Department of Commerce Response to Notice of Inquiry

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Department of Commerce Response to Notice of Inquiry Department of Commerce Response to Notice of Inquiry Prepared by: NTT/VERIO 8005 S. Chester St, Suite 200 Englewood, CO 80112 March 8, 2004 - 1 - March 8, 2004 Please comment on the adequacy of IPv4 address space. In accordance with a United Nation (UN) 2002 report, the Earth’s population is estimated to be 6.3 billion. Without considering the H-ratio, the IPv4 32 bit address space is inadequate to support 1/3 of the Earth’s population after factoring in the unusable IPv4 space such as the RFC 1918 private address block (10/8, 172.16/12, 192.168/16), the loopback address block (127/8) and reserved address space for uses such as multicast (224/3). Further, this ?UN report expects the population to increase by 2.6 billion during the next 47 years, to 8.9 billion in 2050 from 6.3 billion in 2002. The Internet architecture will need to accommodate growth in population and the quantity of devices which will be “naturally” connecting to the Internet; such as PDAs, cell phones and eventually, appliances. China suffers from serious IP address shortages. Statistics show that currently, China has more than 60 million Internet users, but only 30 million-odd IPv4 addresses to be used by their populace, approximately two users for each IP address. Meanwhile, this nation's 240 million mobile phone users are turning into potential Internet surfers and as a result, need their own IP addresses. This inadequate supply of IP address is causing a bottleneck for Internet development within China. The TCP/IP protocol suite was developed under DARPA in the late 60s and early 70s. The lion’s share of IPv4 address space was allocated within the United States. Other countries received a disproportionate and smaller blocks of IPv4 space. The Internet Engineering Task Force (IETF), through standards actions, defined the IPv4 standard that created the 32-bit addressing scheme yielding 4.4 Billion IP addresses. Of total address space, the IETF allocated a portion of the total address space (256/8s) for Unicast 86.3% (220/8s), Multicast, 6.2% (16/8s), and reserved 7.5% (20/8s) address space. The Unicast IP address allocation was delegated to Internet Addressing and Numbers Authority (IANA). The Regional Internet Registrars (RIRs – American Registry for Internet Numbers (ARIN) [US], (Réseaux IP Européens Network Coordination Center - RIPE NCC) [Europe], and Asia-Pacific Network Information Center (APNIC) are the organizations who allocate the address space to ISPs. IETF Reserved, 20.1, 8% Multicast, 16, 6% IANA Allocated, 130.9, 51% IANA Pool, 89, 35% IANA Allocations - 2 - March 8, 2004 As of December 2003, IANA has allocated 51% (51 /8s) of the Unicast address space. This address space is in use by numerous organizations globally. IANA has a reserve pool of 35% - 89/8s, for future allocation to the RIRs. The balance of the IP space is reserved by the IETF, 7% -19/8s, for experimental or other specialized uses and 6% - 16/8s for Multicast uses. With estimated current growth rates, the IANA and RIPE studies predicts IPv4 address space will be exhausted between the years, 2019 and 2045. Further, this study targets a depletion window of 2019-2045, while the IANA is predicting it will exhaust it’s pool of IPv4 address in the year 2020, and the RIRs will exhaust the pool of IP space allocated by IANA in the year 2027. However, this data is based on historical growth and does not take into account the population growth mentioned in the UN study, the China study nor the global growth of Ground Services Mobile (GSM), other wireless or mobile IP services, and other types of mobile hardware devices. The RIPE study acknowledges that predicted dates of exhaustion are wide because of poor initial data collection and analysis. Total Allocations – Projection of “/8s” 224 192 160 128 96 64 32 0 Jan- Jan - Jan- Jan- Jan- Jan- Jan - Jan- Jan- Jan- Jan- Jan- Jan- Jan- Jan- Jan- 96 98 00 02 04 06 08 10 12 14 16 18 20 22 24 26 Based IPv4 historical data, IPv4 address space will be exhausted by the year 2047. Including the growth of cell phones, PDAs, mobile IP and other devices, estimations are closer to 2025. The following IP space under APNIC allocation authority has been allocated to the countries as depicted in the chart below: - 3 - March 