INTRODUCTION
Authority
Applicable Executive Orders, National Policy, and Public Laws for this policy include the following:
- CIO Council, Planning Guide/Roadmap Toward Internet Protocol Version 6 (IPv6) Adoption within the U.S. Government
- Enterprise IPv6 Deployment Guidelines at datatracker.ietf.org
- Federal Acquisitions Regulations (FAR) Part 39 – Acquisition of Information Technology, https://www.acquisition.gov/sites/default/files/current/far/html/FARTOCP39.html
- FAR Part 11.002(g) – Describing Agency Needs – Policy
- FAR Part 39 – Acquisition of Information Technology
- Federal Information Security Modernization Act of 2014 (FISMA 2014) Public Law 113- 283
- IAB Statement on IPv6, The Internet Architecture Board
- IPv6 Enterprise Network Scenarios at https://datatracker.ietf.org/doc/rfc4057/
- IPv6 FAR Requirements: Federal Register, Volume 74 Issue 236, https://www.govinfo.gov/content/pkg/FR-2009-12-10/pdf/E9-28931.pdf
- IPv6 Transition/Co-existence Security Considerations at https://datatracker.ietf.org/doc/rfc4942/
- Office of Management and Budget (OMB) Memorandum, M-21-07, Completing the Transition to IPv6
- Office of Management and Budget (OMB) Circular A-130, Managing Information as a Strategic Resource
- OMB Memorandum M-05-22, Transition Planning for IPv6
- OMB Memorandum, M-21-07, Completing the Transition to Internet Protocol Version 6 (IPv6)
- OMB Memorandum (unnumbered), Transition to IPv6
- OMB Circular A-130, Managing Information as a Strategic Resource
- Security Considerations at https://datatracker.ietf.org/doc/rfc4942/
- National Institute of Standards and Technology (NIST) Special Publication (SP) 500-267B, Revision 1, USGv6 Profile
- NIST SP 500-281A, Revision 1, USGv6 Test Program Guide
- NIST SP 500-281Ar1sUSGv6 Suppliers Declaration of Conformity
- NIST SP 500-267Br1s, USGv6 Capabilities Table
- NIST SP500-281Br1, USGv6 Test Methods: General Description and Validation
Purpose
The purpose of this policy is to establish how FERC will govern and implement IPv6 to ensure and enforce FERC’s strategic commitment to transition to IPv6 and keep pace with industry trends. To effectively govern and enforce the IPv6 efforts, FERC has established an agency wide IPv6 integrated project team, which includes acquisition, policy, and technical team members. FERC’s strategic intent is to phase out the use of Internet Protocol Version 4 (IPv4) for all agency systems.
FERC shall follow OMB Memorandum M-21-07, which provides the mandates for the Federal government's strategic intent to deliver its information services, operate its networks, and access the services of others using only IPv6. IPv6 growth will continue to accelerate as information technology continues to evolve toward mobile platforms, Internet of Things (IoT), and wireless networks. The technical, economic and security benefits of operating a single, modern, and scalable network infrastructure are the driving forces for the evolution towards IPv6-only in the private sector. To keep pace with and leverage this evolution in networking technology, FERC shall implement the outlined steps provided in OMB M-21-07.
Scope
This policy applies to all FERC information and information systems including those used, managed, or operated by a contractor, another agency, or other organization on behalf of the agency. This policy applies to all FERC employees, contractors, and all other users of FERC information and information systems that support the operation and assets of FERC. Systems under development must meet the system and communications protection requirements of FERC in a manner commensurate with the sensitivity of the information they house and the current life cycle phase. This policy applies to all new FERC acquisitions of Information Technology (IT) products or services using Internet Protocol (IP), as well as decommissioning existing IPv4 systems.
ROLES AND RESPONSIBILITIES
Table 3. Roles and Responsibilities
Roles |
Responsibilities |
Chief Information Officer (CIO) |
|
Chief Information Security Officer (CISO) |
|
Information System Owner (ISO) |
|
Information System Security Officer (ISSO) |
|
Cybersecurity and Information Assurance (CsIA) |
|
IT Operations (ITOps) |
|
Systems Development and Engineering (SDE) |
|
POLICY
This policy mandates the implementation OMB Memorandum, M-21-07, and Federal Acquisitions Regulations (FAR) Part 11.002(g) requirements for all of FERC’s program office and employees seeking to procure a networked IT product or service and acquisition staff involved in the procurement process. The FERC is actively implementing these policy updates to ensure IPv6 requirements are in place and align with the overall goal of the U.S. Government (USG) deployment of IPv6 to improve operational efficiency, and ensure the Federal government is capable of accessing IPv6-only services.
