[Federal Register Volume 69, Number 13 (Wednesday, January 21, 2004)]
[Notices]
[Pages 2890-2899]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 04-1154]


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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, U.S. Department of 
Commerce.

ACTION: Notice of inquiry.

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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., NW., 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: 
[email protected]. 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.

SUPPLEMENTARY INFORMATION:

I. Background

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.\1\
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    \1\ 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.
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    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

[[Page 2891]]

addresses and additional user features and applications.\2\ 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.\3\
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    \2\ Background information concerning the history of the 
Internet can be found at http://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), http://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.
    \3\ For the purposes of this Notice, IPv6 can be defined with 
reference to IETF Request for Comments (RFCs) that contain the 
relevant standards. See http://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.
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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.\4\
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    \4\ The National Strategy to Secure Cyberspace, A/R 2-3, at 30 
(Feb. 2003), http://www.whitehouse.gov/pcipb/cyberspace_strategy.pdf.

    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.

C. Request for Comment

    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 U.S. government in the deployment 
of IPv6?
    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.\5\ By expanding the existing IP address field to 
128 bits, IPv6 offers a vast pool (3.4 x 10 38) 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.
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    \5\ 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. http://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.
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    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 United States, as well as users in other 
countries around the world.\6\ We recognize that, because a large 
portion of the available IPv4 addresses have been allocated to North 
America, concerns regarding address availability may differ depending 
on the commenter's perspective. We therefore ask commenters to discuss 
how the purported limitations on IPv4 addresses will affect different 
geographic regions (e.g., North America, Europe, Asia) and customer 
markets (e.g., private sector, government, academia).
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    \6\ See, e.g., Geoff Huston, ``IPv4 Address Lifetime 
Expectancy--2003 http://www.apnic.net/community/presentations/docs/ietf/200307/v4-lifetime-20030715.ppt.
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    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

[[Page 2892]]

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.
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    \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.
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    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?
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    \8\ ``Spoofing'' refers to the creation of Internet packets 
using someone else's Internet address. See, e.g., Matthew Tanase, 
``IP Spoofing: An Introduction,'' http://www.securityfocus.com/infocus/1674.
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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.
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    \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.

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[[Page 2893]]

    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?
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    \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).
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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.
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    \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 http://www.ipv6forum.com/navbar/papers/IPv6-an-Internet-Evolution.pdf, which was prepared by 
the IPv6 Forum, a leading global proponent of IPv6 deployment.
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    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

[[Page 2894]]

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 U.S., relative to the rest of the world, 
influence costs and prices of IPv6 equipment, services, and 
applications? For example, will costs and prices decrease over time as 
a function of the worldwide IPv6 installed base? Could waiting for 
international development and deployment of IPv6 lead to reduced R&D 
costs and fewer security problems for U.S. adopters? Would the U.S. 
benefit from lessons learned by early adaptors or will there be minimal 
knowledge spillovers? Conversely, will late entry into global IPv6 
markets by U.S. firms have a significant long-term negative effect on 
market shares and economic performance? What is the impact of slow IPv6 
deployment on the development of native IPv6 applications?
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    \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).
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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 U.S. from the benefits of foreign IPv6 deployments 
and/or testbeds?
---------------------------------------------------------------------------

    \13\ 13 See, e.g., Eric Carmes, ``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.
---------------------------------------------------------------------------

    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

[[Page 2895]]

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?
---------------------------------------------------------------------------

    \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.
---------------------------------------------------------------------------

