Hi Orie, comments below.

> On 1 Jul 2024, at 23:30, Orie Steele <orie@transmute.industries> wrote:
> 
> # Orie Steele, ART AD, comments for draft-ietf-regext-epp-ttl-14 
> CC @OR13
> 
> https://author-tools.ietf.org/api/idnits?url=https://www.ietf.org/archive/id/draft-ietf-regext-epp-ttl-14.txt&submitcheck=True
>  [author-tools.ietf.org]
> 
> Thanks to Anthony Somerset for the DNSDir early review.
> Thanks to Andy Newton for the shepherd writeup.
> Thanks to Gavin and the working group for this document.
> 
> As you read my comments, please keep in mind that I am not a DNS expert.
> 
> ## Comments
> 
> I found the document easy to read, and most of my comments are minor.
> I do have a concern regarding the choice of enabling 2 modes "Default" and 
> "Policy".
> Especially after reading SAC-025, I wonder why the "Default" mode is offered 
> to implementations.
> If it is possible to make Policy Mode the only option, it seems like that 
> might improve the ability to surface and address the security issues 
> associated with short and long lived TTLs.
> 
> ### Recommended default TTL?
> 
> ```
> 204   4.  "default", which MUST NOT be present in command frames but MAY be
> 205       present in response frames (see Section 2.1.1), and which is used
> 206       by the server to indicate the default value;
> ```
> 
> ```
> 224   2.  empty, in which case the server's default TTL for the given
> 225       record type is to be applied.
> ```
> 
> Is there a recommended default TTL when EPP is used? 
> 
> See security considerations for why this might be a good idea.

I don't think it would be appropriate for this draft to recommend a default TTL 
value. The provisioning system should reflect the policy that's determined on 
the publication side, not impose a policy on it.

> ### DELEG as example
> 
> ```
> 298   <ttl:ttl
> 299     for="custom"
> 300     custom="DELEG">3600<ttl:ttl>
> ```
> 
> Consider a record that is already registered with IANA, TLSA for example.

As I understand it, TLSA is not appropriate for publication at a delegation 
point, so using TLSA here would not make any more sense than DELEG. Perhaps 
this should just be some placeholder value, such as MYCUSTOMTYPE?

> ### Are 2 modes really needed?
> 
> ```
> 308   It has a single OPTIONAL policy attribute, which takes a boolean
> 309   value with a default value of false.
> ```
> 
> Should this be interpreted as Default Mode is mandatory to support and Policy 
> Mode is optional?

No. The text extract only describes the permitted XML syntax of the extension 
elements.

By default, an <info> command just returns information about the specified 
object. The purpose of the <info> Policy Mode is to allow the client to also 
determine the server policy, that is, the supported DNS record types and the 
corresponding min, default and max TTL values.

> ### Examples for Section 2.2.1 and 2.2.2
> 
> Examples in Section 2.2.1 and 2.2.2 both only include the Default Mode.
> 
> Is Policy Mode supported by `<create>` and `<update>` ?
> 
> I assume the answer is yes, but explicit examples might make this clearer.

No, <info> only. In the document, Default Mode and Policy Mode are only 
specified in the context of the <info> command.

> ```
> 753   Servers MAY restrict the supported DNS record types in accordance
> 754   with their own policy.  For example, a server MAY allow clients to
> 755   specify TTL values for DS records only.
> ```
> 
> Can this be strengthened to a SHOULD or MUST?

Yes, a SHOULD here makes sense.

> ### Range and Record Type Errors
> 
> ```
> 757   A server which receives a <create> or <update> command which includes
> 758   a restricted record type MUST respond with a 2306 "Parameter value
> 759   policy" error.
> ```
> 
> Is it correct to reply with 2306 for both out of range and restricted record 
> type errors?

No - 2306 is appropriate for an unsupported DNS record type, but 2004 
(Parameter value range error) is appropriate for "out of range" errors.

There are a couple of usages of 2306 in Section 2.2 which should be 2004, so I 
will fix those.

> ### Servers can ignore clients?
> 
> ```
> 767   EPP servers which implement this extension SHOULD use the values
> 768   provided by EPP clients for the TTL values records published in the
> 769   DNS for domain and (if supported) host objects.
> ```
> 
> This feels like a throwaway sentence, why not MUST?
> 
> When can this SHOULD be ignored?

I didn't use MUST here because provisioning and publication systems are 
normally loosely coupled, so MUST seemed (in my view) to impose too strong an 
obligation on the server. There are scenarios where the TTLs might be ignored, 
such as those contemplated in Section 4.

> ### When can servers ignore the host attribute?
> 
> ```
> 771   EPP servers that use the "host attribute" model SHOULD use any A and/
> 772   or AAAA TTL values specified for the domain object when publishing
> 773   NS, A and AAAA records derived from host attributes.
> ```
> 
> When can this SHOULD be ignored? Why not MUST?

This is basically saying the same thing as the preceding paragraph, just in the 
scenario where an EPP server uses host attributes rather than host objects. See 
Section 1.1 of RFC 5731 for an explanation of the difference.

