Dear Colleagues,

I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.

I would like to share key feedback in our community for prop-166, based
on a meeting we organized on 25th Aug to discuss these proposals.
This feedback is sent on my behalf, but please note that it is a
summary of the discussions among the 7 Japanese community members
who attended the meeting.

Many support opinions were expressed from the attendees about this proposal.


(comment details)
- It should not be delegated to organizations with sloppy operations.

- I would like to know the reason and justification for setting a
60-day grace period.

- While NIR is excluded in this proposal, is exclusion necessary?


Regards,

Satoru  Tsurumaki
JPOPF Steering Team

2025年7月31日(木) 15:23 Bertrand Cherrier via SIG-policy
<[email protected]>:

>
> Dear SIG members,
>
> A new proposal "prop-166-v001: Revocation of Persistently Non-functional RPKI 
> Certification Authorities"
> has been sent to the Policy SIG for review.
>
> It will be presented at the Open Policy Meeting (OPM) at APNIC 60 on 
> Thursday, 11 September 2025.
>
>     https://conference.apnic.net/60/program/program/index.html#/day/8/
>
> We invite you to review and comment on the proposal on the mailing list 
> before the OPM.
>
> The comment period on the mailing list before the OPM is an important part of 
> the Policy Development Process (PDP).
> We encourage you to express your views on the proposal:
>
>   - Do you support or oppose this proposal?
>   - Does this proposal solve a problem you are experiencing? If so,
>     tell the community about your situation.
>   - Do you see any disadvantages in this proposal?
>   - Is there anything in the proposal that is not clear?
>   - What changes could be made to this proposal to make it more effective?
>
> Information about this proposal is appended below as well as available at:
>
>     https://www.apnic.net/community/policy/proposals/prop-166/
>
> Regards,
> Bertrand, Shaila, and Ching-Heng
> APNIC Policy SIG Chairs
>
>
>
> ---------------------------------------------------------------------------------------
>
> prop-166-v001: Revocation of Persistently Non-functional RPKI Certification 
> Authorities
>
> ---------------------------------------------------------------------------------------
>
>
> Proposer: Job Snijders ([email protected])
>
>
> 1. Problem statement
> --------------------
>
> APNIC offers users of its RPKI certification service two deployment
> models: "routing management via MyAPNIC" and "Delegated RPKI". In the 
> "MyAPNIC"
> setup, APNIC is responsible for timely issuance and publication of new RPKI
> Manifests and CRLs, but in the "Delegated RPKI" setup resource holders
> themselves manage their CA and issuance schedule.
>
> It is technically possible for Delegated RPKI CA infrastructure to be
> offline or otherwise non-functional for extended periods of time, or for the
> contents of publication repositories to become stale or otherwise invalid.
>
> A one-time Delegated RPKI CA misconfiguration can result in validators
> collectively attempting hundreds of thousands of synchronization attempts, as
> there currently is no 'liveliness' requirement for Delegated RPKI CAs.
>
> This proposal suggests providing a mandate to APNIC to revoke RPKI
> resource certificates associated with longtime non-functional CAs to reduce
> Relying Party workload.
>
> Persistently Non-functional Delegated CAs have subtle adverse effects within
> the RPKI ecosystem which may become more pronounced over time.
>
>
> 2. Objective of policy change
> -----------------------------
>
> The objective of this proposal is to reduce futile workloads for RPKI
> Validator instances, given that attempts to fetch & validate data from
> non-functional CAs is a waste of resources.
>
>
> 3. Situation in other regions
> -----------------------------
>
> A similar proposal exists in the RIPE region:
>
> https://www.ripe.net/community/policies/proposals/2025-02/
>
>
> 4. Proposed policy solution
> ---------------------------
>
> If APNIC is unable to discover and validate a Delegated RPKI
> Certification Authority's (CA's) current Manifest and Certification Revocation
> List (CRL) for more than two (2) months, that Delegated CA's resource
> certificate should be revoked by APNIC.
>
> APNIC should make reasonable efforts to discover new Manifests, to
> notify the Delegated CA operator if a current Manifest and CRL cannot be
> validated, and to notify the operator if the delegation is revoked.
>
> This policy proposal does NOT target National Internet Registry (NIR)
> RPKI CAs, the proposal only targets pathologically non-functional CAs that are
> not NIRs.
>
>
> 5. Advantages / Disadvantages
> -----------------------------
>
> Advantages
>
> - Non-functional CAs offer nothing of value to validators (RPKI Signed 
> Payloads
>   are not available without a current and valid Manifest).
>
> - RPKI Cache Validator synchronisation becomes more economic with fewer
>   purposeless publication points to traverse.
>
> - Non-functional CAs besmirch RPKI validator syslog message archives and waste
>   CPU cycles and network traffic.
>
> - Revocation is only a minor inconvenience for non-functional CAs (given that
>   the configuration already was broken for an extensive period of time), but a
>   big deal for any Relying Party (RP) - especially when taking into account 
> the
>   many synchronisation attempts made over long periods of time.
>
> - This policy doesn't affect many resource holders; there only is a small 
> group
>   of persistently non-functional CAs, some of which have been non-functional
>   for more than 2 years already.
>
>
> Disadvantages
>
> - Resource holders might require more than 2 months to complete the
>   initial Delegated CA setup.
>
>   [[[ Counterpoint to the above: initial setup procedures usually only takes
>       a few minutes. Resource holders of course are free to simply retry the
>       delegated CA setup procedure following revocation. The goal of this
>       policy is NOT to permanently bar resource holders from setting up
>       Delegated CAs, but to curb persistently non-functional delegations.
>       E.g., "please retry Delegated CA enrollment when you are ready". ]]]
>
>
> 6. Impact on APNIC
> ------------------
>
> APNIC will need to set up a process to detect and revoke non-functional
> CAs. Industry standard open-source tooling already is available for this task.
>
> 7. References
> -------------
>
> An overview of non-functional RPKI CAs is available here: 
> https://console.rpki-client.org/nonfunc.html
>
> The rpki-client software package can detect and report non-functional CAs: 
> https://www.rpki-client.org/
> _______________________________________________
> SIG-policy - https://mailman.apnic.net/[email protected]/
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--
--
Satoru Tsurumaki
BBIX, Inc
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