B. Private Sector and Government Deployment Efforts

1. Overall Domestic Efforts
    The task force seeks specific comment on the status of IPv6 
deployment efforts in the United States. First, we seek comment on the 
availability of IPv6 products and services. Are technology suppliers 
producing the necessary hardware, software, applications, training, and 
any other products and services in sufficient quantity to meet the 
demand for IPv6 in the United States? We ask commenters to identify the 
relevant product and service categories and to describe the breadth and 
depth of offerings in those categories. For example, is the market for 
IPv6 routers characterized by multiple suppliers offering a variety of 
products, or does only a single supplier produce only a limited number 
of products? To the extent any relevant products and services are not 
available or are in limited supply, we seek information about their 
projected availability in the future, including analysts' estimates and 
suppliers' business plans.
    Second, the task force seeks comment on the actual deployment of 
IPv6 products and services in the United States. To the extent 
possible, we ask commenters to provide specific information on the 
status of IPv6 deployment across product and service categories (e.g., 
hardware, software) and across customer segments (e.g., private sector, 
government, academia). For example, how many enterprise network routers 
are currently IPv6-capable? How many public or backbone network routers 
are IPv6-capable? How does U.S. router deployment compare with other 
countries? How many ISPs are currently capable of handling IPv6 
traffic? What percentage of Internet access customers receive IPv6 
capable services? What proportion of end-user equipment (e.g., 
computers, wired and wireless end-user devices, cable modems, DSL 
modems, printers and other peripheral equipment, and other devices) is 
capable of handling IPv6 packets? To the extent that such capability is 
only provisioned in such devices, how easy/costly will it be for users 
to activate that capability? How many of the critical functions within 
an enterprise are IPv6 enabled (e.g., DNS, wireless firewalls)?
    Third, we seek comment on the projected growth of IPv6 products and 
services in the United States. We ask

[[Page 2896]]

commenters to provide all relevant assumptions and underlying data that 
support their growth projections. To the extent possible, we ask 
commenters to provide growth projections for specific products and 
services, as well as projections among customer segments.
2. Domestic Government Efforts
    The task force seeks comment on federal, state, and local 
government efforts to deploy IPv6 in the United States. For example, 
the Department of Defense (DoD) has announced plans to migrate its 
existing Global Information Grid Network to IPv6 by 2008.\15\ 
Additionally, DoD recently initiated a multivendor testbed, known as 
``Moonv6,'' to examine the interoperability of IPv6 equipment, 
software, and services under real-world conditions. Involving more than 
30 networking vendors, testing vendors, and service providers, the 
project purportedly will be the most substantial test of the IPv6 
standard set in North America.\16\ We seek comment on any lessons 
learned to date from DoD's efforts to deploy IPv6 that could be applied 
to federal civilian agencies, state and local governments, academia, 
and the private sector. We seek similar comment on other IPv6 research 
efforts and testbeds, including IPv6 deployments in federal research 
networks (Fednets),\17\ the Abilene backbone network,\18\ and any other 
similar efforts. We ask commenters to identify the costs of these 
efforts and the expected effects these activities may have on the 
deployment of IPv6 within the United States?
---------------------------------------------------------------------------

    \15\ See U.S. Department of Defense, ``Internet Protocol Version 
6 (IPv6), http://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), http://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/.
---------------------------------------------------------------------------

    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. Japan 
and Korea plan to have IPv6 fully deployed before the end of this 
decade.\19\ The European Union has developed substantial IPv6 plans and 
programs to ensure readiness and competitiveness when IPv6 is widely 
deployed.\20\ Additionally, we understand that other countries such as 
Tunisia are engaged in substantial IPv6 deployments.\21\
---------------------------------------------------------------------------

    \19\ See, e.g., a 2002 presentation by Toshihiko Shimokawa 
entitled ``IPv6 status of Japan,'' which describes the development 
of IPv6 in Japan, including information on government and private 
sector activities. This presentation is available at http://genkai.info/2002-1004/materials/toshi.ppt. For information about 
Korea's plans with respect to IPv6, see Gene Kowprowski, ``Internet 
Protocol for the Future: Ipv6 Poised for Adoption,'' TechNews World 
(Jul. 30, 2003).
    \20\ See, e.g., http://www.europa-web.de/europa/03euinf/39INFTEC/ecresult.htm.
    \21\ See http://www.ipv6net.tn/.
---------------------------------------------------------------------------