> ###  Operational considerations
> 
> ```
> 796   Historically, registry operators have used a global TTL value for all
> 797   delegations within their zones, which could then be tuned to an
> 798   optimum value.
> ```
> 
> Is this a recommendation? Can it be turned into one or removed?

It's not a recommendation, just a description of historical practice. It could 
be removed.

> ```
> 800   Registry operators SHOULD implement limits on the maximum and minimum
> 801   accepted TTL values that are narrower than the values permitted in
> 802   the XML schema in the Formal syntax (which were chosen to allow any
> 803   TTL permitted in DNS records), in order to prevent scenarios where an
> 804   excessively high or low TTL causes operational issues on either side
> 805   of the zone cut.
> ```
> 
> This feels like it is in conflict with the Default Mode, which is mandatory 
> to support?

This is not correct. "Default Mode" provides clients with a way to discover the 
current TTL settings for an object (as opposed to "Policy Mode" which also 
returns the server policy, see above). These two modes, which only apply to the 
<info> command, are not intended to, and indeed cannot, effect the server's 
ability to implement its own policy in relation to TTL values.

> ### Should ensure user understands
> 
> ```
> 814   A common operational mistake is changing of DNS record TTLs during or
> 815   after the planned change to the records themselves.  This arises due
> 816   to a misunderstanding about how TTLs work.
> 
> 818   Implementations of this specification SHOULD ensure that the user
> 819   understands that changes to a TTL are only effective in shortening
> 820   transition periods if implemented a period of time — at least equal
> 821   to the current TTL — _before_ the planned change.  The latency
> 822   between receipt of the <update> command and the actual publication of
> 823   the changes in the DNS should also be taken into consideration in
> 824   this calculation.
> ```
> 
> I think this could be rephrased to use BCP14 language in a more intuitive way:
> 
> ```
> It is RECOMMENDED that guidance be provided to users so that they are aware 
> that ...
> ```

Noted, I will make this change.

> ### fast flux DNS
> 
> ```
> 828   Some malicious actors use a technique called "fast flux DNS"
> 829   ([SAC-025]) to rapidly change the DNS configuration for a zone in
> 830   order to evade takedown and law enforcement activity.
> 
> 832   Registry operators should take this into consideration when setting
> 833   the lower limit on TTL values, since a short TTL on delegations may
> 834   enhance the effectiveness of fast flux techniques on evasion.
> ```
> 
> Consider shortening the first part to "in order to evade identification".

I don't believe fast flux allows a malicious actor to evade *identification*, 
its purpose is to render traditional takedown activities moot, because the 
domain has already moved onto new infrastructure by the time the old 
infrastructure has been disrupted.

> Please revise the second part to provide mitigation advice, based on the 
> reference:
> 
> ```
> Mitigations methods that are practiced today, but not uniformly, include:
> • Authenticate contacts before permitting changes to name server 
> configurations.
> • Implement measures to prevent automated (scripted) changes to name server
> configurations.
> • Set a minimum allowed TTL (e.g., 30 minutes) that is long enough to thwart 
> the
> double flux element of fast flux hosting. 
> • Implement or expand abuse monitoring systems to report excessive DNS
> configuration changes.
> • Publish and enforce a Universal Terms of Service agreement that prohibits 
> the use
> of a registered domain and hosting services (DNS, web, mail) to abet illegal 
> or
> objectionable activities (as enumerated in the agreement). 
> 
> ....
> 
> • Rate-limit or (limit by number per hour/day/week) changes to name servers
> associated with a registered domain name. Registries and registrars already
> apply rate-limiting techniques on query-based WHOIS services to discourage
> abuse. Determine a rate of change that (a) accommodates legitimate 
> applications
> of short TTLs for NS records in TLD zone files, (b) provides investigators 
> with a
> window of opportunity to track down the origin of updates and identify bots, 
> and
> (c) makes short TTLs less useful to fast flux attackers.
> 
> • Separate "short TTL updates" from normal registration change processing.
> Treat requests to set TTLs below a certain limit as special requests that 
> require
> some form of verification. 
> ```
> 
> Some of these are not directly related to TTL / EPP... some are.

Rather than copy-and-paste, I propose something like this:

Client implementations which provide an interface for customers to configure 
TTL values for domain names should consider implementing controls to deter and 
mitigate abusive behaviour, such as those outlined in the "Current and Possible 
Mitigation Alternatives" section of <xref target="SAC-025"/>.

> ### additional security considerations for ttl
> 
> Consider commenting on the impact of TTL on DDoS.
> Consider commenting on the impact of TTL on DNS Spoofing.
> Consider commenting on the impact of TTL on DNS Cache Poisoning.

I don't believe this draft has any implications on these topics. If you think 
it might, then I think I would want to get input from DNSOP and/or the DNS 
Directorate.

G.

--
Gavin Brown
Principal Engineer, Global Domains & Strategy
Internet Corporation for Assigned Names and Numbers (ICANN)

https://www.icann.org

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