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Waiver Request for P802.11aq Coordination Comments

Request from P802.11aq BRC to waive IEEE RAC mandatory coordination comments for the draft standard due to possible utility impediments. Summary includes specific MCCs and BRC response commentary.

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Waiver Request for P802.11aq Coordination Comments

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  1. P802.11aq Waiver request regarding IEEE RAC comments Date: 2018-01-18 Authors: Stephen McCann, BlackBerry

  2. Abstract Waiver request for unsatisfied mandatory coordination comments received from the IEEE RAC during the P802.11aq sponsor ballot Stephen McCann, BlackBerry

  3. From the IEEE-SA Sponsor Ballot operations manual: (Dec 2016) 5.4.4 Mandatory coordination … Comments from these entities shall be given appropriate consideration and response. At the time of project submittal to the IEEE-SA Standards Board for consideration for approval, the Sponsor shall supply the most recent coordination comments and indicate either acceptance** or a request for a waiver (see 4.2.3.2). ** Note – “acceptance” also includes “acceptance in principle” (Chair opinion) 4.2.3.2 Review of draft standards … Coordination. Mandatory coordination comments shall be addressed. If the Sponsor believes that satisfying specific mandatory coordination comments will impede the utility of the draft standard, appropriate documentation of this position shall be presented to RevCom. Stephen McCann, BlackBerry

  4. The P802.11aq ballot resolution committee (BRC) requests the IEEE 802 Executive Committee to approve a waiver from satisfying the mandatory coordination comments (MCCs) from the IEEE RAC. The P802.11aq BRC has concluded that satisfying the MCCs received from the IEEE RAC will impede the utility of the P802.11aq amendment**. ** IEEE-SA Standards Board Operations Manual: (Dec 2016) section 4.2.3.2 Stephen McCann, BlackBerry

  5. Technical Summary • The P802.11aq BRC’s objection to making the changes requested by the IEEE RAC is based upon these fundamental observations: • Observation 1: The pre-association operations defined in this amendment using a randomized MAC address are terminated in the access point (AP), meaning that none of them appear on the infrastructure LAN. • Observation 2: Other operations using a randomized MAC address that would attempt to create state with a managed network are either rejected at the AP or subject to prior configuration in the device. • Current protocols in use by wireless devices that achieve this configuration: Hotspot 2.0, ActiveSync, ANDSF, Wi-Fi Simple Config • Observation 3: Removal of the MAC address randomization feature will impede the utility of the resulting standard as it denies the ability of a device to protect its privacy during service discovery procedures. Stephen McCann, BlackBerry

  6. These specific MCCs from the P802.11aq sponsor ballot are as follows: • r03-8 (9008) • r04-8 (10008) • r04-9 (10009) • r04-12 (10012) • r05-5 (11005) [references r04-9] • r05-6 (11006) [references r04-8] • r05-7 (11007) [references r04-12] • r06-9 (12009) • r07-10 (13010) • r07-11 (13011) [references r06-9] • r07-12 (13012) [references r04-9, r06-9 and r06-12) • r07-13 (13013) • r07-14 (13014) [references r06-4] • As detailed in the comment resolution spreadsheet tab “IEEE RAC Comments” • Note the numbers in parentheses relate to the BRC comment numbering Stephen McCann, BlackBerry

  7. The following slides summarize the specific MCCs. These summaries have been produced by the P802.11aq BRC to the best of their ability. • Each MCC summary is formatted as follows: • Summary of the original MCC received from IEEE RAC • Summary of the original BRC comment resolution • BRC waiver commentary based the current state of the P802.11aq draft. • This may differ from the original P802.11aq comment resolution, due to subsequent changes made to the P802.11aq draft Stephen McCann, BlackBerry

