Qwest’s International IP Network Peering Policy

September 14, 2005

Overview
Qwest Communications Corporation ("Qwest") strives to provide premier direct Internet access to all customers. To accomplish this, Qwest has developed this international peering policy to provide guidelines for the selection of International Interconnection Candidates that wish to peer with Qwest in the United States. Qwest selects International Interconnection Candidates based upon, among other things, costs, port availability and bandwidth capacity at particular locations, and the overall strategic benefit Qwest will experience with the connection. Compliance with the technical and operational requirements in the policy does not guarantee a peering relationship with Qwest.

In an attempt to measure accurately the traffic ratios between Qwest and International Interconnection Candidate, Qwest may require a trial peering connection with International Interconnection Candidate. Such a trial may only occur pursuant to a Peering Trial Agreement. Although Qwest only considers private peering initiatives, Qwest may agree to enter into a public interconnection relationship as part of the trial connection. In no case will a public peering connection continue beyond an initial trial. A successful peering trial does not guarantee that Qwest will agree to peer with International Interconnection Candidate.

Basic Definitions

• IP Network means a communications network running TCP/IP and other Internet protocols.
• International Interconnection Candidate means a service provider routing the majority of its IP traffic from customers located outside of North America that is applying to peer with Qwest 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 Candidate’s principal place of business, e.g., Japan, Asia, European Union, South America.  

Technical Requirements

• Network Capacity Requirements: Interconnection Candidate shall have OC-12/STM-4 pop to pop trunking speeds in its Region, i.e., an OC-12/STM-4 backbone.
• Scope of IP Network: International Interconnection Candidate shall have in its Region an IP Network with IP traffic termination ("IP Pops") in a minimum of 5 major Metropolitan Statistical Areas.
• Interconnect: International Interconnection Candidate shall have the ability to interconnect with Qwest in one of six Interconnection Points in the United States where Qwest has interconnection points of presence. The International Interconnection Candidate must have the ability to interconnect directly at OC-12  or greater capacity levels at each point of interconnection.  If multiple interconnections between Qwest and International Interconnection Candidate are required at any point during a peering relationship, Qwest may require Interconnection Points in different US time zones (EST, CST, MST, PST).
• Traffic Ratios: International Interconnection Candidate shall have a 2:1 aggregate traffic ratio with 200 Mbps bi-directional traffic flows. The distribution must be a minimum 60/40 ratio of bi-directional traffic balanced in the case of more than one Interconnection Point. The International Interconnection Candidate must provide 24-hour peak and average traffic volume statistics at each Interconnection Point. The quantity and speed of circuits between Qwest and International Interconnection Candidate will be determined by overall traffic between the two parties, and shall be reviewed periodically.
• Routes: International Interconnection Candidate must carry full customer routes in interconnect routers, and announce consistent routes using BGP4 at all peering locations. International Interconnection Candidate must not establish a route of last resort (i.e., default route) directed toward Qwest. International Interconnection Candidate may not advertise third party routes that allow direct traffic exchange (in either direction) between Qwest and customers of International Interconnection Candidate.

Upon request of Qwest, International Interconnection Candidate shall provide to Qwest an Interconnection Point(s) to its IP Network in its Region and shall provide Qwest with the same access speeds, number of locations, and regionally equivalent Interconnection Points, that Qwest provides to International Interconnection Candidate in the United States.

Operational Requirements

• International Interconnection Candidate must have a fully staffed, 24x7x365, network operations center ("NOC").
• International Interconnection Candidate must provide 48 hours notice to Qwest NOC for scheduled maintenance.
• International Interconnection Candidate must provide trouble reporting and escalation procedures to Qwest. Qwest must have the ability to open tickets with International Interconnection Candidate.

General Information
The peering policy is only a guideline. Meeting or exceeding all of the above requirements does not guarantee Qwest will enter into a peering relationship with International Interconnection Candidate.

Peering will only occur if Qwest and International Interconnection Candidate reach agreement on the terms of a Peering Agreement.
Qwest maintains the right to change this policy at any time without written notification. It is the responsibility of International Interconnection Candidate to maintain compliance with the policy. The policy is located at www.qwest.com/legal.
Send peering inquiries to peering@qwest.com