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Ofcom in denial over UK IPv6 failure

For the UK to reap the economic and social benefits of next generation technology, like the Internet of Things, we need plenty of internet address space. The original addresses have run out, and we must implement IPv6. Experts say the UK has been more negative about the adoption of IPv6 than almost any other nation. Various initiatives aimed at stimulating adoption have fizzled out. The big ISPs convey a lack of urgency and Ofcom, rather than pushing industry to adopt, seems more focused on thinking of work-arounds. Why is our regulator failing to show leadership?

Vint Cerf, the inventor of the Internet, said at this year’s Internet Governance Forum, “You all deserve and need IP version 6 address space, so will you please push your Internet service providers to adopt it and make use of it so we will be ready for the Internet of Things.”

Far from ‘pushing’ UK ISPs to adopt IPv6, Ofcom seems to be focused on recycling second-hand IPv4 addresses, and using technical workarounds. Vint Cerf told me that won’t work. Worse, Ofcom envisions a national IPv4 address allocation scheme – something the British government has been resisting in international fora for years.

Disclaimer: I was part of a team commissioned by Ofcom to do two reports on IPv6 issues: Internet Protocol version 6 Deployment Study and Report on the Implications of Carrier Grade Network Address Translators. I had the privilege of working with a first rate team within Ofcom, and nothing in this article is intended to criticise any individual working for that organisation. I worked with colleagues on the IPv6 reports but, except where credited, the views expressed in this blog are personal and I am not speaking on behalf of any colleagues or clients. I am a director and shareholder of an ICANN accredited registrar, Oxford Information Labs Limited, which relies on IP addresses.

What is the Internet of Things?

The term Internet of Things describes intelligent objects connected to the Internet. Where your fridge orders more milk (or maybe says “I’m sorry, Dave, I’m afraid I can’t do that” in a HAL voice when you go for the ice cream), where sensors tell you that your basement is flooding, or your car tells your insurer that you’re a rubbish driver.

Cisco estimates that the Internet of Things will add more than 50 billion devices to the Internet by 2020. That’s on top of the billions of phones, tablets, laptops and desktops that are already connected. Whether you’re creeped out or excited about the idea of machines talking to each other, it’s already here, and prices are becoming more affordable.

What have IP addresses got to do with Internet of Things?

Each device connected to the Internet needs to be identified by a single IP address. The original internet address space (IPv4) ran out a few years ago. IPv6 is the replacement. The replacement technology, IPv6, offers unimaginably large address space. More than all the grains of sand on a beach, one hundred for every atom on the face of the earth. More than enough for 50 billion Internet things.

Trouble is, IPv6 is not backwards compatible with IPv4. Although the industry has known for years that it needs to migrate to the new standard, progress has been slow. Part of the problem has been the lack of a “killer app” to bring users into the IPv6 address space. The Internet of Things could be that “killer app”, as only IPv6 has the address space we need to move to the next generations of Internet technology.

Ofcom knows all this. In its recently published Infrastructure Report 2014, it devotes several paragraphs to the Internet of Things, discussing the impact on wireless spectrum (an area of responsibility for Ofcom). Even though the underlying research estimates that the UK will have more than 370 million connected “things” by 2022, there is only passing discussion of the need for address space.

IPv6 in the UK, a “lack of urgency”

Separately, the Infrastructure Report discusses the state of Internet addressing in the UK (page 166 ff). In fairness, Ofcom does devote a whole 5 paragraphs to IPv6 adoption, but the tone seems unhurried. Mobile operators are “generally looking to introduce IPv6”. Most major ISPs “told Ofcom they will be rolling out IPv6 addressing in the next 12 months.” No dates, no firm commitments.

The big ISPs are wrong

Vint Cerf

At recent industry meetings, network engineers from the big ISPs have conveyed a “lack of urgency” for IPv6 adoption, apparently favouring workarounds called Carrier Grade Network Address Translation (more of which later). I asked Vint Cerf what he thought about this, not imagining for a moment that he would actually reply. Like the gentleman he is, he wrote a full response by return. His words are blunt: “The big ISPs are wrong”. Nevertheless, it seems that the ISPs’ approach is gaining traction within Ofcom.