  8. Comment summary of r03-8 (9008) • Original MCC summary: • Random MAC address assignment would seem to be out-of-scope for the PAR • Original BRC Response summary: • Rejected • Randomizing the MAC address, as described in P802.11aq clause 12.2.10, is a perfectly reasonable part of the pre-association discovery scope. This avoids revealing privacy compromising information to STAs that are observing the P802.11aq traffic. • BRC waiver commentary: • See observations 1, 2 and 3 Stephen McCann, BlackBerry

  9. Comment summary of r04-8 (10008) I • Original MCC summary: • 11aq specifies that devices select a 48-bit MAC address using 46 bits selected randomly (the other two set to indicate local unicast), whereas IEEE Std 802 (since the June 2017 approval of the amendment IEEE Std 802c) provides for four types of local addresses, and the random use of 46 bits will likely cause collisions with this allocation scheme. Further 44 bits is a large enough space. • Original BRC Response summary: • Revised • The P802.11aq draft behavior has been changed to allow a STA to conform to a local administered address space policy when it associates to a network. • The maximum number of bits of randomization for the MAC is beneficial to address privacy issues associated with network discovery when the STA is in the unassociated state. Stephen McCann, BlackBerry

  10. Comment summary of r04-8 (10008) II • BRC waiver commentary: • See Observation 1 • The P802.11aq draft has been changed, over subsequent re-circulation sponsor ballots, to not refer to the number of bits used for MAC address randomization. • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “The STA shall construct the randomized MAC address from the locally administered address space as defined in IEEE Std 802-2014 and IEEE Std 802c-2017”. • The BRC believes that this satisfy the intent of the original comment as this allows an administrator to configure a 44 bit address space for randomization compliant with IEEE Std 802c-2017. Stephen McCann, BlackBerry

  11. Comment summary of r04-9 (10009) I • Original MCC summary: • There is nothing in the project scope to inform interested parties that the amendment will include specifications that present potential interoperability problems with many other standards that use IEEE Std 802 specified addressing • Original BRC Response summary: • Revised • Changes were made to the P802.11aq draft to make the device manageable at layer-2. Privacy enhancements may be required to perform pre-association service discovery. The draft has been modified to minimize the addressing conflicts suggested by the comment. • Any managed network will need to separate unmanaged devices from that network. This can easily achieved with a router, or alternatively enterprise class access points, which can separate devices that they know how to provision, as opposed to those that they can not. Any necessary isolation of the unmanaged devices, can be achieved through such a router. It is the responsibility of the network administrator to configure the network to provide these properties. Stephen McCann, BlackBerry

  12. Comment summary of r04-9 (10009) II • BRC waiver commentary: • See observations 1, 2 and 3 • Administrators set the rules for the local address space and configure devices using methods which are out of scope of IEEE 802.11. P802.11aq provides mechanisms to enable such configuration that is applied before the STA associates to the LAN. Stephen McCann, BlackBerry

  13. Comment summary of r04-12 (10012) I • Original MCC summary: • The draft is incompatible with IEEE Std 802-2014 because it doesn't allow for the local administrator administering the local addresses • Original BRC Response summary: • Revised • Privacy enhancements may be required to perform pre-association service discovery. The P802.11aq draft has been modified to eliminate the addressing conflicts suggested by the comment and allow for the STA to be configured in a mode consistent with a locally administered address space policy. • A managed network would not expect to connect to an unmanaged access network, as it would typically connect via a router. A managed network might connect directly to an access network of enterprise (managed) APs. Those APs would refuse to admit STAs that did not provide management of the local address space. Stephen McCann, BlackBerry

  14. Comment summary of r04-12 (10012) II • BRC waiver commentary • See observations 2 and 3 • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “a non-AP STA …. shall check the value of dot11LocallyAdministeredMACConfig and shall configure its MAC address according to the rules of the local address space prior to the start of the transaction”. Such a transaction can be association. • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “The default value of the dot11LocallyAdministeredMACConfig is that the local addresses comply with the Structured Local Address Plan (SLAP) as defined in IEEE Std 802c-2017.” Stephen McCann, BlackBerry

