Net Neutrality and Broadband Disclosures
WEST CENTRAL TELEPHONE ASSOCIATION
BROADBAND INTERNET SERVICE DISCLOSURES
Updated June 11, 2018
General description. We provide a variety of High Speed Internet offerings to our residential and business customers. We provide the service over our broadband network and through third party fiber optic lines connecting to the Internet. We monitor our network and traffic patterns and make changes we deem necessary to manage and improve overall network performance. We use reasonable, nondiscriminatory, network management practices to improve overall network performance to ensure a high-quality online experience for all users. We use various tools and techniques to manage our network, deliver our service, and ensure compliance with our Acceptable Use Policy. We also contract with one or more third-party companies for certain network monitoring and management services. Our network management activities may include identifying spam and preventing its delivery to customer email accounts, detecting malicious traffic and preventing distribution of viruses or other harmful code or content and using tools and techniques in order to meet our goal of delivering the best possible Internet experience to our customers. Our network management practices do not target any specific content, application, service, or device. As network management issues arise and as technology develops, we may employ additional or new network management practices. We will update these disclosures as necessary.
Related documents and disclosures. Use of our High Speed Internet Service is also governed by:
- Acceptable Use Policy, available at http://www.wcta.net/pdf's/wcta/ACCEPTABLE_USE_POLICY.pdf
- High Speed Internet Service FAQ, available at http://www.wcta.net/site/index.php?option=com_content&view=article&id=140&Itemid=65
- High Speed Internet Service Packages and Prices, available at http://www.wcta.net/site/index.php/products-services/internet-access/high-speed-internet
Blocking. We do not engage in any practice, other than reasonable network management disclosed herein, that blocks or otherwise prevents end user access to lawful content, applications, service, or non-harmful devices.
Throttling. We do not engage in any practice, other than reasonable network management disclosed herein, that degrades or impairs access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful device.
Affiliated or Paid Prioritization. We do not engage in any practice that directly or indirectly favors some Internet traffic over other traffic to benefit an affiliate or in exchange for consideration, monetary or otherwise.
Congestion management. We describe in this section network management practices used to address congestion on our network.
Congestion management practices used.
Network monitoring. We monitor our network for utilization trends. We receive regular reports showing changes in network traffic and congestion. We use this information to plan increases in bandwidth available, port additions, or additional connectivity to the Internet. Should new technologies or unforeseen developments in the future make it necessary to implement an active congestion management program, we will update these disclosures and otherwise notify our customers of the scope and specifics of this program.
Potential heavy bandwidth users. Through our third party provider, we receive reports showing end user usage for identification and management of potential heavy bandwidth users. If a reasonable solution is not found and usage remains excessive, we reserve the right to limit, suspend, or terminate the high volume user’s Internet service.
Types of traffic affected: Our congestion management practices do not target any specific content, application, service, or device, or otherwise inhibit or favor certain applications or classes of applications.
Purposes of congestion management practices. Our High Speed Internet network is a shared network. This means that our customers share upstream and downstream bandwidth. The goal of our congestion management practices is to enable better network availability and speeds for all users. Our congestion management practices serve to:
- Help us adapt and upgrade our network to maintain or improve network performance as demand for our High Speed Internet Service increases.
- Help us adapt and upgrade our network to maintain or improve network performance as demand for higher bandwidth applications increases. Some examples of higher bandwidth applications are gaming, streaming movies, and streaming high definition video.
- Help us identify potential heavy bandwidth users.
Congestion management criteria.
Network monitoring: Our network monitoring provides data to help us plan upgrades to our network, equipment, technology, and connectivity to the Internet. As demand for our High Speed Internet Service increases, and as demand for higher bandwidth applications increases, we monitor effects on network performance and plan upgrades as we deem necessary. We have not established specific criteria to govern our upgrade decisions.
Potential heavy bandwidth users. We reserve the right, in our sole reasonable discretion, to determine the criteria for data consumption that is not characteristic of a typical residential user of our High Seed Internet Service.
Effects on end user experience: Because our High Speed Internet network is a shared network, periods of high network demand may result in Internet traffic congestion. End users may experience reduced bandwidth or speed during these times.
Application-Specific Practices. This section discloses any application-specific practices we use, if any.
Management of specific protocols or protocol ports. To protect the security of our network and our customers, we may block known hostile ports. In such cases, we may block that specific port until the attack ceases, at which time we remove the block.
Modification of protocol fields. None.
Applications or classes of applications inhibited or favored. None.
Device Attachment Rules. This section addresses any limitations on attaching lawful devices to our network.
