Open Internet Principles

The Federal Communications Commission (FCC) issued rules to preserve the Internet as an open platform. These rules went into effect on November 20, 2011 and can be found here. All Internet service providers (ISPs) are required to post information regarding various issues so that consumers, both residential and business, can make informed choices about choosing an Internet service provider. Here is information regarding our services in compliance with the FCC’s rules. These policies serve as a supplement to the existing terms of service.

The FCC’s rules focus on these primary issues:

Transparency: Fixed and mobile broadband providers must disclose the network management practices, performance characteristics, and terms and conditions of their broadband services;

No blocking: Fixed broadband providers may not block lawful content, applications, services, or non-harmful devices; mobile broadband providers may not block lawful Web sites, or block applications that compete with their voice or video telephony services; and

No unreasonable discrimination: Fixed broadband providers may not unreasonably discriminate in transmitting lawful network traffic.

Reasonable network management: ISPs may engage in reasonable network management to maintain a high quality of service for broadband Internet access.

Network Practices

ISPs must disclose their network practices, specifically in the four general areas listed below. ISPs may not block lawful content, applications, services, or non-harmful devices, subject to reasonable network management. An ISP may not block consumers from accessing lawful Web sites, subject to reasonable network management; nor shall the ISP block applications that compete with the provider’s voice or video telephony services, subject to reasonable network management. ISPs may not unreasonably discriminate in transmitting lawful network traffic over a consumer’s broadband Internet access service, although, reasonable network management shall not constitute unreasonable discrimination.

The FCC’s rules state that a network management practice is reasonable if it is appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service.

Congestion Management: All wireless systems are necessarily shared ones. Typical constraints come primarily from capacity limitations of base-station radios. To a lesser extent, there are also capacity limitations of customer premise equipment and the overall capacity of towers/stations. In order to ensure all our subscribers maximally share the bandwidth available to the system, we employ several techniques. These include limiting the number of subscribers assigned to any base-station radio, setting base-station radio parameters to equitably share bandwidth when approaching saturation, and balancing the amount of bandwidth that is distributed to each tower/station to be used by each component in the system.

There are a number of other congestion management techniques available to employ, such as limiting the total number of Internet connections per user, limiting the total traffic transfer per user, barring certain types of traffic, and others. We do not employ any of those techniques, at this time.

As described in the next section, all types of lawful traffic are permitted on our system. We set base-station radios so that, during times of especially high traffic, all subscribers’ throughput limits are automatically adjusted (proportionally to their service plan speeds) to prevent any individual subscribers from dominating the usage. As soon as this automatic adjustment restores the capacity, the limiting is removed. This process can occur on a second-by-second basis. It can be imperceptible to the typical subscriber, unless the congestion grows extreme. This sort of limiting occurs more frequently during the evening hours, when usage is typically at its highest.

We apply a similar system of automatic adjustment at the tower/station level, when total network usage exceeds the available bandwidth. This also is a largely imperceptible second-by-second process. We make every effort to purchase sufficient bandwidth to make this adjustment a rare occurrence.

We do not currently apply usage limits upon our subscribers. Occasionally, we discover a subscriber’s connection in continual, full use. We may contact such subscribers to determine if viruses or other malware are afflicting their systems. We sometimes counsel and assist individual subscribers in monitoring their family’s or organization’s excessive use of peer-to-peer applications or continual long-form video streaming. Continual use of our network is not considered teasonable use and is not permitted.

Application-Specific Behavior: We block no applications from our network. Some classes of application are favored over others. For example, time-sensitive, VoIP (voice over Internet protocol telephony) data is prioritized over video, web, and mail traffic. Though we permit peer-to-peer traffic, we give it a lower priority than video, web, and mail. Soon, when our own VoIP product is introduced, its routes and quality will be optimized, but we will not prioritize our own product over third-party VoIP products. We will have no control over how well third parties choose their routes, etc. We do not block any ports, at this time.

Device Attachment Rules: Our legacy network requires proprietary devices, which match those at the towers/stations. Only these proprietary devices, which have met our technical standards and are provided by us, may be attached to the network. Our WiMAX™ system does permit attachment of any compatible, non-mobile, WiMAX™ devices, however these need to be qualified by us and will not authenticate on our system without paid subscriptions.

Any devices with ethernet connectivity may be attached to our network at the demarcation point of our customer premise equipment. This would include personal computers and routers.

Security: Utilizing the most advanced techniques, we encrypt all traffic in our base-station radios at the towers and additionally in the core router at our network operations center.

Performance Characteristics

ISPs must disclose the following network performance characteristics:

Service Description: All of our current service is delivered via terrestrial-based, fixed-wireless technology utilizing 802.11 (a), (b), (g), and proprietary WiFi protocols. Our new service utilizes 802.16 (e) WiMAX protocol systems.

All speeds listed on our subscription-plan pricing pages are maximums. Though subscribers can generally expect to experience these maximums, average speeds will generally be approximately 80% of these. Our WiMAX™ upgrades deliver higher averages and more consistent speeds. Latency for all data traffic is maintened below 200 ms and, with 802.16e WiMAX™ equipment, under 60 ms for voice.

Our service is suitable for basic VoIP, virtual private networks, gaming, long-form audio streaming, short-form video streaming, and other real-time applications. With WiMAX™, each of these is more effectively served. In particular, VoIP, including our own high-quality offering, performs especially well.

Impact of Specialized Services: We do not currently offer any specialized services to subscribers. We will introduce a high quality VoIP service in the future, but it will have no negative impact on the rest of the system. Since our network is a shared one with finite capacity, long-form continuous streaming, particularly that of high bit-rate (HD, etc.) video, can bring it to saturation. Our legacy network systems do not effectively support widespread streaming use. Our new WiMAX™ upgrades more effectively support video streaming.

Commercial Terms

ISPs must disclose the commercial terms of their broadband Internet access services including the three categories listed below.

Pricing:
Our subscription plans, equipment fees, seasonal plan, and payment terms are described on the following web pages:
home broadband plans
business broadband plans
equipment lease
seasonal plan
payment policies

Privacy Policies: On a continual basis, our core router does inspect the network traffic in order to prioritize traffic classes such as VoIP, as described above. This is an automatic process, which does not involve human monitoring. No browsing information is stored or shared unless we are ordered to do so with legitimate warrants from bona fide, law-enforcement agencies. No other third parties have access to our network traffic, and this traffic is not subject to any other management inspection.

Redress Options: We respond to all complaints and questions in a timely manner. A live, 24-hour, telephone-support system is in place 888-939-2568 (888-9ez-Cloud). Any issues not easily resolvable are promptly escalated to local personnel.

FCC Notice

If a customer believes that these open Internet rules are not being met, the customer may file an informal complaint at the Federal Communications Commission. The FCC urges customers to submit any complaints via its website here. Customers may also file a formal complaint at the FCC using Part 76 of the Commission’s rules.