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NETWORK MANAGEMENT PLAN

As required by FCC regulations, CTC Telecom, Inc. provides the following disclosure regarding its Network Management Practices for delivery of Broadband Internet Services.  Feel free to contact our customer service staff with any questions at 1-800-426-0794.

 

NETWORK PRACTICES:

 
Blocking:  CTC Telecom does not have any network management practice (other than reasonable network management elsewhere disclosed) that blocks or otherwise prevents end user access to lawful content, applications, service, or non-harmful devices.
 
Throttling:  CTC Telecom does not have any network management practice (other than reasonable network management elsewhere disclosed) 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 Prioritization:  CTC Telecom does not have any network management practice that directly or indirectly favors some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, or resource reservation, to benefit an affiliate.
 
Paid Prioritization:  CTC Telecom does not have any network management practice that directly or indirectly favors some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, or resource reservation, in exchange for consideration, monetary or otherwise.
 
Congestion Management: CTC Telecom does not engage in any specific network management practice to mitigate the effects of network congestion by blocking specific types of traffic or limiting certain connections that may lead to network congestion.  It does, however, monitor network utilization and proactively augment capacity as needed and feasible to minimize or avoid network congestion.
 
Application-Specific Behavior:  CTC Telecom does not block or rate-control specific protocols or protocol ports, nor does it modify protocol fields in ways not prescribed by the protocol standard, or otherwise inhibit or favors certain applications or classes of applications.
 
Device Attachment Rules:  CTC Telecom makes available xDSL modems and Wireless Routers for purchase or lease to its customers.  While customers may purchase their own modems or routers from other sources, this practice is discouraged as CTC is not able to provide support for those products and they may provide inferior performance if they do not meet the technical requirements based on the subscribed Internet connectivity speeds and equipment compatibility.  No restriction is made on connection of customer-owned equipment so long as that equipment is not harmful to the network except that residential customers may not connect commercial or business-oriented servers such as web servers, email servers, news feeds servers, proxy servers, file servers, ftp servers, game servers or to run any other server application or to provide network or hosting services unless subscribing to business-rate service plan.
 
Security: CTC Telecom reserves the right to protect the security and integrity of its network and its customers by any lawful means it deems appropriate which may include blocking of malicious software (often referred to as “malware”), such as viruses, worms, spyware, and distributed denial of service (“DDoS”) attacks.  These not only can adversely affect the network, but also can result in harm to customers’ computers and the quality of service they receive, compromise their data, and harm third parties as well.  CTC does not provide any network protection for customer owned Internet-connected devices; however, it makes available to its customers for purchase personal firewall and anti-malware software to protect their devices from infections and attacks. 
 
CTC does not employee any specific type of triggering conditions that cause a blocking condition to be invoked to provide end-user security or security to the network but does work with upstream service providers to identify and block attacks on the company’s network and on its end users including but not limited to DDoS attacks.

 

PERFORMANCE CHARACTERISTICS

 
Service Description
 
CTC Telecom provides Broadband Internet service over a variety of technologies including ADSL and VDSL service, fiber-to-the-premise/home (FTTP aka FTTH), Terrestrial Fixed Wireless, also known as Point to multi-point Wireless service, and both Terrestrial Fixed and Mobile wireless LTE service.  Available services and Internet speed tiers vary depending on geographic location and technology of delivery.  Full descriptions with pricing and features for Broadband service which are available in your geographic region can be found at our website at http://www.ctcweb.net/services or by calling our customer service staff at 800-426-0794. 
 
The most appropriate package for a particular customer will depend upon a variety of factors, including the types of applications typically used and the number of users in the household, the features, branding, and pricing of our service offerings.  Not all packages are available in all geographic areas.   
Customers are encouraged to contact our customer service staff at 800-428-0794 to determine what speeds and service technologies are available at a particular address. 
 
