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Highland
FCC Transparency Rule

 

COMPLIANCE STATEMENT AND DISCLOSURES FOR
FCC “TRANSPARENCY RULE”

 
Highland Communications, LLC (the “Company”) provides this information in its good faith effort to comply with the disclosures required by the Federal Communications Commission (“FCC”) revised “transparency” rule effective on June 11, 2018.  In this regard, we endeavor through these disclosures to provide consumers with information necessary for them to make informed choices about the purchase and use of the Company’s broadband Internet access service (the “Company’s Service”).
 
            To place our compliance efforts in context, the FCC transparency rule states as follows:
 
 

 (a)       Any person providing broadband Internet access service shall publicly disclose accurate information regarding the network management practices, performance characteristics, and commercial terms of its broadband Internet access services sufficient to enable consumers to make informed choices regarding the purchase and use of such services and entrepreneurs and other small businesses to develop, market, and maintain Internet offerings.  Such disclosure shall be made via a publicly available, easily accessible website or through transmittal to the Commission. 
 (b)      Broadband internet access service is a mass-market retail service by wire or radio that provides the capability to transmit data to and receive data from all or substantially all Internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up Internet access service. This term also encompasses any service that the Commission finds to be providing a functional equivalent of the service described in the previous sentence or that is used to evade the protections set forth in this part.  83 Fed. Reg. 7852, 7922 (Feb. 22, 2018) to be codified at 47 C.F.R. §8.1(b).
 
 (c).     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.  83 Fed. Reg. 7852, 7922 (Feb. 22, 2018) to be codified at 47 C.F.R. §8.1(c). 
  The Company reserves the right to update and modify these disclosures and the underlying policies, in a manner consistent with the FCC’s directives, including by way of example the Company’s terms and conditions, network management practices and performance characteristics. To the extent such changes are made they will be reflected in the links provided below. 
 
COMMERICAL TERMS
 
            The rates, terms and conditions associated with the Company’s Service, including by way of example only, early termination and/or additional network service fees, can be accessed via the following link:
 
Rates: http://highlandtel.net/broadband/
 
Terms and Conditions:
            *HCC User Agreement-http://portal.highland.net/corporate/index.php?cat_id=52b6d3b7372943961822395fee8cc202
 
Rates, terms and conditions can also be requested via phone at 423-346-4050
 
The Company’s “Privacy Policy” can be accessed via the following link:
 
http://portal.highland.net/corporate/index.php?cat_id=fa2ead697d9998cbc65c81384e6533d5
 
If you believe that the Company’s Service is not meeting the rates, terms and conditions applicable to what you have ordered, please feel free to contact us so that we can address your concern:
 
           Via Telephone –         423-346-4050 available 8:30-5:00 
                                              800-555-1212
                                              423-628-2121 after hours
 
            Via Email --                highland@highland.net 
 
            Via Mail --                  G.M. Patterson, CEO/General Manager
                                              PO Box 1278
                                              Wartburg, TN 37887
 
We strongly encourage you to contact us in order to discuss your concerns. If based on those discussions there is some remedial action necessary, we can work together to implement it.
 
NETWORK MANAGEMENT PRACTICES
 
  In offering the Company’s Service, the Company recognizes that, at times, network issues will arise and, during those times, the Company will undertake actions that are appropriate and tailored to achieving a legitimate network management purpose.  The Company notes specifically, the following network management practices.  Please note that each of the statements below are subject to the Company’s “permitted use” policy may be accessed via the following link:
http://portal.highland.net/corporate/index.php?cat_id=52b6d3b7372943961822395fee8cc202.
 
  1. Blocking.  The Company does not block or otherwise prevent end user customer access to lawful content, applications, service, or non-harmful devices. 
  2. Throttling.  Except where network congestion may occur, the Company strives to avoid any degradation or impairment of access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful device.  Where service congestion occurs, the Company Service’s speed may be temporarily reduced. 
  3. Affiliated Prioritization.  The Company does not engage in any practice that directly or indirectly favors any of its affiliates’ traffic over other traffic. 
  4. Paid Prioritization.  The Company does not engage in any practice that directly or indirectly favors some traffic over other traffic in exchange for consideration, monetary or otherwise. 
  5. Congestion Management.  The Company continuously monitors bandwidth usage for indications of congestion and configures the network to normally avoid congestion. If the Company experiences congestion within our network we will redistribute or reroute traffic, as much as is possible, without regard to specific customers, applications, etc.  to reduce the congestion. There are no usage limits to service. 
  6. Application-Specific Behavior.  The Company does not (i) block or rate-control specific protocols or protocol ports; (ii) modify protocol fields in ways not prescribed by the protocol standard; or (iii) otherwise inhibit or favor certain applications or classes of applications.
  7. Device Attachment Rules.  Provided that an attachment does not cause network harm, including by way of example, interference with the Company’s network security measures, the Company does not restrict the types of devices that its end user customers may use and attach to the Company’s network nor does it have any approval procedures for devices to connect to the Company’s network
  8. Security.  The Company has not adopted security measures that would monitor end user real time usage at this time.  The responsibility would be that of the end user to monitor their usage and adopt safe practices that they feel necessary to protect any unauthorized access to their personal files and information. The Company does however engage in internal security measures to monitor aggregate Internet usage to avoid any possible degradation of its IP network and performance.  The Company may block ports that are known to be used for DDOS/DOS, virus and other malicious activities, or to intercept user information for the customers protection. The Company also blocks emails deemed to be SPAM or that are detected to contain a virus or other malicious code both into and out of the Company’s network.

 
 
PERFORMANCE
 
1.         Service Description. The Company’s Service is provided as a “best effort” service, and we provision services to meet the maximum speeds as advertised. However, internet usage can be affected by many variables across multiple networks, and the usage that you experience may be lower than the maximum speed it is provisioned for.  Speeds listed are “up to” a specific level based on the service to which a customer subscribes. 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 internet service provider such as the Company.
            Fiber
            (all services are fiber to the home)
            Bronze             15 Mbps download/1 Mbps upload
            Silver               25 Mbps download/3 Mbps upload
            Gold                50 Mbps download/50 Mbps upload
            Gig                   1000 Mbps download/100 Mbps upload
            (25ms latency across network)
            

Suitability for Real-Time Applications:  All of the Company’s Internet service offerings can be used for real time applications.  However, performance of those applications may improve at higher transmission speeds.

2.         Impact of Non-Broadband Internet Access Service Data Services.  The Company does non-broadband Internet access service data services such as VOIP and PWE3. These services are provided over the same broadband connection as the high‐speed Internet connection but utilize network management to isolate the capacity used by these services from that used by broadband Internet access services.  The Company does not change the priority of any other Internet based service either negatively or positively.
 
 

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Internet Transparency Disclosure (1)
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