FERC shall actively implement the following, according to the timeline documented in the FERC IPv6 Detailed Implementation Plan:
- Ensure all new networked Federal information systems are IPv6-enabled at the time of deployment to ensure the IPv6 only requirement is met. It is the agency's strategic intent to phase out the use of IPv4 for all systems. FERC requires that all IPv4 systems be upgraded to IPv6 upon the next acquisition cycle.
- Continue to identify opportunities for IPv6 pilots, complete at least one pilot of an IPv6- only operational system, and report the results of the pilot to OMB upon request.
- Maintain and update the FERC IPv6 Implementation Plan and Strategic Information Resources Management (IRM) Plan as appropriate, update all networked Federal information systems (and the IP-enabled assets associated with these systems) to fully enable native IPv6 operation.
The FERC IPv6 Detailed Implementation Plan shall provide the FERC’s transition process and include the milestones and actions to ensure IP-enabled assets on FERC are operating in the IPv6- only environment and meet the determined percentages by the dates designated in the IPv6 Detailed Implementation Plan. FERC shall also continue to make progress to dual stack and work toward the goals documented in the FERC IPv6 Detailed Implementation Plan according to the below general phased approach:
- Enable Dual-Stack on the Network Infrastructure;
- Build DNS6 and DHCP6 supporting capabilities;
- Enable End-point Dual-Stack; and
- Enable Native IPv6.
FERC shall:
- Identify and justify Federal information systems within FERC that cannot be converted to use IPv6 and provide a schedule for replacing or retiring these systems.
- Work with external partners to identify systems that interface with networked Federal information systems and develop plans to migrate all such network interfaces to the use of IPv6.
- Complete the upgrade of public and/or external facing servers and services (e.g., web, email, Domain Name System (DNS), and Intrusion Prevention System (ISP) services) and internal client applications that communicate with public Internet services and supporting enterprise networks to operationally use native IPv6.
POLICY COMPLIANCE
Only FERC’s CIO or a designee shall approve or disapprove all IPv6 compliance waivers to this policy. The FERC shall ensure the following operationally use native IPv6:
- Public and/or external facing servers and services (e.g., web, email, DNS, ISP services, etc.); and
- Internal client applications that communicate with public Internet servers and supporting enterprise networks.
ADHERING TO FEDERAL IPv6 ACQUISITION POLICY REQUIREMENTS
FERC shall ensure that future acquisitions of networked information technology include IPv6 requirements as mandated in FAR Council amendment issued in December 2009. Unless the FERC’s CIO or designee waives the requirement, upon acquisition of any information technology using Internet Protocol, the FERC shall develop requirement documents that include reference to the appropriate technical capabilities defined in the U.S. Government Version 6 (USGv6) Profile, National Institute of Standards and Technology (NIST) Special Publication (SP) 500-267, and the corresponding declarations of conformance defined in the USGv6 Test Program. The FERC acquisition approach shall enable natural technology refresh cycles to upgrade the installed base of networked IT products and services to be IPv6-capable. The CIO shall ensure that Federal IT systems are positioned to leverage the technical and economic benefits of IPv6, and eventually migrate to IPv6-only environments when appropriate.
In accordance with existing FAR requirements, FERC shall:
- Continue to use the USGv6 Profile to define agency or acquisition specific requirements for IPv6 capabilities when purchasing networked information technology and services. Going forward, this should include specifying the requirement for hardware and software to be capable of operating in an IPv6-only environment;
- Include IPv6 requirements into all future procurements.
- Continue to require potential vendors to document compliance with such IPv6 requirement statements through the USGv6 Test Program; and
- Provide a process for FERC’s CIO to waive this requirement on a case-by-case basis such as in rare circumstances where the requirement demonstrates that IPv6 capabilities would pose undue burden on an acquisition action. In such cases, the purchasing agency shall request documentation from vendors detailing explicit plans (e.g., timelines) to incorporate IPv6 capabilities to their offerings.
A requestor in the FERC office seeking to procure an IT product or service using IP must work with their Contracting Officer (CO) to ensure appropriate IPv6 requirements language is included in the following documents:
- Procurement Requests,
- Advanced Procurement Plans,
- Statements of Work (SOW),
- Requests for Proposal, and
- Awarded Contracts.
