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Network Management Practice - Gearheart Communications

Legal

Network Management Practice

Inter Mountain Cable / Mikrotec CATV Disclosure of Broadband Internet Access Service Network Management Practices, Performance and Commercial Terms

Introductory Note

This disclosure applies solely to the broadband services offered by Inter Mountain Cable (IMCTV) / Mikrotec CATV on a standardized basis to residential customers, small businesses and other end-user customers. This disclosure does not apply to any other broadband service (e.g., specialized or enterprise services) or to any dial-up Internet access service. IMCTV / Mikrotec CATV may revise this disclosure from time to time without notice by posting a new version of this disclosure here.

Accordingly, users of Inter Mountain Cable / Mikrotec CATV Internet access services should consult this document regularly to ensure that they remain aware of changes to the practices described in this disclosure. In the event of a conflict between any subscriber agreement or the Acceptable Use Policy and this disclosure, the terms of the subscriber agreement or Acceptable Use Policy shall govern. This disclosure does not create enforceable rights in the subscriber or any third party edge provider.

Introduction to Our Broadband Services

Inter Mountain Cable / Mikrotec CATV operates a robust and modern hybrid fiber cable (HFC) network, which spans portions of Eastern Kentucky, Southern West Virginia and Western Virginia. IMC provides a variety of services over this HFC network including Voice, Video and Broadband Internet Access. Inter Mountain Cable / Mikrotec CATV contracts with Mikrotec Internet and the East Kentucky Network for access to the outside world via redundant fiber optic rings, then peering with major Internet providers in Lexington, KY.

Core Network Overview

IMC utilizes a 10Gig core network to transport all broadband services to the rest of the world. No prioritization or discrimination of forwarding traffic is performed, either within a service type or between service categories.

Distribution Network Overview

Inter Mountain Cable / Mikrotec CATV utilizes 1 Gig distribution switches to transport broadband services. No prioritization or discrimination of forwarding traffic is performed, either within a service type or between service categories.

Access Network Overview

Inter Mountain Cable / Mikrotec CATV operates an access network with 2 service types, Voice and Broadband Internet.

  • This access network supports DOCSIS 3.0 and DOCSIS 3.1 cable deployments as well as traditional video components.
  • Video is radio frequency (RF) based and does not interact with Broadband or Voice.
  • Voice traffic (if subscribed to) is prioritized over Broadband Internet Access in the last mile.
  • Available bandwidth packages range from 256Kbit to 750Mbit download speeds.

Network Edge Overview

Currently Inter Mountain Cable / Mikrotec CATV contracts with Mikrotec Internet Services (MIS) and the East Kentucky Network (EKN) to fulfill its edge network requirements:

  • EKN provides a 10 G redundant fiber optic loop from our Harold location to EKN’s facility in Winchester KY.
  • MIS provides a 10 G redundant fiber optic loop from EKN’s Winchester facility to MIS’s Lexington facility.

General Network Principals

Inter Mountain Cable / Mikrotec CATV, as much as reasonably possible, designs and operates its network based on the following guiding principals:

  • The access network is directly facing the customer. The last mile loop is a shared resource to a specific geographic location of customers. Because of last mile technology constraints, it has the highest potential for congestion. As such we implement traffic prioritization on the subscribers DOCSIS connection which insures:

Voice service is prioritized first.

Broadband Internet service is prioritized second.

  • Subject to congestion, we endeavor to provision subscriber broadband Internet packages with additional capacity to cover protocol overhead.
  • Maintaining the security of the network is a top priority and, to this end, we implement commonly accepted security best practices subject to cost and technical considerations.

Network Practices

Congestion Management Practices

  • While Inter Mountain Cable / Mikrotec CATV does not currently utilize any form of congestion management (other than giving voice traffic priority over Internet access), Inter Mountain Cable / Mikrotec CATV may in the future use various tools and techniques to manage its network, deliver its service, and ensure compliance with the Acceptable Use Policy available at gearheart.pivotdev.com/legal/ and the Terms of Agreement available at gearheart.pivotdev.com/legal/. These tools and techniques may be dynamic, like the network and its usage, and may change frequently. For example, these network management activities may include identifying spam and preventing its delivery to customer email accounts, detecting malicious Internet traffic and preventing the distribution of viruses or other harmful code or content and using other tools and techniques that Inter Mountain Cable / Mikrotec CATV may implement in order to meet its goal of delivering a high quality broadband Internet experience to its customers.

Non-Discrimination Practices

  • Inter Mountain Cable / Mikrotec CATV does not currently have any policy in place that would prefer one type of Broadband Internet traffic, protocol, provider, service, application or site over another (other than giving voice traffic priority over Internet access). Subject to the AUP and the security practices listed below, the customer is free to choose any device type, protocol, service, provider, application, etc., without experiencing any type of service degradation or slow down. Inter Mountain Cable reserves the right (but does not undertake the responsibility) to block or degrade content, applications and services that are unlawful, that may violate the rights of third parties (e.g., copyright infringement) or that may pose a harm to our network or other customers.