Internet Service Technology
  1. xDSL Broadband: CTC utilizes industry-standard ADSL and VDSL service technologies to deliver broadband Internet access to customers over traditional copper telephone cable facilities.  CTC Telecom owns copper facilities in Ada County, Idaho.  In Washington and Adams Counties, Idaho, CTC Telecom utilizes copper facilities, which are owned by CTC’s parent company, Cambridge Telephone, under a wholesale contract agreement based on an Interstate pricing tariff filed with the FCC.  This technology is asymmetrical by design offering faster download speeds than upload speeds.  The service is distance sensitive so that the further the customer is from a central office or fiber-fed remote cabinet, the slower the available speeds.  Thus, faster speed packages will be available to customers with shorter copper cable loops and customers with long copper loops can only purchase slower speed service packages.  Some customers may experience slower speeds than the maximum listed on a service package due to distance.  In addition, xDSL technology signaling and protocol overhead could net a realized speed up to 20% lower than advertised speeds.  Generally, speeds should not vary during peak usage. Latency is typically between 15 and 30 milliseconds when the connection is idle.
  2. An ADSL or VDSL modem which may be customer owned or leased from CTC is installed at each home which acts as a gateway to the Internet for the customer’s Internet ready devices. This modem may have WIFI integrated or a separate WIFI router may be installed behind the modem.  Broadband Internet delivered using xDSL technology is well suited for real-time applications.
  3. Fiber to the Premise/Home (FTTP aka FTTH) Broadband: CTC utilizes industry-standard passive optical network (PON) technology to deliver broadband Internet access to customers over fiber optic facilities.  CTC Telecom owns fiber facilities in Ada County, Idaho.  In Washington and Adams Counties, Idaho, CTC Telecom utilizes fiber facilities, which are owned by CTC’s parent company, Cambridge Telephone, under a wholesale contract agreement based on an Interstate pricing tariff filed with the FCC.  This technology is asymmetrical by design offering faster download speeds than upload speeds and unlike xDSL technology, is not distance sensitive.  This means that customers serviced by fiber can subscribe to any service offering available in that geographic area.  An Optical Network Terminal (ONT or ONU), provided by the CTC, is installed at each home which acts as a gateway to the Internet for the customer’s Internet ready devices. A customer-owned router is normally connected to the ONT to provide connectivity to multiple end-devices.
  4. FTTP technology signaling and protocol overhead could net a realized speed up to 5% lower than advertised speeds.  Generally, speeds should not vary during peak usage. Latency is typically between 15 and 30 milliseconds when the connection is idle.  Broadband Internet delivered using FTTP technology is well suited for real-time applications.
  5. Terrestrial Fixed Wireless Broadband: CTC Telecom offers Internet service to select residential and business customers in Ada, Adams, and Washington Counties, Idaho, who cannot be served utilizing xDSL or FTTP broadband service technologies.  CTC’s Fixed Wireless is asymmetrical by design offering faster download speeds than upload speeds and may be distance sensitive.  Specific service packages are available to Fixed Wireless customers which are priced differently from xDSL and FTTP service offering.  This technology employs the use of a company-owned Access Point Radio and antenna, usually located on a tower or hilltop, which broadcasts a wireless signal in a specific pattern to provide service to multiple locations.  A subscriber radio is installed on the exterior of the residence or business which communicates back to the Access Point and which acts as a gateway to the Internet for the customer’s Internet ready devices.  A customer-owned router is normally connected to the subscriber radio to provide connectivity to multiple end-devices.
  6. Terrestrial Fixed wireless provides bandwidth that is aggregated at the Access Point and customers may experience some bandwidth degradation during peak usage. Latency is typically between 30 and 50 milliseconds when the connection is idle.  Broadband Internet delivered using Terrestrial Fixed wireless technology is acceptable for most real-time applications.
  7. LTE Terrestrial Fixed Broadband: CTC Telecom offers LTE Broadband service to select residential and business customers in Adams, and Washington Counties, Idaho, who cannot be served utilizing xDSL or FTTP broadband service technologies.  This technology employs the use of an LTE Wireless Radio and antenna, located on a tower, which broadcasts a signal in a specific pattern to provide service to multiple locations.  A subscriber LTE modem is installed inside the residence or business which communicates back to the LTE Radio.  A customer-owned router is normally connected to the LTE modem to provide connectivity to multiple end-devices and to acts as a gateway to the Internet for the customer’s Internet ready devices.  Broadband Internet delivered using LTE Fixed wireless technology is not suitable for most real-time applications.
  8. LTE Mobile Broadband: CTC Telecom offers LTE Broadband service to residential and business customers in Adams, and Washington Counties, Idaho.  This technology employs the use of an LTE Wireless Radio and antenna, located on a tower, which broadcasts a signal.  Subscribers need to purchase, from CTC Telecom, an LTE capable handset (cell phone).  This service is mobile and can be used any location that an LTE signal is available.  Speeds are on this service are best-effort and will vary depending on distance from the tower and number of users simultaneously downloading data.  Broadband Internet delivered using LTE mobile broadband technology is not suitable for most real-time applications.
Data Usage Allowances
CTC’s Broadband Internet service offerings are not subject to a monthly data allowance with the exception of LTE Mobile Broadband.  LTE Mobile Broadband customers will receive a text when they reach 75%, 80%, 90%, 98, and 100% of the plan’s monthly data allowance. 
 