  15. Comment summary of r05-5 (11005) I • Original MCC summary: • The RAC is not satisfied with the response to Comment r04-9 (slide #11). However, considering the scope of the project, per the PAR, it seems apparent that specifying a new method to assign LAN data frame addresses is out of scope • Original BRC Response summary: • Rejected • The comment makes a general claim that that there are interoperability issues with other standards that make use of IEEE addressing but does not describe a single interoperability issue or suggest a text change that would address the interoperability . • Pre-association Service Discovery mechanisms specified in this amendment have the potential to leak privacy information. The privacy mechanisms incorporated into this amendment address privacy concerns with pre-association service discovery. Therefore it is the view of the CRC that privacy is within scope of the PAR. • Although the draft specifies MAC address selection in the pre-associated state, the draft clarifies the selection of the MAC address used when a BSS is selected is associated with the MAC address. Stephen McCann, BlackBerry

  16. Comment summary of r05-5 (11005) II • BRC waiver commentary • See observations 1, 2 and 3 • Administrators set the rules for the local address space and configure devices using methods which are out of scope of IEEE 802.11. P802.11aq provides mechanisms to enable such configuration that is applied before the STA associates to the LAN. Stephen McCann, BlackBerry

  17. Comment summary of r05-6 (11006) I • Original MCC summary: • The RAC is not satisfied with the response to Comment r04-8 (slide #9). During the discovery process, the draft still specifies that station adopts a 46-bit random address • Original BRC Response summary: • Rejected • In the pre-associated state, the only communication is between STAs. Frames transmitted between a STA and an AP terminate at the AP and never reach the LAN. Security and duplication detection mechanisms prevent frames from a non-associated STA with a conflicting MAC address from affecting any traffic in the BSS. The P802.11aq draft does not specify any number of bits, as it refers to IEEE 802-2014 and IEEE 802c-2017. Stephen McCann, BlackBerry

  18. Comment summary of r05-6 (11006) II • BRC waiver commentary • See Observation 1 • The P802.11aq draft has been changed, over subsequent re-circulation sponsor ballots, to not refer to the number of bits used for MAC address randomization. • The BRC made the following updates contained in D14.0: • The STA shall construct the randomized MAC address from the locally administered address space as defined in IEEE Std 802-2014 and IEEE Std 802c-2017 • The BRC believes that this satisfy the intent of the original comment as this allows an administrator to configure a 44 bit address space for randomization compliant with IEEE Std 802c-2017. Stephen McCann, BlackBerry

  19. Comment summary of r05-7 (11007) I • Original MCC: • The RAC is not satisfied with the response to Comment r04-12 (slide #13). The RAC would prefer a direct control functionality by which the network could specify a local address plan and policy. The current draft instead proposes a MIB-based solution without specifying any method to establish the relevant parameter • Original BRC Response summary: • Rejected • The method used to choose MAC addresses is performed using a MIB variable. This MIB variable can be set by a management agent such as an out-of-band provisioning protocol, for example: Passpoint, using an USB connection. • The MIB variable is the layer-2 part of a mechanism for management that needs additional support from the provisioning protocol. This is no different to the wired case, in that routers are configured through a proprietary management interface. Stephen McCann, BlackBerry

  20. Comment summary of r05-7 (11007) II • BRC waiver commentary: • See observations 2 and 3 • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “a non-AP STA …. shall check the value of dot11LocallyAdministeredMACConfig and shall configure its MAC address according to the rules of the local address space prior to the start of the transaction”. Such a transaction can be association. • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “The default value of the dot11LocallyAdministeredMACConfig is that the local addresses comply with the Structured Local Address Plan (SLAP) as defined in IEEE Std 802c-2017.” Stephen McCann, BlackBerry