    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 United States 
prefer to rely on market forces for the large-scale deployment of new 
technologies. In most cases, reliance on the market tends to produce 
the most efficient allocation of resources, the greatest level of 
innovation, and the maximum amount of societal welfare. Accordingly, we 
seek comment on whether market forces alone will be sufficient to drive 
a reasonable and timely level of IPv6 deployment in the United States. 
For example, given commenters' views on the current and predicted rates 
of IPv6 deployment, do commenters believe those rates demonstrate a 
sufficient uptake of IPv6 in the United States? We ask commenters to 
identify the specific reasons for their positions.
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

[[Page 2897]]

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 United States. 
Although we are not currently aware of any concerns regarding monopoly 
power, such a situation could arise from the existence of a dominant 
firm or group of firms in the relevant markets with the incentive to 
impede normal dissemination of IPv6, either by directly suppressing the 
technology or by setting excessive prices for IPv6 products and 
services. We therefore seek comment on whether any firm or firms have 
monopoly power for IPv6 products and services, and how the exercise of 
such monopoly power will affect IPv6 deployment in the United States.
    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 U.S. market for domestic firms who want to compete 
in global markets?
---------------------------------------------------------------------------

    \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).
---------------------------------------------------------------------------

    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.
---------------------------------------------------------------------------

    \23\ See, e.g., Paul Stone, The Economics of Technology 
Diffusion (2002).
---------------------------------------------------------------------------

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 in the United States. To the extent possible, we ask 
commenters to provide specific, factual examples of any such 
impediments and to describe how those impediments are affecting 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

[[Page 2898]]

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.
---------------------------------------------------------------------------

    \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.
---------------------------------------------------------------------------

a. Security

    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 United States? In 
responding to theses questions, interested parties should explain the 
specific security interests to be furthered and how they would be 
advanced by wide scale deployment of IPv6.
---------------------------------------------------------------------------

    \25\ See Joseph Stiglitz, Economics of the Public Sector (1988).
---------------------------------------------------------------------------

    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 U.S. 
government action to support domestic IPv6 warranted and appropriate in 
order to preserve the competitiveness of U.S. businesses 
internationally? In this regard, we understand that U.S. firms are 
currently major providers of IP equipment, services, and applications. 
We also understand that many have developed or are developing IPv6 
capabilities for their products and services. We further understand 
that some U.S. firms appear to be selling equipment in many of the 
countries (e.g., Korea, Japan, China) that ostensibly are most 
committed to IPv6 deployment. Given these understandings, we seek 
comment on how the competitiveness of U.S. equipment firms and service 
providers would be adversely affected by slower deployment of IPv6 
domestically?
    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 United States (with consequent loss of economies of scale 
and scope) could conceivably reduce the competitiveness of American 
firms in various export markets vis-[agrave]-vis companies from 
countries that have deployed IPv6 more aggressively. We request comment 
on this supposition and, particularly, on the nature and magnitude of 
the cost advantages that use of IPv6 (as opposed to IPv4) may confer on 
a company in a global market context.

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 in the 
U.S., one possible U.S. government action would be to let market forces 
guide the diffusion of IPv6 into existing and future markets. The task 
force requests comment on the appropriateness of this non-intervention 
approach. Commenters should address the potential costs to the U.S. 
economy if government inaction results in a domestic implementation of 
IPv6 that lags other industrialized nations.
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 U.S. economy, we also request comments regarding how, when and in 
what form such action should take. What factors and market information 
should government consider in order to determine that the market-driven 
rate of IPv6 deployment in the U.S. is insufficient, thereby 
necessitating government intervention? Should government intervene 
early to stimulate deployment? Should it allow the market to drive 
deployment forward, and concentrate government efforts on assisting or 
encouraging those individuals and enterprises that are the slowest to 
adopt IPv6? To what extent, if at all, should the timing of government 
intervention differ with respect to private sector deployment of IPv6, 
as compared to its adoption by federal, state and local government?

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

[[Page 2899]]

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 
Abilene \26\ 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)?
---------------------------------------------------------------------------

    \26\ See Section IV.B.2 supra.
---------------------------------------------------------------------------

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.
[FR Doc. 04-1154 Filed 1-20-04; 8:45 am]
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