Performance Characteristics
 
Expected Performance
 
Internet services plans provided by CTC are sold as “up to” speeds and are not guaranteed.  Service plan speeds are the provisioned download and upload speeds configured on the customers port on CTC’s network equipment.  When feasible, CTC may over-provision ports to account for technology overhead.  Actual speeds of the service can be affected by issues under CTC’s control including network congestion, condition of CTC’s outside plant facilities, and copper cable loop length, as well as issues outside of CTC’s control including customer’s location, quality or condition of the wiring inside the home or business, combined usage by customer’s devices inside the home or business, customer’s networking hardware, wireless interference, and websites or content providers that customer may be accessing on the Internet.
 
Latency
 
Latency is one measurement of Internet performance.  Latency refers to the average time it takes for a packet of data to travel from one designated point to another on a network.  Since many communication protocols depend upon an acknowledgement from one end of a connection that packets were received successfully, or otherwise involve transmission of data packets back and forth along a path in the network, latency is usually measured by round-trip time.  Latency is typically measured in milliseconds.  Some applications are particularly sensitive to latency such as some high-definition multiplayer online games and virtual private networking (VPN) connections.  Latency generally has no significant impact on typical everyday Internet usage.  Latency varies based on any number of factors, notably the distance ( and number of intermediate routers) between a customer's computer and the final Internet destination with which the customer is interacting (as well as the number, variety, and quality of networks the customer’s packets cross).  Due to these reasons, each customers experience will be different.
 
Packet Loss
 
Packet loss is a result of data packets that are sent by a source to a destination, but for a variety of reasons, may not reach their destination.  Most packet loss is due to network traffic congestion but also may be due to network or customer premises equipment issues.  Occasional minimal packet loss is to be expected.  CTC customers should experience less than 1% packet loss; however, it is the goal of CTC to achieve no packet loss in our network.  Any customer whose service is adversely affected due to packet loss should contact CTC customer support at 208-257-3314 to assist with troubleshooting and resolution of the issue.
 