General restrictions on types of devices to connect to network. We place no restrictions on lawful devices that a customer may connect our network, so long as the device is: (i) compatible with our network; and (ii) does not harm our network or other users. Our High Speed Internet Service works with most types of PCs and laptops including Macs, and other Internet compatible devices like game systems and Internet enabled TVs. If a wireless router or gateway is properly connected to our High Speed Internet Service, wireless Internet compatible devices including computers, tablets, smartphones and other devices can connect to our network. To connect a computer our High Speed Internet Service, a customer’s computer must have a network interface card or NIC, or a wireless antenna to connect wirelessly. Beyond that, our service works with most types of PCs and laptops including Macs. If a customer or potential customer believes they have an unusual configuration, our customer service department will help determine if there is a compatibility problem.
FTTH ONTs. In our service area, we provide our High Speed Internet Service via Fiber-to-the-Home (“FTTH”) technology. FTTH High Speed Internet Service requires connection of an Optical Network Terminal (“ONT”) to our network. We provide ONTs to our customers. Customer can choose between ONTs with wired ports only or ONTs with wired ports and a wireless gateway. Customers could also attach to an ONT a wireless gateway purchased at retail.
Network and End User Security. This section provides a general description of the practices we use to maintain security of our network.
Practices used to ensure end user security, including triggering conditions.
Virus and Spam filtering: We filter email for virus activity using industry standard virus scanning and prevention techniques. Should an email message be found to contain a virus, the message will be deleted without notification given to either the sender or the intended recipient(s). Spam filtering is optional. If a customer opts-in to Spam filtering, our filtering technology will quarantine messages considered spam for 7 days before deleting the messages. A customer can recover a quarantined email during that 7 day period.
Web Hosting and Data Center Hosting Surveillance: We perform routine surveillance of our networks in connection with our web hosting, data center hosting, and related services. Although we will not, as an ordinary practice, proactively monitor individual Customers’ activities for violations of its Acceptable Use Policy (available at http://www.wcta.net/pdf's/wcta/ACCEPTABLE_USE_POLICY.pdf), there may be instances in which we, through our routine surveillance, finds violations and responds with appropriate action to immediately stop further violations at its sole discretion.
Practices used to ensure security of the network, including triggering conditions.
Virus and Spam filtering: Our email and website traffic is filtered for virus activity and Spam using industry standard virus scanning and prevention techniques. Should an email message be found to contain a virus, the message will be deleted without notification given to either the sender or the intended recipient(s). All spam is quarantined, however the email customer has the option to delete.
Firewall protection: We maintain firewalls to resist hacking and other traffic intended to harm our network.
General Service Description. Our High Speed Internet Service enables a customer to connect an Internet-enabled device through either a wired or wireless connection. The service includes wiring, and an ONT, and a network interface card (NIC) for the personal computer, if required. Our High Speed Internet Service enables residential and commercial subscribers to access all lawful content, applications, and services of their choice that are made freely available on the Internet, unless blocked by an Internet content, applications or service provider.
Service technology. We provide our High Speed Internet Service through FTTH. FTTH uses fiber optic lines and an ONT at the customer residence. To connect from our network to the Internet, we maintain equipment for FTTH at our central office that connects to the public Internet. This is a shared network, which means that our customers share upstream and downstream bandwidth.
Expected and actual speeds and latency:
Expected performance. We offer customers a variety High Speed Internet Service levels. We provide a description of the expected maximum transfer speeds associated with each service level High Speed Internet Service Packages and Prices, available at http://www.wcta.net/site/index.php/products-services/internet-access/high-speed-internet.
Speed. The speeds we identify for each High Speed Internet Service level are the maximum upload and download speeds that customers are likely to experience. We provision our customers’ modems and engineer our network to deliver the speeds to which our customers subscribe. However, we do not guarantee that a customer will actually achieve those speeds at all times. A variety of factors can affect upload and download speeds, including customer equipment, network equipment, congestion in our network, congestion beyond our network, performance issues with an Internet application, content, or service, and more.
Latency. Latency is another measurement of Internet performance. Latency is the time delay in transmitting or receiving packets on a network. Latency is primarily a function of the distance between two points of transmission, but also can be affected by the quality of the network or networks used in transmission. Latency is typically measured in milliseconds, and generally has no significant impact on typical everyday Internet usage. As latency varies based on any number of factors, most importantly the distance between a customer's computer and the ultimate Internet destination (as well as the number and variety of networks your packets cross), it is not possible to provide customers with a single figure that will define latency as part of a user experience.
