop tools that would be used only in the USA at
first, then I would suggest that it would be more appropriate to develop
them in a forum such as ATIS or an ad-hoc group created specifically for the
purpose. If the US experience proved successful, then the tools could be
proposed for adoption elsewhere, for example through ITU-T.

 

If the intent is to develop tools for use in many countries right at the
start, then I would suggest that the appropriate forum would be ITU-T, not
IETF, for the reasons outlined above.

 

Thus, I formally object to the creation of this new working group, and this
even if the Charter is modified as suggested below.

 

Please see additional comments inline.

 

Thanks and best,

Richard

 

From: Modern [mailto:[e-mail]] On Behalf Of McGarry, Tom
Sent: vendredi, 26. juin 2015 00:31
To: [e-mail]
Subject: Re: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

 

This effort is intended to create tools and solutions to enable flexibility
in the process of managing numbers among national administrators, service
and application providers, and consumers.  Entities can choose to use these
tools or not.  These tools are not for the ITU-T's processes or role, nor
for how national administrators interact with the ITU-T.  But of course we
want your input and feedback, so thanks for sending this along.  More
comments in line below.  

 

 

From: Alissa Cooper <[e-mail]>
Date: Thursday, June 25, 2015 7:44 AM
To: Modern List <[e-mail]>
Subject: [Modern] Fwd: [new-work] WG Review: Managing, Ordering,
Distributing, Exposing, & Registering telephone Numbers (modern)

 

Would appreciate people's thoughts on whether any charter edits may be
warranted in response to these comments, and/or whether a separate response
may be useful for addressing some of the questions below. 

 

Alissa

 

Begin forwarded message:







From: "Zhang, Jie" <[e-mail]>

Subject: RE: [new-work] WG Review: Managing, Ordering, Distributing,
Exposing, & Registering telephone Numbers (modern)

Date: June 23, 2015 at 1:56:42 PM GMT-3

To: "[e-mail]" <[e-mail]>

Cc: "Jamoussi, Bilel" <[e-mail]>

Dear Sir/Madam,

Below please find comments from the ITU Telecommunication Standardization
Bureau on the proposed IETF working group MODERN.

1. Potential impacts on Recommendation ITU-T E.164 and E.164.1 
It is stated at the beginning of the Charter that the MODERN working group
will define a set of Internet-based mechanisms for the purposes of managing
and resolving telephone numbers (TNs) in an IP environment. And it is
mentioned that TNs are defined in RFC 3966 "The tel URI for Telephone
Numbers". Does that mean the mechanism being referred to here only deals
with Tel URI? Would there be any impact on Recommendation ITU-E E.164 and
E.164.1 which are core recommendations on Telephone Numbers?

There will be no impacts on E.164 and E.164.1.

 

>RH: Given the scope of the work, I think that it is too early to say
whether there would be an impact. Those Recommendations are regularly
updated, in particular E.164.1, so there is nothing wrong with envisaging
changes, with the recognition of course that the changes would have to be
proposed to ITI-T Study Group 2 and agreed by that group.


2. Entities participating in the defined mechanisms
The Charter states that the protocol mechanism for resolving TNs will allow
entities such as service providers, devices, and applications to access data
related to TNs. But it is not clear what kind of entities can participate in
the mechanisms defined by this MODERN working group. Would it be restricted
to the entities who have been assigned a TN or a block of TNS?

Who participates in numbering processes within countries is subject to
regulation.  The WG cannot make any decisions with regard to this.  I expect
the WG to define "roles" within the number management processes; e.g.,
administrator, telecom carrier, application provider, consumer, etc.; and
how those roles could interact with each other.  This will be a baseline for
what tools and solutions would be useful to facilitate those interactions.  

 

>RH: Even that might be subject to, or affect, national regulations.  That
is, the definition of a "role" may well depend on national regulations.


3. Status of Telephone numbers in the defined mechanisms
Several operations related to TNs are mentioned in the Charter, including
requesting, acquiring, resolving and associating. It is also stated that the
protocol mechanism for acquiring TNs will provide an enrollment process for
the entities that use and manage TNs. Does that mean Telephone numbers with
various status, such as assigned, spare and reclaimed numbers will all be
managed in the mechanisms defined by the MODERN working group?

I would expect proposed solutions to be able to address the status of a
telephone number.

 

>RH: Since the terms "assigned", "spare" and "reclaimed" are defined in
ITU-T Recommendations (albeit sometimes implicitly), addressing the status
of a telephone number might well impact E.164 or E.164.1.


4. Regulatory issues
The Charter states that Solutions and mechanisms created by the working
group will be flexible enough to accommodate different policies for TN
assignment and management, for example those established by different
regulatory agencies. We would like to bring your attention to the fact that
the E.164 international public telecommunication numbering plan is a
politically significant numbering resource with direct implications on
national sovereignty. ITU Plenipotentiary Conference Resolution 133 (Rev.
BUSAN, 2014) recognized "the existing role and sovereignty of ITU Member
States with respect to allocation and management of their country code
numbering resources as enshrined in Recommendation ITU-T E.164", and further
instructed the ITU Secretary-General and the Directors of three Bureaux
(Telecommunication Standardization, Development, and Radiocommunication) to
"take any necessary action to ensure the sovereignty of ITU Member States
with regard to Recommendation ITU-T E.164 numbering plans whatever the
application in which they are used".

We are aware of Resolution 133 and will certainly respect it.  I would
propose adding the following text after the first sentence in the last full
paragraph - "The group acknowledges ITU Plenipotentiary Conference
Resolution 133 which recognizes the existing role and sovereignty of ITU
Member States with respect to allocation and management of their country
code numbering resources as enshrined in Recommendation ITU-T E.164."  

