Billing Code 3510-60-P
DEPARTMENT OF COMMERCE
National Institute of Standards and Technology
National Telecommunications and Information Administration
Docket No. 040107006-4006-01
Request for Comments on Deployment of Internet Protocol, Version 6
AGENCIES: National Institute of Standards and Technology
National Telecommunications and Information Administration,
ACTION: Notice of Inquiry
SUMMARY: The President's National Strategy to Secure Cyberspace directed the Secretary of Commerce to form a task force to examine the issues implicated by the deployment of Internet Protocol version 6 (IPv6) in the United States. As co-chairs of that task force, the Commerce Department’s National Institute of Standards and Technology (NIST) and the National Telecommunications and Information Administration (NTIA) invite interested parties to comment on a variety of IPv6-related issues including: (1) the benefits and possible uses of IPv6; (2) current domestic and international conditions regarding the deployment of IPv6; (3) economic, technical and other barriers to deployment of IPv6; and (4) the appropriate role for the U.S. government in the deployment of IPv6. Comments should be submitted on paper and, where possible, in electronic form as well. All comments submitted in response to this Notice will be posted on the NTIA Web site.
DATES: Interested parties are invited to submit comments no later than March 8, 2004.
ADDRESSES: Comments may be mailed to the Office of Policy Analysis and Development, National Telecommunications and Information Administration, Room 4725, Attention: Internet Protocol, Version 6 Proceeding, 1401 Constitution Ave., N.W., Washington, DC 20230. Parties should submit an original and five (5) copies. Where possible, parties should include a diskette or compact disk in ASCII, WordPerfect (please specify version) or Microsoft Word (please specify version) format. Diskettes or compact disks should be labeled with the name and organizational affiliation of the filer, and the name and version of the word processing program used to create the document. In the alternative to a diskette or compact disk, comments may be submitted electronically to the following electronic mail address: IPv6@ntia.doc.gov. Comments submitted via electronic mail should also be submitted in one or more of the formats specified above.
FOR FURTHER INFORMATION CONTACT: Alfred Lee, Office of Policy Analysis and Development, at (202) 482-1880. Media inquiries should be directed to the Office of Public Affairs, National Telecommunications and Information Administration, at (202) 482-7002.
A. The Internet Protocol
The Internet Protocol (IP) is a technical standard that enables computers and other devices to communicate with each other over networks, many of which interconnect to form the Internet. By providing a common format for the transmission of information across the Internet, IP facilitates communication among a variety of disparate networks and devices. This ability to communicate with a single, widely accepted format has been a key to the rapid growth and success of the Internet. 
The current generation of IP, version 4 (IPv4), has been in use for more than twenty years, and has supported the Internet’s phenomenal growth over the last decade. A variety of stakeholders, through the guiding efforts of the Internet Engineering Task Force (IETF), have developed a newer version of IP, known as IPv6, which has several advantages over IPv4, including the availability of many more Internet addresses and additional user features and applications.  IPv6 has also been designed to provide other features and capabilities such as improved support for hierarchical addressing, a simplified header format, improved support for options and extensions, additional auto-configuration and reconfiguration features, and native security features. 
B. Commerce Department Task Force
In light of the potential benefits of IPv6, especially the security implications, the President's National Strategy to Secure Cyberspace directed the Secretary of Commerce to:
[F]orm a task force to examine the issues related to IPv6, including the appropriate role of government, international interoperability, security in transition, and costs and benefits. The task force will solicit input from potentially impacted industry segments. 
In response, the Commerce Department formed a task force to study IPv6 and to prepare a report of its findings and recommendations. The task force is co-chaired by the Administrator of the National Telecommunications and Information Administration (NTIA) and the Director of the National Institute of Standards and Technology (NIST) and consists of staff from these two agencies. The task force will operate in consultation with the Department of Homeland Security and with other federal offices and agencies, as appropriate.
The task force is in the process of gathering information from a variety of sources, including this request for comment, survey research, and a public roundtable meeting to be held in the first half of 2004. Prior to the public meeting, the task force intends to release an interim report, which will be discussed at the meeting.
By issuing this request for comment, the task force wants to develop a record
on the following broad questions, which are set forth in greater detail below:
(1) what are the potential uses and benefits of IPv6; (2) what are the costs
associated with deploying IPv6; (3) what are the current and projected penetration
rates of IPv6; and (4) what is the appropriate role for the
In answering the questions posed in this request for comment, we urge commenters to provide specific, empirical data and underlying assumptions whenever possible. We also request commenters to supply us with any technical reports or economic analyses that they cite to or rely on in their comments. We further ask commenters, where appropriate, to address how their responses vary, if at all, among different customer markets for communications services and products (e.g., small and medium enterprises, large enterprises, academia, civilian government, military, individual users, and any other relevant segments).
II. Potential Benefits and Uses of IPv6
We seek comment on the potential benefits and uses of IPv6. As described below, some of the potential benefits commonly associated with IPv6 include a significant increase in the number of available Internet addresses, a proliferation of new applications building on peer-to-peer communications, and improved security. We request comment on these and other possible benefits related to widespread adoption of IPv6. We request comment on the benefits accruing to both end users and system providers.
A. Increased Address Space
One of the most commonly cited benefits of IPv6 is the vastly expanded number of individual addresses that IPv6 will enable. IPv4 uses a 32-bit IP address scheme that allows more than 4 billion individual addresses to be identified on the Internet. With the explosive growth rate of Internet users and new applications over the last decade, concerns have been raised that the currently defined IPv4 address space may not be sufficient to meet the needs of the growing Internet user base.  By expanding the existing IP address field to 128 bits, IPv6 offers a vast pool (3.4 x 1038) of assignable Internet addresses. As a result, IPv6 can enable an enormous number of new nodes and users to be connected to the Internet using their own unique Internet addresses.
