From:               Michael Dillon <memracom@yahoo.com>

To:                    <IPv6@ntia.doc.gov>

Date:                 Tue, Feb 10, 2004 11:38 AM

Subject:            IPv6 Deployment in the USA

1) Benefits and possible uses

A major benefit of IPv6 deployment is to release the

IP networking industry from the constraints of an

artificial shortage of addresses. The end result of

this artificial shortage has been an overstrong

interventionist role for ARIN (American Registry for

Internet Numbers). This has constrained the ways in

which businesses can deploy and use IP networking

technology which, in turn, stifles the market for

creative new communications services. IPv6 is not a

magic bullet but it does unleash the possibility of

creative uses for networks that would require large

numbers of addressable endpoints such as portable

communications devices (21st century cellphones) and

intelligent households. Imagine a world in which your

baby monitor can page you during an evening concert

when the decibel level passes a certain threshold.

This would require both baby monitor and

cellphone/pager to have unique addresses that can

communicate over the Internet. Similar scenarios might

involve a security service which monitors fire sensors

in commercial buildings in order to develop a

sophisticated profile of what constitutes "normal"

operations so that management can be alerted when

abnormal situations occur and intervene before

employee mistakes result in property damage events.

2) Current conditions regarding deployment of IPv6

Dividing the world into three regions, Asia-Pacific,

Europe and North America, it is fair to say that IPv6

deployment is most advanced in Asia-Pacific. Europe is

perhaps a year behind them and North-America is two to

three years behind Europe. This is not a good

situation to be in considering that the two major

manufacturers of IP networking equipment (Cisco and

Juniper) are both American companies. It creates a

vacuum into which Asian companies could expand

enabling them to eventually dominate Internet routing

and switching services. Because of the push into IPv6

by the populous Asian countries, the pressure on IPv4

addresses has greatly diminished and the projected

exhaustion point has moved from 2006 to approximately

2025. There is a danger that American companies will

interpret this as an excuse for not planning their

IPv6 strategy and when market demand for IPv6 does

materialize, offshore operators such as NTT will be in

a stronger position to meet that demand than U.S.

companies. The main role for the NTIA in regard to

IPv6 deployment should be to ensure that all American

companies have incorporated IPv6 into their strategic

plans and roadmaps and begun the process of

familiarization with IPv6. This would mitigate many

risks by ensuring that American companies could deploy

quickly when IPv6 market conditions mandate action.

3) Economic, technical and other barriers

There are no serious economic or technical barriers.

It is true that some money would need to be spent to

upgrade software such as operating system versions or

routing software, but such upgrades are already a

normal business expense and simply a matter of time.

On the technical side, it is true that some IPv6

software is not as fully optimized as the IPv4

equivalent but this is mitigated to some extent by

more powerful hardware in both computers and routers.

Again, a prudent shift into IPv6 through phased

deployment is both economically and technically

possible today. The major barrier to implementation is

psychological. Both technologists and managers are too

comfortable with the status quo and are not willing to

put the required effort into continued learning and

knowledge aquisition. This is not something that can

be easily changed by government because it is an

inherent characteristic of the larger organizations

which now dominate the Internet. ISPs have merged with

telcos, router and switch manufacturers have

consolidated, and even large enterprise users of

networked communications have experienced a lot of

consolidation. The role of government should be to

focus on supporting the innovative small firms who

fill the same position in the network ecology that

ISPs filled in the 1994-1996 timeframe when the

Internet grew 1500% per year. In particular,

continuing technology trends have sparked new markets

involving so-called embedded devices in which the

computer is merely a means toward and end, not the be

all and end all of the device. Consider some of the

latest cellphones with integrated pagers, digital

cameras and gameplaying. Or the home Internet gateway

routers that are more powerful than an Internet

backbone router from Cisco in 1994. It is quite

possible to evolve an IPv4 network into IPv6

incrementally beginning with a small number of IPv6

customer services at the edge. The V6OPS working group

of the IETF is currently working on a draft RFC that

explains how the various transition scenarios can be

achieved and this document should be included in the

NTIA review.

4) Appropriate role for government

The government should collect and disseminate

information on IPv6. Government is the collective

represntation of a society and in this respect, the

government should ensure that society is aware of what

IPv6 is, what IPv6 could do for us, and that IPv6 is

available today for those entrepreneurs and early

adopters who will invest some effort. Government can

illuminate the road ahead and government can ask

questions of business leaders and of various domestic

non-governmental organizations. Government should help

to create a domestic IPv6 market by funding

appropriate research projects, supporting educational

institutions in offering IPv6 learning programs and by

demanding that all vendors of software and hardware

bidding on government contracts have a clearly

delineated roadmap to IPv6 that is published on their

websites. It is not yet appropriate for government to

require the use of IPv6 where the technology does not

provide clear benefits, but it is appropriate to

demand that vendors give some thought to future plans

and communicate those plans to the public and to the

government.

Thank you

--Michael Dillon

Internet user since 1992

In the ISP industry since 1994

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