Department of Commerce

Response to Notice of Inquiry

Prepared by:

NTT/VERIO

8005 S. Chester St, Suite 200

Englewood, CO 80112

March 8, 2004

Please comment on the adequacy of IPv4 address space.

In accordance with a United Nation (UN) 2002 report, the Earth’s population is estimated to be 6.3 billion. Without considering the H-ratio, the IPv4 32 bit address space is inadequate to support 1/3 of the Earth’s population after factoring in the unusable IPv4 space such as the RFC 1918 private address block (10/8, 172.16/12, 192.168/16), the loopback address block (127/8) and reserved address space for uses such as multicast (224/3). Further, this UN report expects the population to increase by 2.6 billion during the next 47 years, to 8.9 billion in 2050 from 6.3 billion in 2002. The Internet architecture will need to accommodate growth in population and the quantity of devices which will be “naturally” connecting to the Internet; such as PDAs, cell phones and eventually, appliances.

China suffers from serious IP address shortages. Statistics show that currently, China has more than 60 million Internet users, but only 30 million-odd IPv4 addresses to be used by their populace, approximately two users for each IP address. Meanwhile, this nation's 240 million mobile phone users are turning into potential Internet surfers and as a result, need their own IP addresses. This inadequate supply of IP address is causing a bottleneck for Internet development within China.

The TCP/IP protocol suite was developed under DARPA in the late 60s and early 70s. The lion’s share of IPv4 address space was allocated within the United States. Other countries received a disproportionate and smaller blocks of IPv4 space. The Internet Engineering Task Force (IETF), through standards actions, defined the IPv4 standard that created the 32-bit addressing scheme yielding 4.4 Billion IP addresses. Of total address space, the IETF allocated a portion of the total address space (256/8s) for Unicast 86.3% (220/8s), Multicast, 6.2% (16/8s), and reserved 7.5% (20/8s) address space. The Unicast IP address allocation was delegated to Internet Addressing and Numbers Authority (IANA). The Regional Internet Registrars (RIRs – American Registry for Internet Numbers (ARIN) [US], (Réseaux IP Européens Network Coordination Center - RIPE NCC) [Europe], and Asia-Pacific Network Information Center (APNIC) are the organizations who allocate the address space to ISPs.

IANA Allocations

As of December 2003, IANA has allocated 51% (51 /8s) of the Unicast address space. This address space is in use by numerous organizations globally. IANA has a reserve pool of 35% - 89/8s, for future allocation to the RIRs. The balance of the IP space is reserved by the IETF, 7% -19/8s, for experimental or other specialized uses and 6% -16/8s for Multicast uses. With estimated current growth rates, the IANA and RIPE studies predicts IPv4 address space will be exhausted between the years, 2019 and 2045. Further, this study targets a depletion window of 2019-2045, while the IANA is predicting it will exhaust it’s pool of IPv4 address in the year 2020, and the RIRs will exhaust the pool of IP space allocated by IANA in the year 2027. However, this data is based on historical growth and does not take into account the population growth mentioned in the UN study, the China study nor the global growth of Ground Services Mobile (GSM), other wireless or mobile IP services, and other types of mobile hardware devices. The RIPE study acknowledges that predicted dates of exhaustion are wide because of poor initial data collection and analysis.

Total Allocations – Projection of “/8s”

Based IPv4 historical data, IPv4 address space will be exhausted by the year 2047. Including the growth of cell phones, PDAs, mobile IP and other devices, estimations are closer to 2025.

The following IP space under APNIC allocation authority has been allocated to the countries as depicted in the chart below:

IPv4 Allocations – Distribution by Nation