The task force requests comment on the adequacy of IPv4 address space.
Specifically, we seek estimates (and underlying assumptions) of how many IPv4
addresses have been allocated, how many are still available, and how long
the remaining addresses will be sufficient to meet the needs of users in the
The task force also seeks comment on the potential uses for this greatly expanded pool of addresses. What new products, services, features, applications and other uses are likely to result from the additional addresses offered by IPv6? To the extent possible, commenters should provide estimates and underlying assumptions of the economic impact of these new uses and should identify which market segments will be affected by these uses.
The task force understands that the use of Network Address Translation devices (NATs) and the adoption of address conservation practices, such as Classless Inter-Domain Routing (CIDR), have slowed the consumption of available IPv4 addresses. We seek comment on the accuracy of this understanding. While the adoption of NATs over the last decade has apparently slowed the consumption of IPv4 addresses, we understand that NATs have contributed to the development of separate, privately addressed networks that are interconnected with the public Internet. Because NATs act as gateways between the public Internet and users with private network addresses, each NAT device could potentially represent a single point of failure for traffic moving between a privately addressed network and the public Internet. We seek comment on the effects that NATs (as well as CIDR and other address conservation strategies) may have on network performance and network reliability.
B. Purported Security Improvements
The task force seeks comment on the ability of IPv6 to improve the security of information transmitted over IP networks. In general, we ask commenters to address any characteristics of IPv6 that directly or indirectly enhance network security compared to IPv4. Conversely, we also seek comments on any features of IPv6 that may degrade network security compared to IPv4.
We also seek specific comment on Internet Protocol Security Architecture, or IPsec, as it relates to an examination of the relative merits of IPv4 and IPv6. IPsec is a data security specification that is designed to protect the integrity and confidentiality of data traffic carried over the Internet.7 We understand that while IPsec in IPv4 is functionally equivalent to that available in IPv6, IPsec support is optional in IPv4 networks. Because IPsec is a standard feature of IPv6, will IPsec be easier to use with IPv6 than with IPv4 and, therefore, more widely used? If IPv6 adoption leads to the elimination of NAT devices on the Internet, is it more likely that IPsec will work better as a widely used, end-to-end security mechanism? Are there critical IPsec implementation issues that are independent of the version of IP employed? To what extent will a successful IPsec implementation depend on the development of workable trust models that deal adequately with issues such as public-key management and the adoption of effective security policies? The task force requests comment on these and any other issues involving IPsec, relevant to the growth of IPv6.
We understand that IPsec also permits address authentication, thereby assuring the recipient that a particular message is actually coming from the purported addressor. We seek comment on whether this feature could potentially deter "spoofing" attacks or could facilitate tracing of undesirable messages.8 Specifically, interested parties should explain how implementation of IPv6 or IPsec will accomplish those ends. As noted, moreover, IPsec is also available in IPv4. To what extent would deployment of IPv6 further national security and law enforcement interests over and above the security features and capabilities available via IPv4? The task force also understands that persons sending messages via the Internet can attempt to conceal their identities and addresses by, for example, operating through anonymous servers and relays operating at multiple protocol layers (e.g., NATs, mailrelays, proxies). Assuming that “network traceability” is an important objective in cyber security, to what extent would adoption of IPv6 improve the ability of network operators and law enforcement officials to identify accurately the true source of malicious or illegal network activity?
C. End User Applications
Apart from its expanded addressing capabilities and purported security improvements, we understand that IPv6 has also been designed to address other important user needs, including reducing network management burdens, simplifying mobile Internet access, and meeting quality of service needs. We ask commenters to explain whether and how IPv6 accomplishes these and other functions in a manner superior to IPv4. We also request that commenters explain the importance or value of the improved capabilities afforded by IPv6. To the extent possible, we ask that commenters provide examples of how these improved capabilities of IPv6 could benefit current users of IPv4 (e.g., cost savings, time savings).
One potential benefit of IPv6 is that its increased address space may further an original vision of the Internet. The task force understands that the Internet address space was originally designed to be a unified open scheme, connecting all users and nodes (each with its own unique address), as defined by the IPv4 addressing convention. A central idea was to allow users to communicate and run applications (e.g., Voice over IP (VoIP), gaming, or file exchange) with each other, across the Internet, on a peer-to-peer basis. Interested parties are encouraged to comment on the desirability and potential effort required to return the Internet to a unified open scheme as originally designed.
As noted above, the use of NATs has contributed to the development of separate, privately addressed networks that are interconnected with the public Internet. At the same time, various other devices are apparently being deployed throughout the Internet to increase network functionality. Such devices, often referred to as "middleboxes," appear to be proliferating in response to demand for capabilities that may include not only network address translation, but also firewall protection, intrusion detection systems, and other features.9 There is some concern that use of NATs and other middleboxes may block or inhibit the growth of peer-to-peer applications. Some observers assert that deployment of IPv6, by vastly increasing the available address space, will eliminate the need for NATs in particular, which, in turn, could lead to a proliferation of new peer-to-peer applications. On the other hand, NATs and other middleboxes may persist in an IPv6 environment because they may be useful for other reasons, including affording users some protection from hackers launching attacks across the public Internet. We request comment on these and any other issues involving NATs (or their equivalents) and middleboxes, related to the growth of IPv6.
Notwithstanding the criticisms of NATs, some have argued that NATs will not preclude peer-to-peer devices and applications.10 The task force requests comment on the accuracy of this assertion. Similarly, we seek comment on the effects of middleboxes on the availability and efficacy of peer-to-peer devices and applications. If NATs or middleboxes do interfere with peer-to-peer interactions, can “work arounds” be developed for particular applications? If work arounds can be developed, to what extent will they adversely affect the performance of the associated applications? Will those work arounds scale well (i.e., continue to function seamlessly and efficiently as the number of applications and users increases)? As importantly, what additional costs (in time, money, and complexity) will firms incur to develop work arounds for particular applications in order to accommodate NATs and middleboxes?
