I.

Charter Communication's IP Interconnection Policy and Requirements

Charter Communications, Inc. ("Charter") will interconnect its IP network with those applicants providing content to Charter customers pursuant to customer-initiated Internet sessions who meet the traffic measurement criteria set forth below for at least 3 consecutive months. Interconnection and any subsequent capacity augments under this policy will be undertaken subject to a mutual interconnection agreement at no charge to either party for traffic exchange. Each party will maintain sufficient capacity to support Charter customer-initiated Internet sessions consistent with this policy, including Paragraph (16) and the paragraphs entitled "Network Planning and Augmenting Capacity" and "Suspension" below.

To apply for such interconnection, an e-mail must be sent to interconnection@charter.com with anticipated traffic volumes per point of interconnection. This policy applies to all interconnection relationships meeting the Interconnection Requirements (as defined below) involving Charter’s networks, including any newly acquired networks.

This policy applies to IP interconnection only.

Charter may require a trial connection with any party seeking interconnection under this policy.

Interconnection Requirements for Interconnecting Party

  1. Must interconnect at each of the Charter points of presence (each a "POP") listed below and at any additional Charter POP within 90 days of the establishment of such new POP:

Equinix
11 Great Oak, San Jose, CA

Equinix
350 Cermak, Chicago, IL

Telx
56 Marietta, Atlanta, GA

Equinix
600 W 7th, Los Angeles, CA

Equinix   
20715 Filigree Ct, Ashburn, VA

Equinix
1950  N Stemmons, Dallas,  Tx

Equinix
2001 6th Ave, Seattle, WA

Cologix
511 11th Ave W, Minneapolis, MN

Seattle IX (SIX)
Westin Bldg, Seattle, WA

Charter will maintain the ratio of POPs to Internet customers existing as of the effective date of this policy.

  1. Must deliver traffic to the Charter POP closest to the location at which the corresponding Internet customer traffic terminates.
  2. Must use the same ASN at each interconnection point.
  3. Must maintain a minimum traffic exchange of 3 Gbps (95th percentile) at each Charter POP with AS20115 in the dominant direction as measured on a monthly basis ("Interconnection Requirements").
  4. Must maintain a professional Network Operations Center staffed 24x7x365.
  5. Must maintain consistent global routing announcements at all Charter POPs.
  6. Must not implement a "gateway of last resort" or default route directed at AS20115.
  7. Must demonstrate and enforce strict filtering policies to prevent improper announcements.
  8. Must advertise routes, including customer routes, but eliminate all transit or third party routes.
  9. Must provide IPv4 unicast routes up to /24 netmask or IPv6 Unicast routes up to /48 netmask.
  10. Must use BGP version 4 with BGP authentication keys.
  11. Must not abuse the interconnection relationship by doing any of the following:
    1. Resetting next hop
    2. Reselling, bartering, trading or giving either routes or next hop to third parties (non-customers)
    3. Leaking routes to third parties (non-customers)
    4. Sending inconsistent prefixes inside of a single interconnection region (in number, origin, or other attributes) unless agreed to in writing
    5. Sending inconsistent prefixes are allowed for a party that has island/regional networks without the capacity to transport between those islands/regions, as long as those inconsistent prefixes are not utilized to manage traffic between those islands/regions or otherwise in a manner that disrupts the network management practices and techniques employed by Charter. The use of inconsistent prefixes requires that a party must maintain a minimum traffic exchange of 10Gbps (95th percentile) at each Charter POP with AS20115 in the dominant direction as measured on a monthly basis.
  12. Must register routes or send advance notice of dramatic changes in announcements.
  13. Must advertise/implement routes consistent with "shortest exit routing", unless agreed to in writing.
  14. Must agree to actively cooperate in resolving items in the following:
    1. Security violations
    2. Denial of service attacks
    3. Network abuse (including but not limited to spam issues)
    4. Downed interconnection sessions, interfaces, or circuits
    5. Disrupted, damaged, or flapping interconnection sessions
    6. Similar/related infrastructure and security issues
  15. Must honor all relevant BGP traffic management attributes to deliver substantially all Charter customer network traffic locally within an interconnected region (based on Item 1)
    1. MED (Multi Exit Discriminator)
    2. AS Path length
    3. Standard BGP communities
  16. Must utilize RADB or mirrored IRR resources and shall be configured with max prefix limits, allowing 25% headroom, based upon registered/announced routes.
  17. Must agree not to offer or sell any IP transit service providing only AS20115.