  21. Comment summary of r06-9 (12009) I • Original MCC summary: • The RAC remains unsatisfied with the responses to unresolved RAC Mandatory Coordination comments. RAC believes all remaining Mandatory Coordination issues can best be satisfied by deleting all references and specifications in the draft to use of random MAC addresses • Original BRC Response summary: • Revised • The P802.11aq draft has been modified to specify that the STA select a random address from the local address space according to IEEE 802-2014 and IEEE 802c-2017 while in the unassociated state. When the device selects a AP (BSS) for association, the STA checks the value for dot11LocallyAdministeredMACConfig and sets its MAC address according to the MAC address policy set by the Network Administrator for the BSS. Therefore a STA with MAC privacy enabled selects a random address compliant with IEEE 802c-2017 in the unassociated state and uses the Local Address configuration for a BSS once it associates to that BSS. Stephen McCann, BlackBerry

  22. Comment summary of r06-9 (12009) II • BRC waiver commentary: • See observations 1, 2 and 3 Stephen McCann, BlackBerry

  23. Comment summary of r07-10 (13010) I • Original MCC summary: • The RAC remains dissatisfied with the responses to unresolved RAC Mandatory Coordination comments submitted in earlier ballot rounds. • Original BRC Response summary: • Rejected • This comment fails to identify changes in sufficient detail so that the specific wording of the changes that will satisfy the commenter can be determined. Stephen McCann, BlackBerry

  24. Comment summary of r07-10 (13010) II • BRC waiver commentary • See observations 1, 2 and 3 • P802.11aq D14.0 clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “a non-AP STA …. shall check the value of dot11LocallyAdministeredMACConfig and shall configure its MAC address according to the rules of the local address space prior to the start of the transaction”. Such a transaction can be association. • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “The default value of the dot11LocallyAdministeredMACConfig is that the local addresses comply with the Structured Local Address Plan (SLAP) as defined in IEEE Std 802c-2017.” Stephen McCann, BlackBerry

  25. Comment summary of r07-11 (13011) I • Original MCC summary: • The RAC is dissatisfied with the response to Comment r06-9. The first paragraph of the response argues that the problematic material is important to privacy of pre-assocation discovery, without addressing prior RAC proposals (or many other possible alternatives) that would provide privacy without raising RAC objections. The RAC also notes that the problematic material was not included in the draft originally circulated for Sponsor Ballot but which, we presume, was considered acceptable by the 802.11 Working Group. • The change documented in the response to r06-9 lacks the critical features of prior comments necessary to resolve RAC concerns. The change adds the sentence "The STA shall construct the randomized MAC address from the locally administered address space as defined in IEEE Std 802-2014 and IEEE Std 802c-2017." This is problematic because (1) the cited standards (IEEE Std 802, or IEEE Std 802-2014 as amended by IEEE Std 802c-2017) do not "define" the construction of addresses, although they do "specify" address formats; (2) the reference is ambiguous since IEEE Std 802 specifies various address formats for various circumstances. While the RAC remains convinced that an address space far smaller than 46 bits of randomization would readily address the issue, it notes that two of the four quadrants of the Structured Local Address Plan (SLAP) specified therein could be suitable for randomized addresses (one requiring specification of currently reserved values in amended Std 802 to allow 45 bits for randomization), or using the AAI space only would provide 44 of the 46 bits that the draft currently specifies. Stephen McCann, BlackBerry

  26. Comment summary of r07-11 (13011) II • Original BRC Response summary: • Rejected • The BRC believes that the proposed change would impose a MAC address allocation scheme on local administrators that they may not wish to use. • BRC waiver commentary • See observations 1, 2 and 3 • The P802.11aq draft has been changed, over subsequent re-circulation sponsor ballots, to not refer to the number of bits used for MAC address randomization. • The P802.11aq draft clause 12.2.10 has been changed, over subsequent re-circulation sponsor ballots, to state that “The default value of the dot11LocallyAdministeredMACConfig is that the local addresses comply with the Structured Local Address Plan (SLAP) as defined in IEEE Std 802c-2017.” Stephen McCann, BlackBerry