D. Network Evolution
Although the task force requests comments on the potential benefits of IPv6, we understand that IPv4 networks can incorporate many of the features and capabilities commonly associated with IPv6. Thus, some observers have claimed that the increase in address space afforded by IPv6 is the only compelling reason for adopting the new protocol, not the availability of other capabilities.11 The task force seeks comment on this assertion. Specifically, the task force requests comment on the ease with which each feature and capability associated with IPv6 can be implemented over IPv4 networks and whether IPv4 implementations will perform as effectively as IPv6 networks. Will IPv4 networks providing IPv6-associated features and capabilities suffer a performance penalty as compared to IPv6 networks? We request comment on whether any IPv6 feature or capability cannot be readily implemented over IPv4 networks. We ask commenters to identify the cost of implementing such features or capabilities on IPv4 networks, as compared to the cost of implementing IPv6 alternatives? We request comment on whether any IPv6 feature or capability, or set of features or capabilities is markedly superior to its IPv4 alternative, in terms of implementation cost or relative performance, such that an IPv6 implementation would be the clearly preferred choice over IPv4.
The task force also seeks comment on whether there are any potential performance impairments associated with the adoption of IPv6. For example, would the increased size of the IPv6 header have a significant impact on voice quality in VoIP applications, which are generally sensitive to latency? If, for example, IPv6 header compression schemes are used to mitigate potential performance issues (e.g., increased transmission latency), do such schemes require more router processing effort resulting in increased end-to-end latency? To be widely implemented, does IPv6 require new routing technologies (e.g., new versions of BGP-4) that could result in significant end-to-end system design and operational challenges? Are there any drawbacks due to inherent limitations of the IPv6 protocol design? Are there drawbacks resulting from immature or (currently) impractical hardware and software IPv6 implementation technologies?
We understand that the deployment of IPv4 networking infrastructure continues to evolve in ways that can effectively use existing and emerging transport and transmission system infrastructures (e.g., multi-protocol label switching (MPLS), asynchronous transfer mode (ATM), Frame Relay, optical, wireless, digital subscriber line (DSL), ethernet). Does IPv6 deployment depend on modifications to these underlying networks or require new transport and transmission systems to be implemented? Will IPv6 be able to utilize presently underused capabilities of transport and transmission networks to support new types of applications or to provide more efficient networking services for existing applications? We also seek comment on any spectrum management issues that might arise when IPv6-based wireless and hybrid networks are used to support mobile and fixed applications. Because IPv6 offers new capabilities, do the transport layers (e.g., transmission control protocol (TCP), user data protocol (UDP)) need to be modified to support both existing and new applications? Further, we request comment on whether and to what extent the transport layers need to be modified in order to realize the full capabilities of IPv6, including the potential for significantly improved IP network performance.
E. Other Benefits and Uses
The task force seeks comment on the range, attractiveness, and potential economic impact of new services that will emerge with the growth of IPv6. Specifically, what new service possibilities does IPv6 provide beyond those available using IPv4? We also ask commenters to identify other benefits and uses of IPv6 and to describe the potential economic and other impacts of such developments. For example, does VoIP represent the kind of application that could drive IPv6 adoption, and if so, how? Will IPv6 improve the performance of VoIP? Please identify other applications that could drive or benefit from the adoption of IPv6. Are there applications that could thrive with only a partial implementation of IPv6?
III. Cost of IPv6 Deployment and the Transition from IPv4 to IPv6
The task force seeks information on the factors that may cause individuals and organizations to adopt IPv6 and, most importantly, the costs of doing so and the transitional issues presented. We encourage interested parties to provide us with specific detail, to the extent possible, on their IPv6 deployment strategies. What factors influence an organization’s decision to adopt IPv6? For example, is there a certain level of IPv6-based traffic that will cause network operators or ISPs to convert their facilities to IPv6? Is there a critical point at which consumers’ acquisition and use of IPv6-capable terminal equipment and applications will drive deployment of IPv6-capable infrastructure? To what extent, if at all, do these factors vary by provider (e.g., network operator, ISP, equipment vendors, applications providers) and by market segment (e.g., small and medium enterprises, large enterprises, academia, civilian government, military, individual users, and any other relevant segments)? As importantly, why are certain organizations choosing not to implement IPv6 at this time?
A. Cost of Deploying IPv6
The task force seeks specific data on the hardware, software, training, and other costs associated with implementation of IPv6. In responding to the questions below, we ask commenters to discuss the extent to which any of these costs may vary by market segment. They should also discuss whether and to what extent the costs might vary depending on the nature of the IPv6 implementation (e.g., a “greenfield” implementation versus one that overlays or replaces an embedded IPv4 base)? To what extent do the IPv6 costs vary with the size of the embedded IPv4 base? In instances where IPv6 capabilities are already deployed, what factors must be present to “turn on” existing IPv6 functionality?
1. Hardware costs
Deploying IPv6 on a national scale will require a substantial replacement and/or upgrading of existing IPv4 equipment. The task force solicits comments on the nature and magnitude of the costs of deploying IPv6, including the likely time period over which those costs will be incurred. For example, routers, hosts, servers, and terminal equipment presumably will have to be replaced or modified in order to originate, transport, and receive IPv6 traffic. If only modifications are required, will they involve hardware changes (e.g., router line cards)? What are the likely costs of those changes? What additional costs will be incurred (e.g., training/retraining costs, transition testing on operational functionality and performance)? Will the premises equipment that enables broadband transmission services (e.g., DSL and cable modems) need to be replaced or modified in order to carry IPv6 traffic and, if so, at what cost?
