New Peering Policy Covers Level 3/Global Crossing

To comply with questions raised by the U.S. Department of Justice during its review of Level 3 Communications’ proposed (but now completed) acquisition of Global Crossing, Level 3 today posted a revised peering policy for Internet Protocol (IP) traffic exchanged within the United States.

In November 2010, Level 3 was fighting with Comcast over peering policies. (For more, see Level 3, Comcast Exchange Barbs Over Alleged ‘Tollbooth’ Charges and Level 3 Closes Global Crossing Acquisition).

Level 3’s new policy comprises four overarching principles it believes should control all next-generation peering arrangements:

1. The primary objective of a peering arrangement is to enable each party to deliver high-quality service to its Internet customers.
2. The interconnection architecture and traffic exchange practices of each party should assure that the exchange of traffic is resilient, secure and quickly scalable.
3. Regardless of the direction or type of traffic exchanged between the networks, or the technology used to deliver it, the parties should work together to implement routing practices and adjust location of interconnection points such that each party bears a reasonably equal share of backbone burdens – taking into account the amount of traffic carried by each party and the distance over which that traffic is carried. This will give each party the option to use its own backbone network to balance backbone network burdens between the parties and thus eliminate the need to impose charges to interconnect or carry traffic.
4. Any termination or modification of a peering arrangement should be managed by both parties in a manner that minimizes adverse impacts to each party’s customers and the overall operation of the Internet.

The revised policy takes effect immediately and applies to the combined networks of Level 3 and Global Crossing.

"For too long, peering practices between Internet carriers have focused solely on the commercial needs of the carriers," said Jack Waters, Level 3’s CTO, in a statement. "We believe that the focus should be on customers, and that carriers must attempt to structure and implement fair and equitable interconnection relationships and practices that are designed to deliver fast, secure, reliable and quickly scalable Internet services to customers.”

He continued, “Peering relationships and practices from a decade ago were implemented when traffic was dominated by email and text-based communications, and periodic interruptions in Internet service were common. Today, residential, governmental and commercial users rely on the Internet for rich content and applications, and demand better performance in an increasingly dynamic Internet environment. Fair, equitable, scalable and dynamic interconnection is essential to deliver that experience."

One fundamental aspect of the new policy is a requirement that carriers adjust routing practices and interconnection locations so that the distance and volume of traffic carried by each party on their backbone networks remains equitable.
 
Said Waters, "If one party to a settlement-free peering relationship is carrying far less traffic over far less distances than the other party, the policy would require changes to interconnection locations and routing to more equitably distribute the burden of carrying traffic and thus preserve a fair settlement-free peering relationship. In addition, the policy contemplates that carriers should meet and confer frequently to augment interconnection capacity, and adjust interconnection locations so that Internet content sought by customers can be delivered with increasing quality and without congestion that can adversely impact consumers’ Internet experience."

-Linda Hardesty