  27. Comment summary of r07-12 (13012) I • Original MCC summary: • The RAC is dissatisfied with the response to Comment r06-9. In the past, the RAC expressed concern regarding the draft scope exceeding the PAR scope (see, e.g., r04-9). In response to r04-9, the Working Group responded that it made changes and that "These changes include removal of any specification for behavior after discovery and selection." This is critical, because a key PAR scope limitation is succinctly summarized in the project title: "Pre-Association Discovery." Yet the response to r06-9 again recognizes that the draft ventures into post-discovery, stating that "When the device selects a AP (BSS) for association, the STA checks the value for dot11LocalMACAddressConfig and sets its MAC address according to the MAC address policy set by the Network Administrator for the BSS." The group also states (r06-12) that "this draft specifies the use of MAC addresses for post-association use, for example see P66L57 in D13.0." Stephen McCann, BlackBerry

  28. Comment summary of r07-12 (13012) II • Original BRC Response summary: • Rejected • A STA discovers and selects a IEEE 802.11 network before it associates. In order to complete association, a STA must be configured. The configuration process takes place pre-association and therefore it is within scope of IEEE 802.11aq to impose requirements on the STA. This comment is in support of an unsatisfied IEEE RAC comment and does not provide substantive new proposed change. • IEEE 802.11 STAs have many steps which prepare them for post-association operation. The comment identifies some of those pre-association configuration steps that are done in preparation for post-association operation. This amendment does not modify post-association behavior, which remains as defined in the IEEE 802.11 standard, using the MAC address configured pre-association. Stephen McCann, BlackBerry

  29. Comment summary of r07-12 (13012) III • BRC waiver commentary • See observations 1, 2 and 3 • The P802.11aq draft has been changed, over subsequent re-circulation sponsor ballots, to not refer to “post-association use”. Stephen McCann, BlackBerry

  30. Comment summary of r07-13 (13013) I • Original MCC summary: • The RAC remains dissatisfied with the changes to the second paragraph of 12.2.10 and to the specification of dot11LocallyAdministeredMACConfig. The text specifies that the device "shall check the value of dot11LocallyAdministeredMACConfig and shall configure its MAC address according to the rules of the local address space." However, the relationship between the "rules of the local address space prior to the start of the transaction" and "the value of dot11LocallyAdministeredMACConfig" is not clear. Furthermore, it is not clear how a local parameter within the device is able to impart an awareness of the "rules of the local address space." For example, if the non-AP STA is in range of several BSSs and each belongs to a different ESS and subject to a different local administrator, is each such administrator enabled to establish such rules, and to convey knowledge of its rules, to the STA "prior to the start of the transaction?" If so, how? Stephen McCann, BlackBerry

  31. Comment summary of r07-13 (13013) II • Original BRC Response summary: • Rejected • Administrators configure devices using methods which are out of scope of IEEE 802.11. MAC address allocation is simply another configuration parameter that would need to be configured for a STA to operate on an administered LAN. P802.11aq provides mechanisms to enable such configuration that is applied before the STA associates to the LAN. • This comment fails to identify changes in sufficient detail so that the specific wording of the changes that will satisfy the commenter can be determined. • BRC waiver commentary • See observations 1, 2 and 3 • As stated above in the BRC response summary. Stephen McCann, BlackBerry

  32. Comment summary of r07-14 (13014) • Original MCC summary: • The RAC is dissatisfied with the response to Comment r06-4, which does not address the issues raised in the comment. • Original BRC Response summary: • Rejected • The BRC believes the resolution of r06-4 did address the issues raised by the comment and resulted in the commenter changing their vote to approve. • BRC waiver commentary • See observations 1, 2 and 3 • As stated above in the BRC response summary. Stephen McCann, BlackBerry

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