As embedded IPv4 equipment reaches the end of its useful life, users will presumably need to acquire replacements. What are the useful lives of the various categories of such equipment (e.g., routers, servers, premises equipment) and how has the duration of those lives changed over time? Are there differences between the technical and economic lives of particular equipment that may have a bearing on the decision to move from IPv4 to IPv6? When the time comes to replace existing IPv4 equipment, will the relative costs be such that users will tend to purchase IPv6-capable equipment? Or will the added direct and indirect costs (e.g., operating, and administrative costs) of purchasing IPv6 equipment induce users to stay with IPv4-compatible equipment and applications? Will manufacturers continue to produce equipment and applications that can handle only IPv4 packets? What market conditions would persuade manufacturers to cease offering IPv4 equipment?
2. Software costs
To what extent will the modifications to routers, hosts, servers, and terminal equipment mentioned above involve only software changes? What is the likely magnitude of those costs? Will various applications and Internet services (e.g., search engines, content delivery networks, DNS) have to be modified to make them compatible with IPv6 transmission? What are the estimated costs of those changes? Will the necessary modifications to software and applications require extensive changes in the underlying coding and, if so, at what cost? Are there differences in the useful life and cost of software, as compared to hardware, that make it likely that firms will acquire and implement IPv6 software and applications before IPv6 hardware, or vice versa?
3. Training costs
An organization’s personnel will have to be trained in how to install, operate, maintain, and service IPv6 hardware and software. How much will that training cost? How do training costs compare (e.g., in percentage terms) to the costs of IPv6 hardware and software? To what extent does the likely costs of training influence an organization’s decision to adopt IPv6?
4. Other costs
What are the opportunity costs of waiting to deploy IPv6?12 To
what extent will these costs vary by market segment (e.g., small and
medium enterprises, large enterprises, academia, civilian government, military,
individual users, and any other relevant segments)? How will the transition
path of the
B. Transition Costs and Considerations
1. Migration from IPv4 to IPv6 and the Coexistence of Dual Protocols
As our nation migrates from IPv4 to IPv6, there will be a period of time during which IPv4 and IPv6 operate simultaneously. The task force seeks comment on the costs and any other issues related specifically to this migration from IPv4 to IPv6. For example, what are the costs, burdens, and potential problems of ensuring interoperability between IPv6 and IPv4 networks? What are the incremental costs resulting from operating IPv6 and IPv4 concurrently? To what extent will various interoperability solutions continue to function efficiently and effectively as traffic increases? Does the operation of dual IPv4/IPv6 equipment impose significant costs relative to IPv4 or IPV6-only equipment? To what extent do measures to ensure interoperability reduce the performance of network routers, increase routing tables, or have other adverse effects?
Many observers assume that, regardless of the pace of IPv6 deployment, there
will be significant "islands" of IPv4 for the foreseeable future.13 There appear to be several transition
mechanisms to allow interoperability among IPv4 and IPv6 hosts and networks,
including dual stack, tunneling IPv6 over IPv4 networks, and IPv6-only to
IPv4-only translation. What are the costs and benefits of each of these
mechanisms? Is there a “best” or accepted approach that will provide
for interoperability between islands of IPv4 and/or IPv6 and the Internet
at large? What factors may determine whether and where alternative transition
mechanisms will be available and applicable? Can alternative transmission
mechanisms co-exist while still providing end-to-end interoperation among
IPv6 and IPv4 networks? Does the embedded base of IPv4 equipment and
applications function as a barrier that could isolate the
The task force recognizes that industry groups have worked hard to ensure interoperability between IPv4 and IPv6 networks and applications. Will domestic and international market forces alone produce a level of network interoperability that maximizes overall social welfare, or will government intervention be needed to produce such an outcome? If government intervention is needed, what form should it take?
What problems, if any, may arise when existing IPv4 networks convert hardware, appliances and middleware to IPv6? Will applications that use IP services migrate easily? Are there estimates of the cost associated with these issues? On the other hand, implementation of IPv6 (as distinct from gains anticipated via the definition of the new protocol) could also yield substantial hardware and software advances. Currently, IPv4 operates on top of several protocol layers (e.g., MPLS, ATM, frame relay, ethernet and wireless). Commenters are requested to explain how the technical requirements for these protocol layers and dependencies of protocol layers supported by IPv4 (e.g., UDP and TCP) may be impacted by the use of IPv6.
The task force seeks comment on the adequacy of the existing set of IETF standards for IPv6. Is the current set of IETF standards for IPv6 technically complete enough to enable widespread commercial deployment of interoperable IPv6 (and IPv4/IPv6 transition mechanisms) networks, equipment and applications? Would it be helpful for the IETF standards-track RFCs to define “mandatory” services (e.g., protocol capabilities) and “optional” services? What problems, if any, may arise in implementing IPv6, as embodied by the IETF standard set, in various types of equipment and software? Will the standards create undue hardship on equipment and software providers? Are additional industry or government specifications required to successfully realize the potential benefits of IPv6?
2. Security in Transition
Among the IPv6-related issues that the National Strategy to Secure Cyberspace directs us to study is “security in transition,” the need to ensure that security interests are protected during transition from IPv4 to IPv6. To what extent would the simultaneous operation of IPv4 and IPv6 networks and applications, potentially interconnected by a set of diverse transition mechanisms, compromise efforts to safeguard the integrity and security of communications traffic, or limit government’s ability to protect legitimate security and law enforcement interests?
3. Other Transition Concerns
Proper Internet address allocation is achieved through a network of national (i.e., the American Registry for Internet Numbers (ARIN)) and international (i.e., Reseaux IP Europeens Network Coordination Centre (RIPE-NCC) and Asia Pacific Network Information Centre (APNIC)) organizations that are authorized by the Internet Corporation for Assigned Names and Numbers (ICANN) to administer numbering and addressing. Does the deployment of IPv6 create address allocation issues for any market segment? How will allocations to end users and end-user devices be affected by IPv6 deployment? Will small and mid-sized ISPs and IT firms have equitable access to the addresses they need? Are the existing national and international registries technically capable of handling administrative tasks required for IPv6 numbering and addressing? If not, identify the tasks and the costs for registries to be made capable of handling IPv6 related administrative tasks.
