Overview

This document sets forth Highwinds Network Group ("HWNG") Business' Policy for Settlement-Free Interconnection with Internet Networks ("Policy"), also referred to as "peering." HWNG Business regularly updates its Policy and maintains the current version of its Policy on the HWNG web site at www.highwinds.com/peering.html.

HWNG strives to provide premier direct Internet access to all customers. To accomplish this, HWNG has developed this Peering Policy to provide guidelines for the selection of interconnection candidates that wish to peer with HWNG. Interconnection candidates are based upon, among other things, costs, port availability and bandwidth capacity at particular locations, and the overall strategic benefit HWNG will experience with the connection. Compliance with the technical and operational requirements in the Policy does not guarantee a peering relationship with HWNG.

HWNG considers private as well as public peering initiatives. This Policy applies to all requests for settlement-free interconnection with a HWNG regional Internet Network, either via dedicated connections ("private peering") or via traffic exchange at a multi-party Internet exchange point ("public peering"). For the purposes of this Policy, an Internet Network must be a single Autonomous System ("AS").

Part 1 of the Policy details the interconnection requirements that an Internet Network requesting interconnection (the "Requester") must meet in order to qualify for settlement-free interconnection.

Part 2 of the Policy specifies the notification requirements for interconnecting networks, which both the Requester and HWNG must satisfy.

1. Interconnection and Operational Requirements

   The following operational requirements apply both to the Requester and to the HWNG Network with which it desires to enter into a settlement-free interconnection arrangement.

   1.1. Peer must use the same peering AS at each US interconnection point and must announce a consistent set of routes at each point, unless otherwise mutually agreed.

   1.2. No transit or third-party routes are to be announced; all routes exchanged must be Peer's and Peer's customers' routes.

   1.3. Neither party shall abuse the peering relationship by engaging in activities such as but not limited to: pointing a default route at the other or otherwise forwarding traffic for destinations not explicitly advertised, resetting next-hop, selling or giving next-hop to others.

   1.4. Each Internet Network shall implement "shortest exit/hot potato routing" and advertise routes consistent with that policy, unless both Internet Networks mutually agree otherwise based on special circumstances.

   1.5. If Peer's network scope spans a continent and/or multiple continents, then Peer must consider peering at all exchange points that make sense unless otherwise mutually agreed.

   1.6. Each Peer will maintain accurate prefix and routing information in a publicly accessible Internet Routing Registry (IRR).

   1.7. Highwinds will prefer peering sessions for best path. Highwinds expects the Peer to do the same unless agreed otherwise.

   1.8. 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.

   1.9. 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.

   1.10. Each Internet Network must operate a fully functional 24x7 Network Operations Center (NOC).

   1.11. 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 HWNG has an interconnection agreement, status under the Policy will be evaluated within 30 days of such change.

   1.12. 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.

2. Notification Requirements

   The following notification requirements apply both to the Requester and to the HWNG Network with which it desires to enter into a settlement-free interconnection arrangement.

   2.1. Any outage or impairment to peering session which is identified by the remote network operator is to be reported to the HWNG NOC as soon as it is identified.

   2.2. Upon identification of a customer-impacting peering event (outage), technicians will make themselves available for immediate troubleshooting and restoration of the peering session.

   2.3. Prior to the peering session being established, a copy of Network's escalation procedures and contact information will be exchanged.

   2.4. Each Internet Network must be responsive to unsolicited e-mail and network abuse complaints, as well as routing and security issues, providing a knowledgeable technician within a two-hour period after notice.

   2.5. HWNG 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. HWNG reserves the right to modify this Policy at any time.

   2.6. All requests for settlement-free interconnection should be submitted to HWNG via e-mail at peering@hwng.net.