8, 2004 IPv4 Allocations – Distribution by Nation AP 1% AU MY PH CN 13% 1% NZ TW 20% 1% 1% 7% TH ID 1% 1% Other SG OTHER 14% 1% 1% KR 21% IN HK 2% JP 3% 26% Country Codes: AU – Australia IN – India PH – Philippines AP – Other Asia Pacific JP – Japan SG – Singapore CN – China KR – South Korea TH – Thailand HK – Hong Kong MY – Malaysia ID – Indonesia NZ – New Zealand - 4 - March 8, 2004 Estimate (and underlying assumptions) 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. Current estimates for IPv4 address “exhaustion” range from the year 2005 to 2010 and beyond. Estimates are very sensitive to factors such as 3G service addressing architecture, 3G service growth, xDSL and cable modem adoption. The important fact is IPv4 addresses will continue to become harder to obtain, especially where new services such as streaming video and mobile PC phones require large numbers of addresses for initial deployment. The data below factors in anticipated growth rates of subscribers utilizing GSM, cable modems and DSL. As of April 18, 2001, the IPv4 address space currently allocated to RIRs for further allocation to customers are: · RIPE – 7 x /8s · ARIN – 13 /8s · APNIC – 6 x /8s Total remaining IPv4 space available for allocation to RIRs is 103/8s. Demand Forecast for IPv4 space for GSM service: The table below shows the total number of GSM Subscribers (in Millions) broken down by regions: Actual Forecast 2001 2002 2003 2004 2005 2006 2007 Total 627.8 796.0 941.3 1080.0 1204.1 1309.6 1393.0 Africa 26.2 36.9 51.1 70.4 94.4 121.2 146.0 South 4.5 8.4 11.9 17.5 24.0 30.8 37.2 America Asia Pacific 226.1 313.9 381.5 447.5 505.6 552.5 587.0 Eastern 48.5 73.4 97.1 119.1 135.0 144.6 150.0 Europe Western 298.6 328.4 355.2 370.4 379.4 385.0 388.9 Europe Middle East 11.4 17.4 23.8 31.5 39.3 46.8 53.0 USA/Canada 12.5 17.6 20.6 23.7 26.4 28.7 30.9 Source: EMC World Cellular Database, May 30, 2003 - 5 - March 8, 2004 Global Cellular IP address (Millions) IPv4 address demand (based on terminal demand) 01/02 02/03 03/04 04/05 05/06 Exhaustion Scenario 759 919. 1060 1177 1274 Worst Case 531.6 643.9 742.2 823.6 891.5 Most Likely 80 92 106 118 150 Best Case Source: RIPE, April 2001 estimate DSL + Cable Modem (Millions) Global Growth Forecast 01/02 02/03 03/04 04/05 05/06 Exhaustion Scenario 88 182 266 329 408 Worst Case 44 91 133 165 204 Most Likely 9 18 27 33 41 Best Case Note: Carriers and industry analysts are significantly increasing their estimates of DSL deployments. These figures need to be revised upwards. Summary of Exhaustion dates (based on projections for terminal and lines, not IP addresses): Best Case (late exhaustion): · 2014 (for 84 x /8s) · 2018 (for 103 x /8s) Most Likely Case: · End 2010 (for 84 x /8s) · End 2012 (for 103 x /8s) Worst Case (early exhaustion) · Mid 2005 (for 84 x /8s) · Mid 2006 (for 107 x /8s) Note: NAT proxy servers and DHCP (dynamic addressing) are factored into estimates above. - 6 - March 8, 2004 Over the past four years, both China and India have started an explosive user growth rate: Asia Pacific Internet User Population 100 90 80 Australia 70 China 60 Hong Kong India 50 Korea 40 Singapore 30 Taiwan 20 Other 10 0 1998 1999 2000 2001 2002 2003 2004 Source: Morgan Stanley Dean Witter - 7 - March 8, 2004 Discuss how the purported limitations on IPv4 addresses will affect different geographic regions (such as North America, Europe and Asia) and customer markets (such as the private sector, government and academia). , Asia) and customer markets (e.g., For the Asia Pacific region, the potential growth of population (per head) for China (CN), India (IN) and Indonesia (ID) are shown in the graph below: 25 I P 20 V 4 15 IN T ID 10 O CN T A 5 l 0 (/8) 0.01 0.02 0.04 0.08 0.16 IPv4 Ad dresses per Head Taiwan’s IPv4 growth rate - 8 - March 8, 2004 - 9 - March 8, 2004 Discuss potential uses for the 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? According to an IDC report, worldwide shipments of mobile telephones and personal Comment: This report is a little old at this point – can we find updated info or digital assistants (PDAs) with digital imaging capabilities will increase to 151 million by delete the date of the report? Should be the year 2006. less than 12 months old The global wireless market has exploded beyond expectation and the market is hungry for new and innovative services.
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