###### Before the

###### UNITED STATES DEPARTMENT OF COMMERCE

**National Telecommunications and Information Administration**

**Washington, DC 20230**

**In the Matter of: )**

**)**

**Deployment of Internet Protocol, ) Docket No. 040107006-4006-01**

**Version 6 )**

**)**

**MCI COMMENTS**

WorldCom, Inc. d/b/a MCI (MCI) hereby submits its comments on the
Department of Commerce's Notice of Inquiry (Notice) concerning issues
implicated by the deployment of Internet Protocol version 6 (IPv6) in
the United States.

The Notice was issued by the Department of Commerce in response to the
President's *National Strategy to Secure Cyberspace*, which directs the
Department 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."[^1] The *National Strategy* emphasizes that the reliability
and secure use of the Internet Protocol (IP) are essential to the
security of the Internet infrastructure.[^2]

The Task Force, which is co-chaired by the National Institute of
Standards and Technology (NIST) and the National Telecommunications and
Information Administration (NTIA), has issued the Notice in order to
solicit comments on (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.[^3] According to the Notice, any submitted comments
will be used as input to the Task Force's interim report, which is to be
discussed at a public roundtable meeting to be held in the first half of
2004.[^4]

MCI's comments reflect its experience as a leading provider of IP-based
services. Today, MCI offers IP-based services at speeds from dial to
OC-48 over the farthest-reaching global IP network, a 98,000-mile global
fiber optic network that spans more than 4,500 Points of Presence (POPs)
throughout the world. MCI is also a pioneer in the deployment of IPv6,
having offered IPv6 services over its very high speed Backbone Network
Service (vBNS+) since 1998.

**II. Benefits and Costs of IPv6**

In order to assess the likely course of IPv6 deployment, the Task Force
asks parties to compare the benefits of IPv6 to the costs of deploying
IPv6, including the "transition" costs of introducing IPv6

**A. Address Space**

The most significant benefit offered by IPv6 is its capability to
dramatically increase the number of computers connected to the Internet
without relying on Network Address Translators (NATs).

As is discussed in the Notice, IPv4 address availability is limited by
both the size of the IPv4 "address space" and by past address assignment
practices. Although there has been considerable debate about the precise
date on which the IPv4 address space will be depleted, the need to
conserve IPv4 addresses has already had a signficant impact on the
architecture of the Internet. In place of the "peer-to-peer"
architecture envisioned by the IPv4 protocol designers, network
operators have inserted NATs throughout the Internet in order to share
public IPv4 addresses among multiple computers.

Although NATs have allowed the Internet to continue growing despite
limitations on the availability of IPv4 addresses, the introduction of
NATs has had a number of negative side effects. In particular, it has
been MCI's experience that NATs make it more difficult to deploy new
Internet applications: because NATs are tailored to existing
applications, new applications can often be introduced only by
reconfiguring NATs or through workarounds that may not work in all
cases. Fundamentally, an Internet that relies on NATs is more complex
and less flexible than an Internet in which each computer has its own
unique address.

Because the IPv6 address space is so much larger than the IPv4 address
space, a virtually unlimited number of computing devices could be
connected to the Internet without the use of NATs. Such a significant
expansion of the address space is likely to be necessary to accommodate
the expected proliferation of wireless data devices, computers connected
to "always-on" cable modem and DSL services, and other new types of
computing devices. And by creating a NAT-free infrastructure, IPv6 would
provide a flexible platform for the development of new applications.

**B. Security and Other Benefits**

In addition to the expanded IP address space, IPv6 offers a number of
additional features. These features include simplified network
management, more efficient routing, improved support for
class-of-service, and improved support for mobile devices. The inclusion
of these features reflects experience gained in operating IPv4 networks
over the past two decades.

One of the features of IPv6 that has attracted significant attention is
the potential for improved network security. In particular, the
President's *National Strategy to Secure Cyberspace* cites the improved
security features of IPv6 in its discussion of measures that could be
taken to develop "secure and robust mechanisms that will enable the
Internet to support the Nation's needs now and in the future."[^5]

The network security improvements offered by IPv6 fall into two
categories. First, IPv6 networks are potentially more robust than
today's NAT-reliant networks. NATs are a point of vulnerability in the
network: typically, if a NAT fails, all connections that are set up
through that NAT are lost even if there is an alternate physical path.
The vulnerability of communications to such NAT failures is at odds with
the original objectives for the Internet, which was designed to allow
communications to be routed around points of failure.

Second, IETF standards require that all implementations of IPv6 include
IPsec, which is a suite of protocols that define mechanisms for
authenticating and encrypting IP packets. Although IPsec is compatible
with IPv4, the "mandatory" inclusion of IPsec in the IPv6 specification
is expected to result in far wider distribution of IPsec-capable
computers. Moreover, "end-to-end" security protocols such as IPsec are
difficult to deploy in many IPv4-based networks because of the
widespread use of NATs in such networks.

**III. Status of IPv6 Deployment**

Much of the groundwork has been laid for commercial deployment of IPv6.
Although work continues on IPv6-related topics within the IETF, the core
IPv6 specifications have been finalized and are sufficiently complete to
support initial commercial implementations of IPv6. IPv6 has been tested
extensively in a variety of research networks, both in the United States
and around the world. Those testbeds have allowed researchers to
investigate IPv6 protocol implementations and, more recently, operations
and transition issues as well.