IV. Current Status of Domestic and International Deployment
A. Appropriate Metrics To Measure Deployment
Efforts to deploy IPv6 commercially are relatively recent phenomena. Notwithstanding the nascent nature of the IPv6 market, the task force seeks to develop an understanding of how the market is evolving across regions (both domestically and internationally) and among user groups (e.g., government, industry, academia). What are the most appropriate metrics to gauge IPv6 deployment? Is the quantity of equipment purchased, the number of routers acquired, the number of addresses assigned, the number of hosts with IPv6 operating systems, the number of available applications that are IPv6 or IPv6/IPv4 compatible, or the amount of IPv6 traffic carried sufficient to properly define the IPv6 market? Are there other metrics or some combination of metrics best suited to characterize the domestic and international penetration of IPv6?
The task force is interested in an assessment of the total domestic and international deployment of IPv6. What is the known current volume of deployed native IPv6 and IPv4 network equipment (e.g., hosts, routers, switches)? To what extent does the pace and extent of IPv6 deployment vary from country to country or region to region (e.g., North America vs. Europe vs. Asia)?14 How is that equipment deployed by market segment? What is the approximate domestic and global value of all deployed IPv4 and IPv6 equipment? What is the percentage (and proportion as compared to IPv4) of known IPv6 deployments by market segment?
1. Overall Domestic Efforts
The task force seeks specific comment on the status of IPv6 deployment efforts
Second, the task force seeks comment on the actual deployment of IPv6 products
and services in the
Third, we seek comment on the projected growth of IPv6 products and services
2. Domestic Government Efforts
task force seeks comment on federal, state, and local government efforts to
deploy IPv6 in the
What is the current state of IPv6 deployment by other federal, state, and local government agencies? What factors have various agencies considered in deciding whether and at what pace to deploy IPv6? How do factors like geographic location, population density and/or available expertise impact the costs/benefits for state and local municipalities that are considering IPv6 deployments? How will the recent DoD requirement that all Global Information Grid assets be IPv6-capable by 2008 affect the procurement plans and decisions of other federal agencies? The task force encourages states and local governments to describe any initiatives or studies that they have undertaken regarding the deployment of IPv6. What is the current state of IPv6 deployment by state and local government agencies? What factors have various agencies considered in deciding whether and at what pace to deploy IPv6? How do factors like geographic location, population density and/or available expertise impact the costs/benefits for state and local municipalities that are considering IPv6 deployments?
3. International Efforts
In addition to domestic IPv6 deployments, the task force seeks comment on
international efforts to deploy IPv6. For example, we understand that
governments and companies in Asia have
been aggressively promoting and adopting IPv6, purportedly because of the
growing demand for public Internet addresses in their countries.
The task force requests comment on the current and projected levels of IPv6 deployment across the globe, on both a regional basis (e.g., Europe, Asia, South America) and on a country specific basis, where available. To the extent possible, we ask commenters to provide such information by product category (e.g., hardware, software) and by customer segment (e.g., government, private sector, academia). We also ask commenters to explain how particular initiatives or programs by foreign governments or foreign suppliers have helped (or hindered) IPv6 deployment. For example, have government commitments to reach a specific level of IPv6 deployment by a date certain helped spur deployment? Are governments devoting significant funding for IPv6 deployment efforts? Have government initiatives (of lack thereof) interfered with normal market forces and what are the consequences of those actions or inactions?
V. Government's Role in IPv6 Deployment
The task force seeks to build a public record that addresses two fundamental questions: (1) should government be involved in fostering or accelerating the deployment of IPv6; and (2) if so, what actions should government undertake? In answering these questions, we ask commenters to build upon their responses to the questions above and to provide specific, empirical evidence, where possible, to support their assertions regarding the proper role of government in IPv6 deployment.
A. Need for Government Involvement in IPv6 Deployment
1. Reliance on Market Forces
As a general matter, government policymakers in the
2. Potential Market Impediments
Notwithstanding the government’s general preference for relying on market forces, there may be impediments in a particular market that warrant corrective action by the government. In this section, the task force seeks comment on whether some of the more common forms of impediments are present in the market for IPv6 products and services.
a. Technological Interdependencies and the “Chicken and Egg” Problem
The task force requests comment on whether a "chicken and egg" problem exists that could hinder efficient deployment of IPv6 (i.e., disincentives for investment in supporting infrastructure until applications are deployed, matched by disincentives for investment in applications until supporting infrastructure is in place). In the case of IPv6, firms may be reluctant to build IPv6 networks (or to install IPv6 capability in existing IPv4 networks), or to develop and market IPv6 devices, if there are no IPv6 applications that prompt consumer demand for the underlying transmission infrastructure. Similarly, Internet service providers may be reluctant to install IPv6 in the absence of sufficient IPv6 applications. Applications providers, on the other hand, may hold off until the infrastructure is in place to make those applications usable by consumers. We seek comment on whether such a “chicken and egg” relationship exists between IPv6 applications and supporting infrastructure, and if so, how that relationship is manifesting itself in the market for IPv6 products and services.