IPv6 adoption: the role of governments

In 2012, I was part of a team commissioned by Ofcom to evaluate the UK’s progress on IPv6 implementation. We concluded that on any measure, the UK is behind the curve. If you look at IPv6 success stories in other countries, they have one thing in common: their government has taken the lead.

This isn’t surprising, because IPv6 is one of those things that consumers are unlikely to be aware of, let alone ask their ISP for. It’s not a differentiator for services, and if ISPs are facing difficult financial decisions, then investment in upgrading infrastructure is often a tough one to sell.

If you look at IPv6 success stories in other countries, they have one thing in common: their government has taken the lead.

In some countries, IPv6 adoption has been mandated by regulation, but in many cases it has not. For example, in Sweden, the government just kept an eye on things, regularly held industry events and asked ISPs how IPv6 adoption was going. This soft approach was effective.

Second-hand IPv4 addresses for the UK?

On the evidence of Ofcom’s Infrastructure Report, it seems that officials have become excited at the idea of selling unused IPv4 address space. A study has discovered that the Ministry of Defence and the Department of Work and Pensions are each sitting on over 16 million unused IPv4 addresses. Ofcom notes that second-hand IPv4 addresses are changing hands for $10 “or more per address”, and muses “There may be ways to bring these unused blocks of addresses into efficient use; for example, by recycling them to other UK based access and service providers.”

The British Government is sitting on over 30 million unused IPv4 addresses

The underlying report by Jim Reid of RTFM is less than encouraging at this prospect, pointing to an array of legal, security, and technical obstacles:

  • Some of the addresses may be in use, for example in Ministry of Defence systems, and audits will be required to understand the extent of actual use. These are “likely to be expensive and time-consuming because large networks tend to be complicated and difficult to manage”.
  • “Significant security issues are expected”
  • The legal basis for releasing the legacy IPv4 address space is questionable. Reid highlights the risk that “the address holders do not legally own it”, and therefore may be unable to transfer it.

These significant costs and risks don’t really come through in the Ofcom summary. Neither is the economic question of whether the market price of $10 would be sustainable if the government decided to flood the market with over 30 million second hand IPv4 addresses.

What’s wrong with technical workarounds anyway?

Over the past couple of years, the big ISPs have begun experimenting with Carrier Grade Network Address Translation (CGN), the technical workaround ISPs use to extend the utility and life of their stock of IPv4 addresses. Essentially, CGN attaches large networks to the Internet using a small number of IPv4 addresses, so instead of each connection having a single IP address, many connections share IP addresses.

Geoff Huston of APNIC has been researching CGN, and estimates that 50% of today’s internet users are living with CGN, that 15% of European Internet traffic, and up to 50% of developing country traffic, is behind CGN. In the mobile industry, CGN has been in use for years. If you access the Internet on your smart phone, you’re probably using CGN. You didn’t die, did you? The Internet didn’t collapse, did it?

We know that implementing IPv6 is not simple, or cheap. So, why not just use CGN instead?

It is estimated that half of today’s internet users are affected by Carrier Grade Network Address Translation

Last year, Ofcom asked us to look at the technical and policy implications of CGN. Our report demonstrated that there are numerous problems:

  • Many modern applications, such as mapping and gaming don’t work with CGN.
  • CGN create real problems for law enforcement in identifying criminals.
  • CGN are not standardised, so mass adoption could erode innovation and competition.

Vint Cerf shares this view. He told me, “If you use [CGN], it is really messy to establish direct connections between the communicating devices. You need third party rendezvous or discovery of routable IPv4 addresses.”

So, what about mobile? David Holder explains: “In mobile, where CGN are widely deployed, there is usually one user, one device, use of mobile apps and low service expectations. In contrast, with fixed line, there are many users, many devices of different kinds, software and applications of many different kinds and much higher service expectations.”

CGN is really messy

Vint Cerf

What about the Internet of Things? It’s rumoured that some of the chip manufacturers are saying they’re happy to deploy through CGN. David Holder comments: “Of course they are going to say this! They don’t want their products to be limited only to areas that have v6 deployments.” He also points out that some Internet of Things manufacturers also manufacture CGN equipment.