PRODUCT AND SERVICE PROCUREMENT REQUESTS
The following are the requirements for FERC staff to follow in order to request procurement of IT products and services:
-
-
- Include appropriate IPv6 requirements language in Procurement Requests and Advanced Procurement Plans;
- Work with CO to ensure appropriate IPv6 requirements language is included in Statements of Work (SOW), RFPs and awarded contracts;
- Analyze that the vendor meets FERC requirements and complies with Federal guidance.
-
EVOLVING THE USGv6 PROGRAM POLICY REQUIREMENTS
NIST will continue to update and expand the USGv6 Program and provide periodic updates to the USGv6 Profile to incorporate the latest Internet Engineering Task Force (IETF) specifications relevant to IPv6 technology. FERC shall continue to monitor updates from the USGv6 Program to ensure the agency maintains consistency with IPv6 changes of other government agencies, as well as continue to monitor and adhere to updates from NIST as required per FISMA. FERC shall enforce the following policy requirements:
- Avoid any unnecessary duplication of generic testing requirements by leveraging the USGv6 Test Program for basic conformance and general interoperability testing of commercial products; and
- Ensure that the agency or acquisition specific testing focus on specific systems integration, performance, and information assurance testing not covered in the USGv6 Test Program.
To help ensure the security benefits of IPv6 for all Federal agencies, the FERC shall require the following requirements are in place for all of FERC’s information systems in additional to all existing FERC polices:
- Include plans for full support of production IPv6 services in IT security plans, architectures, and acquisitions;
- Validate all systems that support network operations or enterprise security services (e.g., identity and access management systems, firewalls, and intrusion detection/protection systems, end-point security systems, security incident and event management systems, access control and policy enforcement systems, threat intelligence and reputation systems) are IPv6-capable and can operate in IPv6-only environments;
- Follow applicable Federal guidance and leverage industry best practices, as appropriate, for the secure deployment and operation of IPv6 networks; and
- Ensure that all security and privacy policy assessment, authorization, and monitoring processes fully address the production use of IPv6 in Federal information systems.
CONTRACTING OFFICERS
The FERC CO shall review advanced procurement plans to determine the applicability of IPv6 requirements to its acquisition. The CO shall ensure the APP and supporting documents are in accordance with FAR 11.002(g) IPv6 requirements by including:
- Instructions in solicitations that require offerors to notify the contracting officer of any contract specifications that do not comply with providing full feature functionality for IPv6.
- Contract requirements statement in solicitations that specifically states that products and services that use Internet Protocol provide full feature functionality in IPv6-only environments in compliance with the NIST USGv6 Testing Program.
VENDORS
. All vendors shall complete and meet the requirements of Department of Homeland Security (DHS) Cybersecurity and Infrastructure Security Agency (CISA) Secure Software Development Attestation Form. As documented in both the FERC Supply Chain Risk Management Policy and FERC Supply Chain Risk Management Strategy document, vendors shall be further evaluated to determine if the vendor already meets the government-wide attestation requirement or if FERC needs to provide the DHS Self-Attestation Form to the vendor for completion.
WAIVERS
Only the FERC’s CIO or a designee may waive the IPv6 requirements and must do so in writing. A requestor within the FERC seeking a waiver to retain an IT product or service that does not meet the IPv6 compliance requirements specified in OMB Memorandum M-21-07, FAR 11.002(g), and in this policy must submit a signed request in memorandum format to the FERC’S CIO. All IT hardware, software, and services that do not comply with Federal and FERC IPv6 requirements require written and signed approval from the CIO.
APPENDIX A: ACRONYMS
Table 4. Acronyms
Acronym |
Definition |
CIO |
Chief Information Officer |
CISO |
Chief Information Security Officer |
CO |
Contracting Officer |
CsIA |
Cybersecurity Information Assurance Division |
DNS |
Domain Name Service |
FAR |
Federal Acquisition Regulations |
FERC |
Federal Energy Regulatory Commission |
FIPS |
Federal Information Processing Standard |
FISMA |
Federal Information Security Modernization Act |
FY |
Fiscal Year |
IETF |
Internet Engineering Task Force |
IP |
Internet Protocol |
IPV4 |
Internet Protocol Version 4 |
IPV6 |
Internet Protocol Version |
IoT |
Internet of Things |
IRM |
Information Resources Management |
ISO |
Information System Owner |
ISP |
Intrusion Prevention System |
ISSO |
Information System Security Officer |
IT |
Information Technology |
NIST |
National Institute of Standards and Technology |
OMB |
Office of Management and Budget |
RFP |
Requests for Proposal |
SP |
Special Publication |
SOW |
Statements of Work |
USG |
U.S. Government |
USGv6 |
U.S. Government v6 Profile |