 

>RH: That certainly would be a helpful addition. In addition to the above, I
would suggest adding "The group's outputs would be consistent with the
provisions of relevant ITU-T Recommendations, in particular E.164, E.164.1,
E.190 and the Recommendations referenced therein."  

 

>RH: For the sake of clarity I reiterate that I oppose the creation of this
group even if the Charter is modified to include the text above.

 


5. Relationship with .Tel
DNS-based use of international numbering resources has been discussed in
ITU-T Study Group 2 (SG2) since its meeting of 17-26 September 2013. TSB
Director has also exchanged letters with ICANN on issues related to
registering digit strings in the .TEL domain. A representative from ICANN
participated in the ITU-T SG2 meeting (28 May - June 2014) and provided some
background on the TELNIC application. A correspondence group under ITU-T SG2
was also set up in this regard. We would like to know how the work of this
new WG would relate to issues related to registering digit strings in the
.TEL domain and other DNS-based use of telephone numbers.

The WG will not create any new namespace that would require regulatory
oversight, e.g., a new TLD, SLD, etc.  I wouldn't rule out the WG leveraging
existing namespaces as part of proposed solutions.  But it's too early to
say anything specific about that.  There is nothing in the charter that
references .tel.  


6. Relationship with related existing or concluded WGs
It is stated in the Charter that the working group will take into
consideration existing IETF work including STIR, ENUM, SPEERMINT, DRINKS and
SCIM. Detailed description of the relationship between this new WG and the
above mentioned other existing or concluded WGs would be appreciated.

I agree.  I would modify that sentence to add the following at the end - "as
well as other relevant industry and standards organizations."


7. The name of this new WG
The name of this new WG is "Managing, Ordering, Distributing, Exposing, &
Registering telephone Numbers (modern)". But in the Charter, ordering,
exposing and registering TNs are not mentioned, which seems to be a little
bit inconsistent.

The IETF often has fun with creating WG names.  : )  But the charter is
where to look for the scope of work.  The charter uses the following phrases
"distribution, acquisition and management of TNs", "functions involved in
associating information . with TNs", "associating, acquiring and resolving
TNs", "access data related to TNs", and "mechanisms for resolving
information related to TNs".  The functions you believe were left out of the
charter will be part of one or more of these processes.  



Best regards,

Jie Zhang
Advisor, ITU-T SG2
International Telecommunication Union
Place des Nations
CH-1211 Geneva , Switzerland 
Tel :[phone]
[e-mail]
www.itu.int
www.itu150.org


-----Original Message-----
From: new-work [mailto:[e-mail]] On Behalf Of The IESG
Sent: Friday, June 12, 2015 8:47 PM
To: [e-mail]
Subject: [new-work] WG Review: Managing, Ordering, Distributing, Exposing, &
Registering telephone Numbers (modern)

A new IETF working group has been proposed in the Applications and Real-Time
Area. The IESG has not made any determination yet. The following draft
charter was submitted, and is provided for informational purposes only.
Please send your comments to the IESG mailing list (iesg at ietf.org) by
2015-06-22.

Managing, Ordering, Distributing, Exposing, & Registering telephone Numbers
(modern)
------------------------------------------------
Current Status: Proposed WG

Chairs:
 Tom McGarry <[e-mail]>
 Steve Donovan <[e-mail]>

Assigned Area Director:
 Alissa Cooper <[e-mail]>

Mailing list
 Address: [e-mail]
 To Subscribe: https://www.ietf.org/mailman/listinfo/modern
 Archive: http://www.ietf.org/mail-archive/web/modern/

Charter:

The MODERN working group will define a set of Internet-based mechanisms for
the purposes of managing and resolving telephone numbers (TNs) in an IP
environment. Devices, applications, and network tools increasingly need to
manage TNs, including requesting and acquiring TN delegations from
authorities. The output of the working group should make distribution,
acquisition, and management of TNs simpler for all entities involved.

The working group will define an information management framework for the
roles and functions involved in associating information with one or more TNs
in an IP environment.  The working group will also identify protocol
mechanisms to support the interactions between the functions defined by the
framework. This includes either recommending or defining protocol mechanisms
for acquiring, associating and resolving TNs, with a preference for use of
existing protocol mechanisms. TNs may either be managed in a hierarchical
tree, or in a distributed registry. The protocol mechanism for acquiring TNs
will provide an enrollment process for the entities that use and manage TNs.


The protocol mechanism for resolving TNs will allow entities such as service
providers, devices, and applications to access data related to TNs.
Maintaining reliability, real-time application performance, and security and
privacy for both the data and the protocol interactions are primary
considerations. The working group will take into consideration existing IETF
work including STIR, ENUM, SPEERMINT, DRINKS and SCIM.

The work of this group will focus on TNs, as defined in RFC3966, and blocks
of TNs, that are used to initiate communication with another user of a
service. There is an expectation that aspects of the architecture and
protocols defined by the working group will be reusable for other
user-focused identifiers. Any such extensions or reuse of MODERN mechanisms
are out of scope for the MODERN working group. Solutions and mechanisms
created by the working group will be flexible enough to accommodate
different policies for TN assignment and management, for example those
established by different regulatory agencies.

The working group will deliver the following:

- An architecture overview, including high level requirements and
security/privacy considerations

- A description of the enrollment processes for existing and new TNs
including any modifications to metadata related to those TNs

- A description of protocol mechanisms for accessing contact information
associated with enrollments

- A description of mechanisms for resolving information related to TNs

Milestones:

TBD

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