The translation of IETF standards and the experience gained from
research testbeds into commercial deployment is slowly beginning to
occur. For example, MCI offers IPv6 services to government customers
over its vBNS+.[^6] Software and network equipment vendors are
increasingly implementing IPv6 in their products. Most key software
vendors now include IPv6 implementations in their operating system
software. And the availability of IPv6-capable routers and other network
equipment is growing steadily.

In deploying IPv6, MCI is drawing on its years of experience providing
IPv6 services over the vBNS+. A key consideration for MCI is ensuring
that IPv6 services meet the performance requirements of commercial
customers. In order to continue providing the service level agreements
(SLAs) that commercial customers have come to expect, commercial IPv6
services require not only upgrades to routers, but also upgrades to
network management and monitoring. Moreover, commercial-quality services
require careful attention to the interworking and coexistence of IPv4
and IPv6. MCI expects that IPv4 and IPv6 will coexist for many years to
come.

**IV. Government's Role**

In the Notice, the Task Force asks whether government should be involved
in fostering or accelerating the deployment of IPv6 and, if so, what
actions government should take.

Although the deployment of IPv6 has occurred more slowly than was
anticipated when the IETF began work on IPv6, there is no evidence of a
market failure warranting government intervention. To a great extent,
the current pace of IPv6 deployment reflects the normal weighing of
benefits and costs that is associated with any technology deployment.
Although IPv6 offers significant benefits over IPv4, particularly when
the disadvantages of NATs are taken into account, it is clear that the
use of NATs made access to the larger IPv6 address space less urgent.
Moreover, the costs of IPv6 deployment are significant: as discussed
above, the deployment of commercial-grade IPv6 services by ISPs is a
complex undertaking. Similarly significant are the costs of developing
new applications or porting existing applications to work with IPv6.

Notwithstanding these considerations, it is probable that demand for
IPv6-based services will grow over the short- and medium-term and that
deployment of IPv6 will accelerate as customers and service providers
develop applications that make full use of IPv6's capabilities. Of
particular significance is the growing presence of IPv6 implementations
in operating system software. As more and more computers become
IPv6-capable, it becomes more likely that customers will develop
applications that use IPv6's capabilities and will thus generate demand
for IPv6 services. And as ISPs respond to that demand by expanding their
IPv6 offerings, those expanded offerings will in turn spur the
development of additional applications that take advantage of those
offerings.

A second key trend that has the potential to drive demand for IPv6
services is the proliferation of wireless data devices and devices
attached to "always-on" connections such as cable modems and DSL. The
expected growth in the number of such devices, coupled with the fact
that some potential applications for such devices require that each
device be assigned a unique address, is likely to require the much
larger IPv6 address space. For example, the wireless industry's Third
Generation Partnership Project (3GPP) is making use of IPv6 in the 3GPP
standards. Moreover, growth in the number of computers connected to
"always-on" services such as cable modem and DSL is likely to drive
demand for "end-to-end" security of the type offered by IPsec within
IPv6.

Even without direct government intervention, the federal government will
play a key role in influencing the pace of IPv6 deployment, in its
capacity as a significant customer for IP-based services and equipment.
As is demonstrated by the Department of Defense's recent announcement
concerning IPv6, federal agencies may find that security requirements
and other factors necessitate planning for IPv6. In its announcement,
DoD explained that it found IPv4 to be "incapable of meeting the
long-term requirements of . . . DoD,"[^7] and cited benefits of IPv6
such as improved security and "new enhancements to quality of service
and easing system management burdens."[^8]

Because of IPv6's improved support for IPsec, the early adoption of IPv6
by federal agencies would be fully consistent with the *National
Strategy to Secure Cyberspace*. As the *National Strategy* emphasizes,
"federal agencies should become early adopters of new, more secure
systems and protocols where appropriate."[^9]

Once IPv6 begins to be more widely deployed, the Task Force should
assess whether that deployment is meeting the goals of the *National
Strategy to Secure Cyberspace*. Although it is "mandatory" for IPv6
implementations to support IPsec, there is no requirement that IPsec
actually be used. The extent to which IPsec is used will depend on a
variety of factors, including the security policies adopted by the
communicating parties, the availability of alternate security
mechanisms, the interoperability of IPsec implementations, and the
development of effective key distribution mechanisms. As part of its
mandate, the Task Force should continue to monitor the deployment of
IPv6 to determine the extent to which the potential for improved network
security is being met.

**V. Conclusion**

Although the deployment of IPv6 will involve significant costs, the
benefits of IPv6 over IPv4 are sufficiently important that it is
probable that demand for IPv6 products and services will grow in the
coming years. It is also probable that federal agencies will play a
significant role as early adopters of IPv6.

Respectfully submitted,

WORLDCOM, INC. d/b/a MCI

/s/ Alan Buzacott

Alan Buzacott

Senior Manager, Reglatory Affairs

1133 19^th^ Street, N.W.

Washington, DC 20036

\(202\) 887-3204

March 8, 2004

[^1]: *The National Strategy to Secure Cyberspace,* February, 2003 at
    30.

[^2]: *Id*.

[^3]: Notice at 1.

[^4]: *Id.* at 3.

[^5]: *National Strategy* at 30.

[^6]: *See* http://www.vbns.net/;
    http://global.mci.com/us/enterprise/govt

    /federal_solutions/resource_guide/rg_products/vbns/

[^7]: DoDD 8100.1 Global Information Grid Overarching Policy, September
    19, 2002, at 1.

[^8]: *Id*.

[^9]: *National Strategy* at 43.