Speed
 
Customers experienced Internet speed is likely to vary do some degree.  Speed is normally measured by utilizing a speed test website such as http://www.speedtest.net.  These sites measure the throughput speeds between the customer’s Internet connected device and a server connected to the Internet.  The above listed site is “closer” to CTC customers in terms of the network than other sites that a customer may use to test speeds and thus will produce more accurate results than a site that may require the test packets to be sent across multiple networks outside the control of CTC.  If a customer is experiencing slow Internet access or buffering issues, CTC recommends contacting our support staff to troubleshoot or assist in determining if a faster Internet service plan may be needed.  As follows are some factors that may negatively affect a customer’s speed experience:
  1. Customer Premise Equipment (CPE) – Wireless routers, modems, computers and other Internet connected devices, including the age of the technology, wireless interference, configuration, and compatibility can all affect the connection speed and overall customer experience. Wirelessly connected devices are more likely to experience speed fluctuations and slow connectivity than wired connected devices due to wireless interference and congestion.  Older wireless devices can slow the overall wireless performance for all devices on the network if the wireless router not configured correctly or if some features and capabilities are not supported.  Wireless interference between neighbor’s wireless routers and other technologies using the same frequency can slow and disrupt wireless connectivity and result in slow Internet connectivity.  As Internet connection speeds increase, newer technology may be required to accommodate the speeds.  This is true for both the Internet connected devices as well as the networking equipment at the customer premises.  Over time CPE equipment will fail and need to be replaced.  CTC technical support can help in troubleshooting to determine if equipment needs to be upgraded or replaced.
  2. Customer bandwidth utilization – Certain applications and devices may consume varying amounts of available bandwidth on a customer’s service.  For example, if a customer is uploading files to cloud storage, this may consume all available upload bandwidth and render the service almost unusable.  Streaming video, especially in high resolution, may consume a large amount of downstream bandwidth.  Interactive gaming also consumes larger amounts of downstream and upstream bandwidth. 
  3. Malware or Viruses – The presence of malware on customer devices can not only slow down the device performance but also may consume Internet bandwidth.  CTC recommends that Internet connected devices have some type of malware protection and makes software available for purchase to its customers.
  4. Internet backbone routing – The physical distance and network path between the customer and the site they are connecting to may affect the speed of the Internet experience.  This may include network congestion and routing issues on upstream service providers to CTC or to the destination site.  While there are many redundant Internet paths, if one path is experiencing issues, the alternate paths may become overloaded handling the additional traffic and all Internet traffic on that path may be adversely affected.
  5. Destination site bandwidth restrictions – Most web servers have limits on the number of concurrent connections, overall available bandwidth, and individual connection bandwidth.  This may limit the speed and availability of these web servers to individuals accessing those servers if the destination server does not have sufficient capacity to serve all the visitors at the same time.
  6. Provider network issues – CTC does not monitor individual customer’s network connections.  It does however actively monitor its backbone networks for congestion and network failure.  CTC takes a proactive approach to network congestion and if points of congestion are identified, CTC will augment capacity or upgrade equipment as needed.  It is possible for customer network connections to degrade which will negatively affect a customer’s service. Customers who are experiencing service issues are encouraged to contact our knowledgeable support staff to address concerns.
CTC offers a variety of different speed plans based on available service delivery technologies, price, and customer location.  CTC recognizes that different customers have different needs and our customer service staff can assist in determining which plan will best meet those needs.  CTC is actively upgrading network equipment and replacing older copper cable with fiber optic cable to enable delivery of faster broadband Internet services.  Once the fiber optic-based service is available, customers are contacted advising them of faster available plans.  Customers are converted to the newer technology as needed at no cost to the customer.
 
Suitability of the Service for Real-time Applications.  CTC’s broadband Internet access service is generally suitable for typical real-time applications, including voice applications, video chat applications, gaming, Internet video, VPN connections, etc. 
Impact of Non-Broadband Internet Access Service Data Services: CTC Telecom offers Voice over Internet (VoIP) services as well as dedicated point-to-point data services to business customers.  These services have no affect on the availability or performance of our Broadband Internet services
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COMMERCIAL TERMS:

 
            Pricing: CTC maintains current pricing for services on our website located on our website at https://ctcweb.net.  Pricing is based on geographic area as services offered in Adams, Boise, and Washington Counties, Idaho are impacted by regulated telephone company filed Interstate Tariffed Rates where-as services offered in Ada County, Idaho is a non-regulated service area.  Broadband services purchased in Adams, Boise, and Washington Counties require the purchase of a local telephone line and have a 6-month minimum term.  If this term is not met, an early termination fee of $25.00 is assessed.  Broadband Internet service from CTC is not subject to data usage allowances.  Rates listed are not inclusive of regulatory fees; Federal, State, and Local taxes.
            Privacy Policies:   CTC Telecom values the privacy of its customers are strives to maintain that privacy.  CTC does not engage in any network monitoring that tracks customer’s Internet activity except as may be required by law enforcement or for protection of its network from malicious activity.  CTC does not collect, store, or use traffic information to market services or products to its customers nor do we share information with affiliated or unaffiliated companies.  CTC does maintain logs of IP address assignment for customers which may be used to manage network performance, ensure that the network is operating efficiently, track illegal Internet activity.
            Redress Options:  Customers may contact CTC Telecom in a variety of manners to address questions, resolve complaints, or to make changes to their services provided by CTC.  To contact our customer service staff, customers may call 1-800-426-0794 or email our staff at customerservice@ctctele.com.  If customers are not satisfied with the resolution to complaints presented by our customer service staff, customers may request a callback from one of our senior managers.  Our secure website is located at https://ctcweb.net/contact-us and lists all of our local contact numbers as well as a contact form submission for inquiries.
Customers may also file consumer complaints with the Federal Communication Commission (FCC) at their website address https://consumercomplaints.fcc.gov/hc/en-us