The “chicken and egg” problem seems to be most acute when the interrelated products are costly to develop and are highly interdependent (i.e., the end product is a complex and capital intensive system). We seek comment on whether those characteristics are present for IPv6 infrastructure and applications. We also seek comment on how the expected degree of interoperability between IPv6 and IPv4 networks will affect this potential chicken and egg problem. Will the interoperability between IPv6 and IPv4 reduce potential impediments to the synchronized deployment of IPv6 infrastructure and applications, or will that interoperability merely serve to delay decisions to upgrade infrastructure and applications to IPv6? In some instances, government has responded to concerns over potential “chicken and egg” problems by playing an active role in the introduction of certain products and services, such as FM radio and HDTV. We request comment on how the deployment of IPv6 compares to other standards-based technology transitions and whether IPv6 presents the same or similar concerns that warrant government action.
b. Monopoly Power
The presence of a firm or group of firms, with monopoly power in the market
for IPv6 products or services could create a potential impediment to the efficient
deployment of IPv6 in the
To aid in this analysis, we seek comment on the extent to which IPv4 and IPv6 are direct substitutes. If IPv4 and IPv6 are direct substitutes (e.g., if IPv6 equipment and applications compete directly with IPv4-based counterparts for market share), it may be unlikely that providers of IPv6 equipment, applications, and services will be able to charge excessive prices for their products (i.e., prices that exceed any performance differential). Alternatively, if IPv6 builds on IPv4, enabling related but different applications, early entrants into the market may be able to establish sufficient market power to impede adequate competition. Economists, however, generally consider such temporary monopolies to be a normal phase of new technologies’ evolution and thus such a pattern may represent an efficient deployment of a new technology and not a market failure. We request comment on these issues.
c. Network Externalities
The presence of network externalities or networking effects could also impede
efficient deployment of IPv6.22 The task force requests comment
on whether and to what extent deployment of IPv6 is characterized by network
externalities. If so, what is the magnitude of those externalities?
In this regard, most observers believe that IPv6-based networks will be interoperable
to a considerable degree with embedded IPv4 networks and, therefore, IPv6
users will be able to communicate with IPv4 users in many instances.
To what extent does that affect the size or scope and timing of any network
externalities associated with deployment of IPv6? Do network externalities
arise, if at all, from all IPv6-based services and applications, or are they
limited to specific offerings (e.g., gaming services whose value to
individual users likely depends on the number of potential opponents)?
Given the early state of IPv6 deployment, is it premature to predicate a case
for government intervention at this time on the possible existence of network
externalities? How important are network externalities in the
Network externalities increase uncertainty (and thereby deter efficient investment decisions) because the returns on a company’s investment are dependent on the investment decisions of other companies.23 In addition, if related applications, or applications and infrastructure are highly complementary, early entrants into a market that is not mature may not be able to realize returns on investment in an acceptable time frame. These factors increase market risk and impede the development and deployment of technologies. A lack of information and documentation regarding benefits and costs also increases market risk. The task force seeks comments on the importance of coordinating the timing of IPv6 migration for achieving efficient market penetration.
d. Other Impediments
In addition to the potential market impediments described above, we seek comment
on any other potential market impediments that may hinder IPv6 deployment
3. Public Goods
An important role of government is to ensure the adequate provision of “public goods,” which market forces alone commonly cannot do.24 Examples of public goods include national defense, law enforcement and clean air. Infrastructures, to varying degrees, also have the characteristics of public goods. Because standards are by definition used collectively by competing and partnering economic agents, they have infrastructure characteristics. In this section, the task force seeks comment on the public good characteristics of IPv6-capable products and services.
In section II.B above, we seek comment on the potential security benefits
of IPv6. To the extent that commenters believe
IPv6 may directly or indirectly facilitate improved IP security, we seek comment
on whether security benefits from IPv6 exist that can significantly further
the delivery of public goods. For example, could the deployment of IPv6
advance important national security, national defense, and law enforcement
interests, which are commonly understood to be public goods?25 We understand that certain features
of IPv6 (e.g., expanded address space, auto-configuration) could enable
the military to provide soldiers with equipment that could improve command
and control capabilities in the field. Improved auto-configuration could
also enable first responders to establish vital communications systems in
the event of disaster or national emergency. Does the furtherance of
those and any other security-related interests require government action to
speed the deployment of IPv6 in the
The task force also seeks comment on whether the private sector may fail to sufficiently implement IPsec or other security mechanisms, and whether government action to accelerate the deployment of IPv6 could aid private sector security efforts. For example, what conditions could hinder private sector efforts to fashion key management systems and trust mechanisms needed to implement IPsec in an IPv6 environment? To what extent would federal government intervention be useful or necessary to overcome such obstructions?
b. National competitiveness
Given other nations' announced commitments to IPv6, is
We also understand that use of IPv6-capable networks and applications may
increase the efficiency of users of IPv6 infrastructure, potentially allowing
them to produce and market their goods and services at lower cost or with
higher quality – both domestically and in international markets. Thus,
lagging deployment of IPv6 in the
B. Nature of Government Action
In light of commenters’ answers provided to the preceding questions, we now seek comment on the type of action or actions, if any, that the government should take regarding IPv6 deployment. Traditional government support for new technologies and technology infrastructures have included R&D support, incentives for investment in equipment, government procurement, and facilitation roles with respect to standards development and deployment. We emphasize that the list of government actions discussed below is not exhaustive, nor are such actions mutually exclusive. We therefore request that commenters provide specific details for any course(s) of action they propose, together with the estimated costs of such action(s).
1. No Government Action
To the extent commenters believe the aforementioned
trends and potential market conditions suggest a timely deployment of IPv6
2. Options for Government Action
We discuss below specific actions that government could take to further deployment
of IPv6. As noted above, the approaches discussed are not exhaustive,
however, and interested parties are encouraged to identify and outline other
potential avenues for government action. If the federal government should
elect to spur deployment of IPv6 within the
a. Government as Information Resource
Rather than actively promoting deployment of IPv6, the government could establish programs to assist public and private sector entities in making their deployment decisions. It could, for example, create an information clearinghouse that gathers and disseminates IPv6-related information among government agencies and interested private sector firms. Such information could include data concerning the potential benefits and costs of deploying IPv6, the purchasing decisions made by other public and private actors, and guidelines to aid interested parties in making IPv6 procurement decisions. What would be the costs and benefits of such an approach? What would be the essential elements of an effective clearinghouse program?
b. Government as Consumer
We seek comment on whether the government should use its position as a large consumer of information technology products to help spur IPv6 deployment. For example, working through its procurement process, should the federal government purchase only IPv6-compatible products and services? Should state and local governments adopt similar procurement policies? What would be the cost to the government of adopting IPv6 procurement policies compared to not adopting such policies? Could the government’s adoption of IPv6 procurement policies have any unintended, adverse effects on the market for IPv6 products and services? If so, please define and assess the likelihood and magnitude of such effects?