Ofcom’s Infrastructure Report does acknowledge that CGN can be problematic, but it seriously downplays the issue. It advocates a mix of recycled IPv4 addresses and CGN as an alternative to implementing IPv6.

This view seems overly influenced by the ISP industry, by excitement at selling the second hand stock of IPv4. It seems to flirt with the idea that transition to IPv6 may be optional. That idea runs contrary to the evidence, Ofcom’s own projections for Internet of Things growth, and is even out of step with the views of ISPs and mobile operators.

ISPs and Mobile Operators: working with CGN is ‘horrendous’

I spoke with David Holder, one of the authors of Ofcom reports on IPv6 implementation. He recently organised a conference on IPv6 implementation. “We had mobile operators at the event. Both were scathing of CGN. They stated that they are deploying IPv6 to overcome the limitations of CGN. So using the widespread deployment of CGN in mobile networks to argue that CGN is a good solution is disingenuous. It was a necessary evil until IPv6 became widely available on web-sites and Internet services. Today, over 50% of a typical home user’s traffic can use IPv6”.

Mobile operators were scathing of CGN

David Holder

At the end of the conference, speakers from BT and Sky both announced that they would be rolling out IPv6 to consumers by the end of 2015, and the reason both gave was the poor performance of CGN.

National IP address plan – what will developing countries think?

The innocent little half sentence about “recycling” IPv4 addresses “to other UK based access and service providers” could unleash a world of pain. For the past 6 years or so, the UK Government and industry have been fighting a battle with the UN’s International Telecommunication Union (ITU) to stop the ITU’s plans to become a regional internet registry. The ITU wants to supply IP addresses to its members (national governments) to be distributed on a national basis. There are technical and political arguments against this as it would fundamentally reshape the Internet architecture.

UK government and industry has been fighting for 6 years to stop IP addresses being distributed on a national basis. Ofcom wants to change that

What message would the UK’s distribution of second hand IPv4 addresses send to the rest of the world? A rich, developed country has been hoarding these scarce resources, and now wants to use them to meet their own needs while developing countries don’t have the same opportunities, and have even been prevented from adopting a similar approach (through the ITU) by that very same government!


The Ofcom Internet team contains first rate individuals, who are knowledgeable about the issues from a range of perspectives: technology, policy, industry. Yet, as a whole, Ofcom seems to be suffering from organisational paralysis on IPv6 implementation.

It is perfectly legitimate to believe in market driven solutions. It’s absolutely the right thing to do in most Internet policy questions. But when, after a decade of waiting for the market to deliver, it’s clear that our country is lagging behind on implementing a standard that will enable the next generation of innovation and economic growth, someone needs to show leadership.

Ofcom’s reticence as a regulator is analysed by Dr Alissa Cooper as being a result of lack of budget and informal constraints that drive its decision making, such as a narrow perception of its remit, greater concern for organisational reputation, and fear of litigation. These combine to inhibit regulation, according to Cooper.

We need to implement IPv6 essentially everywhere

Vint Cerf

This has now reached the absurd level where Ofcom is appearing to make excuses and find alternatives for industry, when the industry itself is coming round to having to implement IPv6.

The idea of the UK regulator advocating recycling of IPv4 addresses to help ISPs avoid the expense of implementing IPv6 seems perverse.

There is little sense that voices other than the ISP industry are being heard within Ofcom when it comes to IPv6 adoption. That’s a pity, because the UK Internet, and economy, need a robust, modern infrastructure to be ready for the next opportunities.

Last word to Vint: The Internet needs to keep evolving and there are things that should happen beyond IPv6 but to overcome the present address space exhaustion, we need to implement IPv6 essentially everywhere”.

Emily Taylor

Emily Taylor is the CEO of Oxford Information Labs. She is an Associate Fellow of Chatham House and is the Editor of the Journal of Cyber Policy and co-founder of ICANN accredited registrar, Oxford Information Labs.

Published: , 2379 Words.