Suddenlink Communications' Settlement-Free Interconnection (Peering) Policy
Background and Introduction
This document sets forth Suddenlink Communications' Policy for Settlement-Free Interconnection with Internet Networks ("Policy"), also referred to as "peering". Suddenlink Communications regularly updates its Policy and maintains the current version of its Policy on the Suddenlink Communications public Web site at http://www.suddenlink.com/terms-policy/peering/.
This Policy details the requirements that an Internet Network requesting interconnection (the "Requester") must meet in order to qualify for settlement-free interconnection. For purposes of this Policy, an Internet Network must be a single Autonomous System ("AS"). Suddenlink Communications also will consider requests for settlement-free interconnection on a national level or in other regions of the world, with the same guiding principles and with appropriately scaled interconnection requirements. This Policy also specifies the operational requirements for interconnecting networks, which both the Requester and Suddenlink Communications must satisfy.
IP Network means a communications network running TCP/IP and other Internet protocols.
International Requester means a service provider routing the majority of its IP traffic from customers located outside of North America that is applying to peer with Suddenlink Communications in the United States.
Interconnection Point means the place where two IP Networks are connected by dedicated bandwidth for the purpose of exchanging Internet traffic.
Route means a unique path along which data is directed on the public Internet and/or on either party's IP Network.
Border Gateway Protocol 4 or BGP4 means protocol used to exchange routing information between collaborating routers on the Internet.
Peering is the settlement-free exchange of IP traffic between service providers operating IP Networks.
Region describes the major economic market of International Interconnection Requester's principal place of business, e.g., Asia, European Union, Japan, US, South America.
The Requester shall operate facilities capable of terminating IP customer leased line connections onto a device in at least two or more private peering locations (at least one on the West Coast, one on the East Coast and or one in the Mid West).
The ratio of the aggregate amount of traffic exchanged between the Requester and the Suddenlink Communications Internet Network with which it seeks to interconnect shall be roughly balanced and shall not exceed 1.8:1.
The Requester shall have a fully redundant backbone network, in which the majority of its inter-hub trunking links shall have a capacity of at least (OC-12) for interconnection with Suddenlink Communications-ASPAC.
The aggregate amount of traffic exchanged in each direction over all interconnection links between the Requester and the Suddenlink Communications Internet Network with which it desires to interconnect shall be a minimum of 100Mbps (95th percentile) with Autonomous System 19108.
The Requester shall utilize RADB or mirrored IRR resources. The Requester shall be configured with loose prefix limits based upon registered/announced routes to guard against leaks.
The following operational requirements apply both to the Requester and to the Suddenlink Communications Internet Network with which it desires to enter into a settlement-free interconnection arrangement:
Each Internet Network must establish and maintain traffic exchange links of a sufficient robustness, aggregate capacity, and geographic dispersion to facilitate mutually acceptable performance across the interconnect links.
Each Internet Network must operate a fully functional 24x7x365 Network Operations Center ("NOC").
Requester must provide 48 hours notice to Suddenlink Communications' NOC for scheduled maintenance. Requesters are encouraged to register routes or send notice in advance of dramatic deltas in announcements to allow for adjustments to those limits.
Each Internet Network must set next hop to be itself, the advertising router of the network. Each Internet Network will propagate such routes to its transit customers with its own router as next hop.
Each Internet Network shall implement "shortest exit routing" and advertise routes consistent with that policy, unless both Internet Networks mutually agree otherwise based on special circumstances.
Each Internet Network will restrict its advertisements to non-transit routes originating within the geographic region for which peering is established and will not propagate the received route announcements outside such region.
Each Internet Network must operate a fully redundant network, capable of handling a simultaneous single-node outage in each network without significantly affecting the performance of the traffic being exchanged.
The two Internet Networks must exchange with each other prior to any settlement-free interconnection agreement a free shell or PPP account for testing and auditing purposes related to routing. This will be used for confirmation of traffic flows, troubleshooting of interconnection-related issues, and auditing purposes.
Each Internet Network must be responsive to unsolicited email and network abuse complaints, as well as routing and security issues, providing a knowledgeable technician within a two-hour period after notice.
For the purposes of Requirements 2.2 and 2.4 of the Policy, all traffic is to be measured over interconnection links. In the event that such links do not exist, the two Internet Networks may establish temporary test links for the purposes of traffic measurement. In the event that establishing such links is not feasible or desirable, traffic will be measured at peak utilization, based upon a representative sample consistent with industry practice.
For the purposes of Requirements 2.2 and 2.4 of the Policy, the traffic to be measured will include only what is being exchanged by the two Internet Networks and their respective customers (excluding any transit traffic) in the specific geographic region for which settlement-free interconnection has been requested.
General Policy Notifications
The two Internet Networks must be willing to enter into a Mutual Non-Disclosure Agreement and a bilateral Interconnection Agreement.
The Requester and Suddenlink Communications must be willing to sustain an equal financial burden for the costs of private interconnection via local facilities.
The requirements in Section 2 above must be met at the time the request for settlement-free interconnection with Suddenlink Communications is made.
All requirements of the Policy must continue to be met to continue a settlement-free interconnection relationship. Status under the Policy will be evaluated periodically. In the case of a change in ownership or control of an Internet Network with which Suddenlink Communications has an interconnection agreement, status under the Policy will be evaluated within 30 days of such change.
Suddenlink Communications will continue to monitor the development of the Internet and traffic conditions and make appropriate changes in this Policy as the Internet continues to evolve. Suddenlink Communications reserves the right to modify this Policy at any time without written notification and to make exceptions to this policy at its sole discretion. It is the responsibility of the Requester to maintain compliance with this Policy. Any contractual rights shall arise out of an interconnection agreement between Suddenlink Communications and Requester, not this Policy.
Meeting or exceeding the guidelines set forth in this Policy is not a guarantee that a settlement-free interconnection will be established with a Requester. Suddenlink Communications will not enter peer with any network that has been an IP transit customer within the past nine (9) months.
All requests for settlement-free interconnection should be submitted to Suddenlink Communications at [email protected].