To the extent commenters support government IPv6 procurement policies, we seek specific comment on how they should be implemented. For example, when should such policies become effective? Should such policies apply to all government entities, or are there specific classes of agencies that should adopt these policies before others? How should government fund any additional costs (if any) associated with the adoption of IPv6 procurement policies.
c. Government Support for Research and Development
As discussed above, testbeds and experiments by the Fednets and Abilene26 have provided early working experience relating to the deployment and use of IPv6. Those activities have also helped to train a corps of IPv6 technicians that could be available to facilitate private sector deployment of IPv6. Furthermore, the Internet2 program has established an IPv6 Working Group that interacts with users, university networks, and Fednets to explain IPv6 deployment and transition issues and to provide hands-on experience to those entities concerning implementation, maintenance, and use of IPv6. In light of these activities, we seek comment on whether the government should provide additional support for IPv6 research and development. Are current research and development efforts sufficient? Does the government possess research and development tools or resources for IPv6 that are not readily available to the private sector? If the government does provide research and development assistance, what form should it take (e.g., use of government facilities, tax incentives, matching grants, direct funding)?
d. Government Funding of IPv6 Deployment
Aside from research and development projects, we also seek comment on whether the federal government should attempt to spur the growth of IPv6 networks, applications, and services through direct funding of IPv6-related activities. For example, the government could provide direct assistance to entities desiring to purchase IPv6-capable equipment, whether in the form of tax incentives, matching grants, or direct funding. The task force seeks comments on the need, feasibility and wisdom of these approaches. How should such programs be structured and how much would they cost? Could existing policies and programs be used to provide such funding, or would new legislative authorization be required? Where the federal government provides funding to state and local governments for emergency communications equipment and networks, should the federal government require state and local agencies to purchase IPv6-capable equipment to ensure interoperability among equipment and networks in neighboring communities?
e. Government IPv6 Mandates
Although imposing government mandates on the private sector to deploy IPv6 is perhaps the least preferred role for government, the task force nonetheless seeks comment on this option to ensure that we develop a complete record. Specifically, we seek comment on whether the government should require suppliers of IP products and services to provide those products and services in an IPv6-compatible version by a date certain. To the extent commenters support such an approach, we ask them to explain the specific authority under which such a mandate could be imposed (legislative or administrative), the timeline under which the mandate would operate, and the benefits and costs of imposing such a mandate.
DATED: January 14, 2004
Arden L. Bement, Jr., Director
National Institute of Standards and Technology
Michael D. Gallagher
Acting Assistant Secretary for Communications and Information
National Telecommunications and Information Administration
 See, e.g., Barry M. Leiner, et al, “A Brief History of the Internet,” http://www.isoc.org/internet/history/brief.shtml. This document describes the development of the Internet and explicitly describes the original decision to use IP in a widespread manner. See http://www.isc.org/ds/host-count-history.html for statistics on the rapid growth of Internet hosts.
 Background information concerning the history of the Internet can be found at www.isoc.org/internet/history/. IETF efforts to transition from IPv4 to a successor protocol standard are described in S. Bradner, "The Recommendation for the IP Next Generation Protocol", RFC 1752 (Jan. 1995), www.ietf.org/rfc/rfc1752.txt?number=1752. Because of the vast amount of widely available resources that provide information on IPv6 and related topics, only representative citations are contained herein for the purpose of facilitating responses to this Notice. Commenters are requested to cite, as appropriate, specific references in support of comments submitted.
 For the purposes of this Notice, IPv6 can be defined with reference to IETF Request for Comments (RFCs) that contain the relevant standards. See www.ietf.org for updated information on this matter. Within the IETF, the IP Next Generation (IPng) Working Group developed IPv6, including the "core" draft standards approved in August 1998 (i.e., RFCs 2460, 2461, 2462, 2463). To date, more than 70 RFCs comprise the suite of IETF documents that define IPv6. While the IETF continues to standardize IPv6, and a wide range of related efforts are being undertaken by other organizations (e.g., the IPv6 Forum), the essential features of IPv6 appear to be well established and manufacturers already have a range of IPv6 compatible products available in the marketplace.
 The National Strategy to Secure Cyberspace, A/R 2-3, at 30 (Feb. 2003), www.whitehouse.gov/pcipb/cyberspace_strategy.pdf.
 IETF RFC 1752 (see note 2, supra) estimates that IPv4 address space will be exhausted "between 2005 and 2011" and notes relevant assumptions underlying this estimate, which was made in 1993. While estimated dates for potential exhaustion of the IPv4 address space vary widely, a calculation made more recently by Christian Huitema purports to confirm the RFC 1752 timeframe projection. In his view, "we are again facing a crisis. We must either deploy IPv6 or risk a strange evolution of the Internet toward a set of disconnected networks." Christian Huitema, Routing in the Internet 366 (2d ed. 2000). Information relating to allocation of IPv4 and IPv6 addresses is provided by the American Registry for Internet Numbers (ARIN). See, e.g. www.arin.net/announcements/20031027_ipv4.html. See also Mark McFadden and Tony Holmes, “Report of the Ad Hoc Group on Numbering and Addressing” (Mar. 2001), http://www.icann.org/committees/adhoc/mcfadden-holmes-report-08mar01.htm.