Network Planning and Augmenting Capacity
The interconnecting party agrees to meet with or report to Charter on a periodic basis to participate in planning network status reviews and forecasting network traffic.

In the event there is an increase in the maximum data transfer rate into or out of Charter’s network of more than 5.9% per month over a rolling 12-month period ("Peak"), Charter and the interconnecting party agree to upgrade interconnection capacity within 90 days after Peak, if Peak is sustained for a time period greater than 10 days and has surpassed 70% of a circuit's port capacity.

Suspension
Charter reserves the right to suspend any interconnection agreement in the event there is traffic that compromises the security infrastructure of the network and/or security of other users on the network (an "Adverse Network Effect"). Prior to exercising its right to suspend an interconnection agreement and within 24 hours of the occurrence of the Adverse Network Effect, Charter shall provide the interconnecting party a reasonable opportunity to meet in order to provide detailed information regarding the circumstances giving rise to the Adverse Network Effect and to present a plan to eliminate, mitigate, or otherwise address the Adverse Network Effect and underlying cause(s) thereof. A suspended agreement will resume upon a reasonable showing that the Adverse Network Effect has been resolved.

Charter reserves the right to suspend any interconnection agreement with respect to which any of the following occur (each a "Critical Network Threat"):

I. there is an increase in the maximum data transfer rate into or out of Charter’s network ("Peak") of 10% or more in any month compared to the Peak of all prior months; or

II. there is an increase in the compound growth rate of Peak of more than 5.9% per month over any rolling six-month period.

Within 15 days of the occurrence of the Critical Network Threat, Charter shall provide the interconnecting party a reasonable opportunity to meet in order to provide detailed information regarding the circumstances giving rise to the Critical Network Threat and to present a plan to eliminate, mitigate, or otherwise address the Critical Network Event and underlying cause(s) thereof. A suspended agreement will resume upon a reasonable showing that the Critical Network Threat has been resolved.

Packet Error and Network Management
Charter reserves the right to implement reasonable traffic management techniques as may be necessary to eliminate or minimize bandwidth waste associated with misdirected, mis-transcoded, or undeliverable packets. Furthermore, nothing in this policy shall be deemed to abrogate or otherwise limit Charter’s rights under applicable law to implement reasonable network management practices.

Interconnection Agreement Termination
Charter reserves the right to terminate its interconnection agreement with any party who materially breaches this policy after the party (i) has been given written notice of the breach and fails to cure it within 10 days of the written notice and (ii) has obtained and transitioned traffic to sufficient capacity from a third party, except in no event is Charter required to continue under this policy more than 20 days after Charter would otherwise be entitled to terminate it for material breach. Charter reserves the right to terminate any interconnection agreement immediately if necessary to comply with any applicable law, regulation or government order.

Policy Changes
This interconnection policy and any interconnection agreements established pursuant to this policy will be subject to periodic review. Interconnection agreements entered into pursuant to this policy shall not expire before December 31, 2018.

Charter reserves the right to change this interconnection policy prior to December 31, 2018, to accommodate changes (i) to its IP network (such as growth in or changes to the geographical reach of its IP network), so long as such policy changes do not result in payment for interconnection, (ii) that are necessary to comply with any applicable law, or (iii) resulting from a change in law that might render Charter’s compliance with the terms of any interconnection agreement impracticable or impossible.