Device Attachment Rules

  • Inter Mountain Cable / Mikrotec CATV operates with a strict company owned modems only policy and does not allow attachment of unapproved devices to it’s network. However, in the interest of customer service, Inter Mountain Cable does provide a device free of charge to each of it’s customers.
  • Inter Mountain Cable / Mikrotec CATV does not restrict what types of devices are eligible to connect to our network, however we can only provide direct end user support for devices for which we are familiar. In addition all attached devices must be capable of making a valid access request (DHCP). At each cable modem we provide a single ethernet port or USB port for Broadband Internet and if a customer wishes to use multiple devices, the customer will need to provide their own router, which will provide NAT. For residential service, each cable modem customer is dynamically assigned a single public IPv4 address. For commercial service, multiple IPs are available if needed. Inter Mountain Cable / Mikrotec CATV reserves the right (but does not undertake the responsibility) to prohibit devices that may pose a harm to our network or other customers.

Security Practices

  • In an effort to maintain the security of the Inter Mountain Cable / Mikrotec CATV network and our subscribers as well as to abide by good Internet Citizenship,Inter Mountain Cable / Mikrotec CATV utilizes the following listed security practices, which affect forwarded traffic delivered to our subscribers. In addition to this list, Inter Mountain Cable / CATV utilizes multiple other mechanisms to promote the Confidentiality, Integrity and Availability of the Inter Mountain Cable / Mikrotec CATV network; however, only those having a direct bearing on customer forwarded traffic are listed here.

Access Network

  • In order to assist in the world wide fight against unsolicited commercial email (SPAM), commonly accepted network practices dictate that ISP’s block outbound traffic destined for the SMTP service (port 25). This doesn’t preclude a customer from being able to run a mail server at their site, but does require a simple change to the normal configuration, i.e. using our mail server as a smart relay host.
  • Only traffic destined for a valid IP/mac address pairing is terminated to a subscriber; broadcast flooded traffic is not delivered to the end user.
  • An end subscriber that sustains more than 5 pps of ARP request for a 15 second period is automatically shutdown for 30 seconds. After the 30-second blacklist period the port is automatically re-enabled and the counters reset.
  • An end subscriber that sustains more than 5 pps of DHCP traffic on the Broadband Internet service for a 15 second period is automatically shutdown for 30 seconds. After the 30-second blacklist period the port is automatically re-enabled and the counters reset.
  • DHCP broadcast requests destined to UDP port 67 (attempting to connect to a DHCP server) are not permitted to terminate to a subscriber end point.
  • Traffic entering our access network sourced from RFC1918 address space is denied.
  • In the event of malicious activity, Inter Mountain Cable / Mikrotec CATV may implement a temporary block at the network level restricting traffic, which may be harmful to the network as a whole. If such activity is necessary, the affected customer(s) would be contacted and worked with to remove the underlying threat.
  • Inter Mountain Cable / Mikrotec CATV collects performance characteristics in the aggregate at this level (link level utilization), which allows us to proactively plan in advance proper network scaling.
  • If needed, when working with a subscriber to troubleshoot a problem, properly trained staff within Inter Mountain Cable / Mikrotec CATV may perform real time traffic analysis of subscriber traffic.

Distribution Network

  • In the event of malicious activity, Inter Mountain Cable / Mikrotec CATV may implement a temporary block at this network level restricting traffic, which may be harmful to the network as a whole. If such activity is necessary, the affected customer(s) would be contacted and worked with in an effort to remove the underlying threat.
  • Inter Mountain Cable / Mikrotec CATV collects performance characteristics in the aggregate at this level (link level utilization), which allows us to proactively plan in advance proper network scaling.
  • If needed, when working with a subscriber to troubleshoot a problem, properly trained staff within Inter Mountain Cable / Mikrotec CATV may perform real time traffic analysis of subscriber traffic.

Core Network

  • In the event of malicious activity, Inter Mountain Cable / Mikrotec CATV may implement a temporary block at this network level restricting traffic, which may be harmful to the network as a whole. If such activity is necessary, the affected customer(s) would be contacted and worked with to remove the underlying threat.
  • Inter Mountain Cable / Mikrotec CATV collects performance characteristics in the aggregate at this level (link level utilization), which allows us to proactively plan in advance proper network scaling.
  • If needed, when working with a subscriber to troubleshoot a problem, properly trained staff within Inter Mountain Cable / Mikrotec CATV may perform real time traffic analysis of subscriber traffic.