 See, e.g., Geoff Huston, “IPv4 Address Lifetime Expectancy - 2003 http://www.apnic.net/community/presentations/docs/ietf/200307/v4-lifetime-20030715.ppt.
7 See, e.g., Pete Loshin, “Securing the Internet with IPsec (Internet Security Architecture),” Earthweb (Sept. 9, 1999), http://itmanagement.earthweb.com/erp/article.php/615921. This article provides background information on IPsec and its operation with IPv4 and IPv6. The task force notes that IPsec is only one method of protecting the security of private communications. Interested parties are encouraged to comment on the availability of other data security specifications and their effectiveness at protecting the security interests of users, providers, and government, as compared to IPsec.
8 “Spoofing” refers to the creation of Internet packets using someone else’s Internet address. See, e.g., Matthew Tanase, “IP Spoofing: An Introduction,” www.securityfocus.com/infocus/1674.
9 See, e.g., M. Lerner, et al., Middleware Networks: Concept, Design, and Deployment of Internet Infrastructure (2000). In this document, the term “NAT device” refers to equipment that performs only network address translation. We use the term “middleboxes” in this Notice to describe a broader category of equipment, which could encompass NAT devices and other equipment that provide a variety of capabilities including, but not necessarily, network address translation. For a discussion of thee potential effects of NATs and middleboxes on end-to-end Internet connectivity, see David Margulius, “The Threat to Universal Internet Connectivity,” InfoWorld, Nov. 21, 2003, http://www.infoworld.com/article/03/11/21/46FEtrouble_1.html.
10 See, e.g., Dan Jones, “European IPv6 Plan Comes Under Fire,” Light Reading, at 2 (Mar. 7, 2002) (citing statement of Paul Francis, inventor of the NAT).
11 See, e.g., Geoff Huston, “Waiting for IP version 6”, at 9, The ISP Column (Jan., 2003); John Klensin, “A Policy Look at IPv6: A Tutorial Paper,” at 17 (Apr. 2003). Contra Latif Ladid and Jim Bound, “Response by IPv6 Forum,” The ISP Column (Jan. 2003). Claimed benefits of IPv6, including but not limited to resolution of IPv4 address depletion issues, are discussed in an IETF work in progress that outlines the business and technical case for IPv6. See S.King, et al., "The Case for IPv6 (Dec.1999). A wide range of potential IPv6 benefits are described in www.ipv6forum.com/navbar/papers/IPv6-an-Internet-Evolution.pdf, which was prepared by the IPv6 Forum, a leading global proponent of IPv6 deployment.
12 The “opportunity cost” of an action or choice is the net benefits associated with the next best alternative to the course of action adopted. For a more complete discussion of opportunity cost, see Michael Parkin, Economics 10, 53-56 (1990).
13 See, e.g., Eric Carmés, “The Transition to IPv6” (Internet Society Briefing #6), http://www.isoc.org/briefings/006/, which describes transitional mechanisms for IPv6 and briefly discusses problems inherent with the coexistence of IPv4 and IPv6 networks.
14 See Nokia’s Chinese website for IPv6 which has compiled a list of IPv6 enabled applications. This information can be viewed at http://www.ipv6.com.cn/technique/applications.html.
15 See U.S. Department of Defense, “Internet Protocol Version 6 (IPv6), www.dod.gov/news/Jun2003/d20030609nii.pdf.
16 See the Moonv6 Media page at http://www.iol.unh.edu/moonv6/ to view a presentation that gives more detail about this particular program.
17 Fednets are networks operated by the National Science Foundation, the Department of Defense, the National Aeronautics and Space Administration, and the Department of Energy. The Fednets coordinate closely to support participating agency missions and R&D requirements. See National Science and Technology Council, High Performance Computing and Communications Information Technology Frontiers for a New Millenium: A Report by the Subcommittee on Computing, Information, and Communications R&D (2000), www.ccic.gov/pubs/blue00.
18 The Abilene Network is an Internet2 high-performance backbone network that enables the development of advanced Internet applications and the deployment of leading-edge network services to Internet2 universities and research labs across the country. See abilene.internet2.edu/about/.
a 2002 presentation by Toshihiko Shimokawa entitled “IPv6 status of
20 See, e.g., www.europa-web.de/europa/03euinf/39INFTEC/ecresult.htm.
21 See www.ipv6net.tn/.
22 Network externalities arise from the fact that the value of a network to its users typically increases with the number of people that can access the network. Similarly, networking effects arise from the fact that the value of a network also increases with the number of individuals actually using the network. When a consumer decides whether to purchase and use a networked product or service (such as an IPv6-capable device), that person considers only the personal benefits of that purchase, and ignores the benefits conferred on all other users (e.g., those users who may now have a new opponent in a IPv6-based gaming service). The individual may choose not to purchase the networked product or service, even though that purchase may have increased overall economic welfare. In consequence, deployment of the service (and the equipment and technologies that make that service possible) will be less than it "should" be. See Parkin, note 12 supra, at 504-510; Robert Willig, “The Theory of Network Access Pricing” in Issues in Public Utility Regulation 109 and n.2 (H. Trebbing ed. 1979).
23 See, e.g., Paul Stone, The Economics of Technology Diffusion (2002).
24 Public goods are characterized by consumption nonrivalry, in that one person’s consumption does not reduce the amount of the good available to others. More importantly, public goods are characterized by nonexcludability, in that no individual can be prevented from enjoying the benefits provided by a public good. Nonexcludability creates the problem of “free riders,” who can enjoy the benefits of a public good without paying the costs of providing it. Moreover, the producer’s inability to exact payment from free riders may prevent the producer from fully recovering costs. For these reasons, market forces alone tend to “under produce” public goods. See Parkin, note 12 supra, at 499-503.
25 See Joseph Stiglitz, Economics of the Public Sector (1988).
26 See Section IV.B.2 supra.