I agree with Yaron that this document is not ready to be advanced. 

Aside from whether the document is appropriate for publication on the Standards 
Track (I believe that Informational would be a better choice), I'd suggest that 
the document has a more basic problem in that it doesn't do a very good job of 
defining the problem it is trying to solve or demonstrating that the solution 
offered actually solves that problem or can be practically
implemented. 

For example, early on the document makes the following statement: 
   This document defines and implements EAP channel bindings to solve
   the lying NAS and the lying provider problems, using a process in
   which the EAP peer provides information about the characteristics of
   the service provided by the authenticator to the AAA server protected
   within the EAP method.  This allows the server to verify the
   authenticator is providing information to the peer that is consistent
   with the information received from this authenticator as well as the
   information stored about this authenticator.  "AAA Payloads" defined
   in [I-D.clancy-emu-aaapay] proposes a mechanism to carry this
   information.

However, as noted in Section 3:

   In service provider networks, global knowledge is
   infeasible due to indirection via roaming.  When a peer is outside
   its home administrative domain, the goal is to ensure that the level
   of service received by the peer is consistent with the contractual
   agreement between the two service providers.

Unfortunately the term "level of service" is not well enough defined here to 
give a good sense of what is
possible and what is not.  As noted above, in general the home AAA server does 
not have 
enough information to independently verify AAA attributes provided to it by 
roaming partners.  The problem is not just lack of "global knowledge";  even if 
it were possible
for a home AAA server to have perfect global knowledge, if that knowledge were 
obtained from the
providers themselves (where else could it come from?) then if those providers 
were untrustworthy,
then how could it be used in channel binding verification?  

As a result, I'd suggest that some careful analysis is needed to describe in 
detail the threats that 
the "lying provider" solution really can mitigate.  As noted later:

      In other words, channel bindings enable the
      detection of inconsistencies in the information from a visited
      network, but cannot determine which entity is lying.  

Given that it is not really possible to determine whether a provider is 
actually lying or not, how
does the offered solution actually solve the "lying provider" problem? 

The service provider attacks described in Section 3, which attempt to make the 
case for the
utility of channel bindings are not very convincing: 

  a. Inappropriate billing.  In this scenario, it's not clear to me how Channel 
Bindings would be
     helpful  Today rates are not advertised in Beacons, and if accounting 
fraud is suspected,
     wouldn't this be best verified by computing the expected billed amounts 
against the actual
     ones, based on RADIUS accounting data?  

  b. Transmit power boost.  Detecting inappropriate levels of transmit power 
seems like something
     beyond the capability of channel bindings (and more in the jurisdiction of 
regulatory agencies
     like the FCC).  Even if the geolocation were to be transmitted along with 
the power measurement,
     detecting an inappropriate transmit power level would involve some fairly 
complex modeling with
     lots of variables (e.g. precise tower location, absorption along the line 
of sight, etc.). 

At a minimum, I'd suggest that the document needs to come up with some more 
plausible service provider
scenarios. 

















                                          
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