On 8 April 2022, the IAB responded to the FCC’s request for comments on Secure Internet Routing:

IAB Comments on A Notice by the Federal Communications Commission on
Secure Internet Routing, issued 03/11/2022

The Internet Architecture Board (IAB), which provides oversight for the
protocols and procedures used by the Internet and also handles the
liaison management for the Internet Engineering Task Force (IETF),
appreciates the opportunity to submit comments in response to the
Federal Communication Commission’s (FCC) Notice of Inquiry, “Secure
Internet Routing”. The IETF is the main engineering organization that
works on standards relating to Internet technology. The mission of the
IETF is to produce relevant technical documents that influence the way
people design, use, and manage the Internet (RFC 3935). The IETF is an
open, diverse, global community of developers consisting of network
operators, vendors, researchers and many other stakeholders.

The IETF originally developed the Internet protocol stack, including the
Internet routing system based on the Border Gateway Protocol (BGP), and
continues to be responsible for maintaining and evolving the technical
specifications that define the Internet and its protocols. We believe
the Internet’s success has resulted from its flexible, modular
architecture. BGP is the central protocol for providing global
connectivity across the world’s heterogeneous network domains to provide
end-to-end global connectivity. It is fundamental to the operation of
the Internet.

As in any protocol development, the adoption within the industry of new
capabilities will vary. In recent decades, with the increasing growth of
the Internet, occurrences of BGP-related operational issues have
increased. The existing BGP protocol stack is based on a design which
can be extended, building on existing network investments. The IETF
currently has two working groups dedicated to improving BGP interdomain
routing, called Inter-Domain Routing (IDR) and Global Routing Operations
(GROW). IDR is concerned with the correctness, robustness, and
scalability of BGP. GROW is concerned with the consideration of the
operational problems associated with global routing systems, including
measurement, policy, and security. The IETF will continue to evolve the
BGP protocol to meet the needs of new network structures and
applications, with a strong focus on security.

We believe in a continuous, modular, flexible evolution of the Internet
and its protocols based on operational experience and requirements,
where each service provider can determine their security needs based on
their diverse requirements and in partnership with other providers. The
success of future standardization efforts intended to increase routing
security, we believe, will be highly dependent on educating BGP users
about BGP operational issues and how well real-world deployment
experience can be fed back into the multistakeholder standards
development process, as opposed to a mandated top-down approach, which
would fail to meet the diverse needs of the global community.

The Federal Communications Commission can support the efforts of the
Internet community to deploy mechanisms to secure global routing by
supporting research and other work that help these communities to
understand issues, develop solutions where needed, and deploy security
technology more widely. The IAB believes that the IETF is an important
partner in these efforts.