Edge Network

  • In the event of malicious activity, Inter Mountain Cable / Mikrotec CATV may implement a temporary block at this network level restricting traffic, which may be harmful to the network as a whole. If such activity is necessary, the affected customer(s) would be contacted and worked with to remove the underlying threat.
  • Inter Mountain Cable / Mikrotec CATV collects performance characteristics in the aggregate at this level (link level utilization), which allows us to proactively plan in advance proper network scaling.
  • Inter Mountain Cable / Mikrotec CATV collects netflow data on all external traffic flows to better understand network attacks.
  • If needed, when working with a subscriber to troubleshoot a problem, properly trained staff within Inter Mountain Cable / Mikrotec CATV may perform real time traffic analysis of subscriber traffic.
  • Traffic entering our network edge from the external side, sourced from an IP address within one of our network ranges is denied.
  • Traffic traversing our network edge sourced from RFC1918 address space is denied.
  • Traffic traversing our network edge sourced from loopback, link local or ‘this’ address (as defined in RFC 3330) is denied.

Performance Characteristics – Service Description

  • Inter Mountain Cable / Mikrotec CATV provides a DOCSIS 2.0 based cable modem service. Data rates are available from 256k to 6Mbps depending on service needs. Our cable modem service is based on a “best effort” technology. That means that all advertised speeds are an “up to” rating and not a committed information rate.
  • The “actual” speed that a customer will experience while using the Internet depends upon a variety of conditions, many of which are beyond the control of an ISP such as Inter Mountain Cable / Mikrotec CATV. These conditions include:
    1. Performance of a customer’s computer, including its age, processing capability, its operating system, the number of applications running simultaneously, and the presence of any adware and viruses.
    2. Type of connection between a customer’s computer and modem. For example, wireless connections may be slower than direct connections into a router or modem. Wireless connections also may be subject to greater fluctuations, interference and congestion. IMC does not recommend wireless modem connections for use with its higher speed tiers as many wireless connections do not perform at the speeds delivered by these tiers.
    3. The distance packets travel (round trip time of packets) between a customer’s computer and its final destination on the Internet, including the number and quality of the networks of various operators in the transmission path. The Internet is a “network of networks.” A customer’s connection may traverse the networks of multiple providers before reaching its destination, and the limitations of those networks will most likely affect the overall speed of that Internet connection.
    4. Congestion or high usage levels at the website or destination limit speed. If a large number of visitors are accessing a site or particular destination at the same time, your connection will be affected if the site or destination does not have sufficient capacity to serve all of the visitors efficiently.
    5. Gating of speeds or access by the website or destination limit speed. In order to control traffic or performance, many websites limit the speeds at which a visitor can download from their site. Those limitations will carry through to a customer’s connection.

For these reasons, Inter Mountain Cable / Mikrotec CATV, like all other ISPs, advertises speeds as “up to” a particular level, and does not guarantee them.

  • The customer premises is supplied either one 10/100 meg ethernet port or one USB port.
  • Data obtained from our sampling of a hosted speedtest.net server has shown that our average performance speeds for the period from 08/01/2011 through 11/11/2011, including all customer locations and packages, were as follows (peak time is from 7:00pm until 11:00pm):
    • Overall Download 2.78Mbps
    • Overall Upload 482Kbps
    • Overall Latency 64ms
    • Peak Download 2.64Mbps
    • Peak Upload 364Kbps
    • Peak Latency 99ms
  • Inter Mountain Cable / Mikrotec CATV does prioritize voice traffic on each individual account (i.e. your voice traffic will take priority over your data traffic).

Impact of Specialized Services

  • Inter Mountain Cable / Mikrotec CATV does not currently offer any specialized network services that would negatively impact the last mile capacity or the performance of broadband internet access service.

Terms and Conditions of Service Pricing

  • In order to continually maintain current pricing in this area, we have chosen to provide a link to our most current pricing and promotions. Please see gearheart.pivotdev.com/broadband/ for complete pricing information.

Privacy Policies

  • Inter Mountain Cable / Mikrotec CATV reserves the right to inspect and analyze network traffic to assist in troubleshooting or service recovery, to evaluate our services, to provide our services and to detect unauthorized activity. Aggregate and specific analysis information may be shared with third parties to assist in said troubleshooting, service recovery, evaluation, provision or detection, however no personally identifiable information would be included except to the extent authorized by the customer, required by law or regulation, allowed by the privacy provisions of the AUP, allowed by our privacy statement available at gearheart.pivotdev.com/legal/ or allowed by 47 USC 551. All subscribers are required to abide by our Terms of Agreement (TOA) available at gearheart.pivotdev.com/legal/ . In the event of a conflict between the Network Management Practices described in this document and the TOA or the AUP, the terms of the TOA or AUP shall govern. Section 1 of the AUP contains additional privacy policies.

Redress Options

End User / Customer:

  • All service concerns should initially be addressed to the billing office at 800.635.7052. Our customer support staff will take ownership of the issue and work with internal resources to resolve any problems.

Edge Provider:

  • All complaints should be addressed to abuse@imctv.com. Customers found to be acting in violation of the AUP will receive two warnings and service may be disrupted or discontinued upon the third complaint.
  • Customer information will only be released upon receipt of a bona fide subpoena or other legal requirement.

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