Enforceability
Either party to the interconnection relationship may enforce rights or obligations established by this policy or related interconnection agreement in a court or agency of competent jurisdiction.

II.

Charter Communication's Private Settlement Free Peering Policy and Requirements

Policy

Charter Communications looks to interconnect its IP network with other providers on a settlement-free basis whereas such interconnection provides measurable benefits to Charter and its customers.

This policy applies to private and public peering with the noted exceptions in the guidelines. The criteria involving traffic measurements below or negotiated arrangement must be met by the applicants for three consecutive months. To apply for settlement-free interconnection with Charter an e-mail must be sent to peering@charter.com with a proposal of interconnection points, and anticipated traffic volumes per location.

Each request will be reviewed on a case by case basis.

Guidelines

  1. Must interconnect in a minimum of 3 Charter points of presence (“POPs”) listed below and each in a different time zone:

Equinix
11 Great Oak, San Jose, CA

Equinix
350 Cermak, Chicago, IL

Telx
56 Marietta, Atlanta, GA

Equinix
600 W 7th, Los Angeles, CA

Equinix   
20715 Filigree Ct, Ashburn, VA

Equinix
1950  N Stemmons, Dallas,  Tx

Equinix
2001 6th Ave, Seattle, WA

Cologix
511 11th Ave W, Minneapolis, MN

Seattle IX (SIX)
Westin Bldg, Seattle, WA

  1. Must use the same ASN at each peering POP
  2. Must deliver traffic to the Charter POP closest to the location at which the corresponding Internet customer traffic terminates.
  3. Must maintain a minimum traffic exchange of 300 Mbps with AS20115 in the dominant direction and measured on a monthly basis. Any amount less than 300 Mbps must be delivered to Charter through a public peering path.
  4. Must maintain a professional Network Operations Center staffed 24x7x365
  5. Must maintain consistent global routing announcements at all peering POPs
  6. Must not implement a “gateway of last resort” or default route directed at AS20115
  7. Must demonstrate and enforce strict filtering policies to prevent improper announcements
  8. Must advertise routes, including customer routes, but eliminate all transit or third party routes
  9. Must provide IPv4 unicast routes up to /24 netmask or IPv6 Unicast routes up to /48 netmask
  10. Must use BGP version 4 with BGP authentication keys
  11. Must not abuse the peering relationship by doing any of the following:
    1. Resetting next hop
    2. Reselling, bartering, trading or giving either routes or next hop to third parties (non-customers)
    3. Leaking routes to third parties (non-customers)
    4. Sending inconsistent prefixes (in number, origin, or other attributes) unless agreed to in writing
  12. Must register routes or send advance notice of dramatic changes in announcements
  13. Must advertise/implement routes consistent with "shortest exit routing", unless agreed to in writing
  14. Must agree to actively cooperate in resolving items in the following:
    1. Security violations
    2. Denial of service attacks
    3. Network abuse (including but not limited to spam issues)
    4. Downed peering sessions, interfaces, or circuits
    5. Disrupted, damaged, or flapping peering sessions
    6. Similar/related infrastructure and security issues
  15. Must be willing to upgrade interconnection capacity within 90 days when peak usage, for a time period
  16. Must be able to transport capacity greater than the interconnecting port speed
  17. Must utilize RADB or mirrored IRR resources and shall be configured with max prefix limits, allowing 25% headroom, based upon registered/announced routes
  18. Must agree not to offer or sell any IP transit service providing only AS20115

Meeting the guidelines is not a guarantee that peering will be established. Charter reserves the right to refuse peering to the applicant based on business reasons, without requirement of disclosure. Charter reserves the right to terminate private peering at any time with 14 days' notice. Such advanced notice is neither guaranteed nor required for unresponsive, abusive, or negligent peers.

Charter Communications reserves the right to change this peering policy without notice.