Actual speed and latency performance. Actual speed and latency may vary depending upon network conditions and other factors. Actual performance of our broadband Internet access service in most cases will conform to national wireline broadband Internet speed and latency levels reported by the FCC. The FCC has reported cable ISP subscribers receive mean download speeds that are 109.33% of advertised speeds, and mean upload speeds that are 115.30% of advertised speeds. The FCC has reported DSL subscribers receive mean download speeds that are 99.64% of advertised speeds, and mean upload speeds that are 97.59% of advertised speeds. The FCC has reported fiber subscribers receive mean download speeds that are 107.73% of advertised speeds, and mean upload speeds that are 149.53% of advertised speeds. In addition, the FCC has reported mean latency delays for cable ISPs at about 22.24 milliseconds and 11.07 milliseconds for DSL ISPs.
Non-Broadband Internet Access (BIAS) Data Services.
Non-BIAS data services offered to end users. We offer specialized or non-BIAS data services over our network, sharing network capacity with our High Speed Internet Services. Specialized services include Internet Protocol Television, Voice Service over FTTH, dedicated bandwidth and point to point VLANs to business users.
Effects of specialized services on availability and performance of broadband Internet access service. Our specialized services have no effect on the availability and performance of our High Speed Internet Service.
Prices. Monthly prices for our High Speed Internet Service are available at http://www.wcta.net/site/index.php/products-services/internet-access/high-speed-internet.
Usage-based fees. Not applicable.
Fees for early termination. Not applicable.
Fees for additional network services. We offer wireless network set-up service for our residential customers. You can find fees for this service at http://www.wcta.net/site/index.php/products-services/internet-access/wireless-networking-wi-fi
Privacy Policies. We collect and store information from many sources as it relates to providing and maintaining service to our customers. Individually identifiable customer information, including usage data obtained in our role as your broadband Internet access service provider is only used to provide the service, improve your use of the service, manage our network, or as otherwise required or authorized by law.
We do not disclose individually indentifiable broadband Internet access service customer or use information to third parties except: (i) as necessary to provide our High Speed Internet Service and to manage our network; or (ii) in response to law enforcement requests, court order, or as otherwise required or authorized by law.
Inspection of network traffic. We routinely monitor network and traffic patterns. Except as necessary to employ virus and Spam filtering, we do not inspect the contents of network traffic.
Storage of network traffic information: DHCP (Dynamic Host Configuration Protocol) information is a code included in all network traffic that associates that traffic with a particular modem sending or receiving the traffic. We store DHCP information for at least 1 month. The data generated on each customer’s usage is divided into broad categories for analysis to help us monitor and predict trends in usage for our customer as a whole.
Provision of aggregate or anonymized network traffic information to third parties: We may disclose aggregate or anonymized network traffic information to third parties for purposes of providing and managing our High Speed Internet Service or if required by law.
Use of network traffic information for non-network management purposes: None.
Practices for resolving end-user and edge provider complaints and questions:
Questions: We will endeavor to answer questions promptly via email or voice.
Complaints: We will provide an initial response in writing within 15 business days of receipt. We will attempt to resolve complaints informally, escalating the matter to senior management if needed.
 47 CFR 8.3 and In re: Preserving the Open Internet, Broadband Industry Practices, Report and Order, 22 FCC Rcd 17905 (2010); Protecting and Promoting the Open Internet, Report and Order on Remand, Declaratory Ruling, Order, 30 FCC Rcd 5601 (2015).
 See FCC’s Office of Engineering and Technology and Office of Strategic Planning & Policy Analysis, 2016 Measuring Broadband America Fixed Broadband Report, A Report on Consumer Fixed Broadband Performance in the United States, (Dec. 1, 2016) (available at https://www.fcc.gov/reports-research/reports/measuring-broadband-america/measuring-fixed-broadband-report-2016) (“2016 Measuring Broadband America Report”). .
 2016 Measuring Broadband America Report, Validated Data, Statistical Averages, Download Sustained and Upload Sustained, (Dec. 1, 2016) (available at https://www.fcc.gov/reports-research/reports/measuring-broadband-america/validated-data-measuring-broadband-america-2016#block-menu-block-4) (data presented is unweighted mean percentage of advertised speeds, taken over a 24 hour, Saturday-Sunday period).
 The FCC has defined latency is the total length of time it takes a signal to travel from an origination point to the nearest server, plus the time for an acknowledgement of receipt to travel back to the origination point. The nearest server is the server providing the minimum round trip time.
 2016 Measuring Broadband America Report, Validated Data, Statistical Averages, Latency, (Dec. 1, 2016) (available at https://www.fcc.gov/reports-research/reports/measuring-broadband-america/validated-data-measuring-broadband-america-2016#block-menu-block-4) (data presented is unweighted mean latency in milliseconds, taken over a 24 hour, Saturday-Sunday period).