a) The "free peering" relationship is directly analogous to a "bill & keep" interconnection relationship between traditional telephone companies.
I suspect that "directly analogous" is neither a legal nor a regulatory term.
b) Under the Communications Act of 1934 As amended by the Telecommunications Act of 1996 ("Act"), "telecommunications carriers" are under obligation to interconnect "with the facilities and equipment of other telecommunications carriers..." (Act, Sec. 251 (a) (1)
It may be worth your while to learn what a "telecommunications carrier" is. (I rather doubt that you are one. I also rather doubt that the people you want to peer with are either.) The telecomreg mail list might be a useful place for you to explore this topic. -tjs