Gtelco Open Internet Transparency Statement

The following disclosure describes the network practices, performance characteristics and commercial terms for Gtelco.net (“Gtelco”, “LightBurst Broadband” or “Company”) pursuant to the Federal Communications Commission’s Open Internet Transparency requirements in 47C.F.R §8.3 and to ensure that you have sufficient information to make informed choices about the purchase of broadband services. Information about Gtelco’s other policies and practices concerning broadband are available at https://lbbroadband.com/policies.html.

Gtelco engages in network management practices that are tailored and appropriate for achieving optimization on the network considering the particular network architecture and technology of its broadband Internet access service. Gtelco’s goal is to ensure that all of its customers experience a safe and secure broadband Internet environment that is fast, reliable and affordable. Gtelco wants its customers to indulge in all that the Internet has to offer, whether it is social networking, streaming videos and music, to communicating through email and videoconferencing.

Gtelco’s network management includes congestion and security-protocol-management and customers generally will not be impacted by the protocols and practices that Gtelco uses to manage its network.

Gtelco’s Open Internet Transparency Disclosure

Gtelco uses various tools and industry standard techniques to manage its network and deliver fast, secure and reliable Internet service. Gtelco believes in full transparency and provides the following disclosures about its network management practices:

Network Practices

Blocking:

Gtelco does not block or otherwise prevent end user access to lawful content, applications, service, or non-harmful devices.

Throttling:

Gtelco does not degrade or impair access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful device.

Affiliated Prioritization:

Gtelco does not implement any 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, including identification of the affiliate.

Paid Prioritization:

Gtelco does not implement any 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. Gtelco does not plan to ever enter into any paid prioritization deal to create “fast lanes”.

Congestion Management:

Gtelco monitors the connections on its network in the aggregate on a continuous basis to determine the rate of utilization. If congestion emerges on the network, Gtelco will take the appropriate measures to relieve congestion.

On Gtelco’s network, all customers have access to all legal services, applications and content online and, in the event of congestion, most Internet activities will be unaffected. Some customers, however, may experience longer download or upload times, or slower surf speeds on the web if instances of congestion do occur on Gtelco’s network.

Customers using conduct that abuses or threatens the Gtelco network or which violates the company’s Acceptable Use Policy, Internet service Terms and Conditions, or the Internet Service Agreement will be asked to stop any such use immediately. A failure to respond or to cease any such conduct could result in service suspension or termination.

Gtelco’s network and congestion management practices are ‘application-agnostic’, based on current network conditions, and are not implemented on the basis of customers’ online activities, protocols or applications. Gtelco’s network management practices do not relate to any particular customer’s aggregate monthly data usage.

Gtelco monitors its network on a continuous basis to determine utilization on its network. Gtelco also checks for abnormal traffic flows, network security breaches, malware, loss, and damage to the network. If a breach is detected or high volume users are brought to light by complaint, Gtelco provides notification to the customer via email or phone. If a violation of Gtelco’s policies has occurred and such violation is not remedied, Gtelco will seek to suspend or terminate that customer’s service.

Application-Specific Behavior:

Except as may be provided elsewhere herein, Gtelco does not currently engage in any application-specific behaviors on its network. Customers may use any lawful applications with Gtelco.

Device Attachment Rules:

Customers must use IPoE for authentication of point to point connections between devices on the network. There is a limit of one (1) IPoE session per account. For best results, DSL modems, Fiber Network Interfaces, or other proprietary network gateways used on the Gtelco broadband network should be provided by Gtelco. Customers may attach devices of their choosing to their modems, including wired or wireless routers, laptops, desktop computers, video game systems, televisions, or other network-enabled electronics equipment. However, customers are responsible for ensuring that their equipment does not harm Gtelco’s network or impair the service of other customers. Gtelco is not responsible for the functionality or compatibility of any equipment provided by its customers. Customers are responsible for securing their own equipment to prevent unauthorized access to Gtelco’s broadband network by third parties and will be held responsible for the actions of such third parties who gain unauthorized access through unsecured customer equipment.

Network Security:

Gtelco knows the importance of securing its network and customers from network threats and annoyances. The company promotes the security of its network and patrons by protections from such threats as spam, viruses, firewall issues, and phishing schemes. Gtelco also deploys spam filters in order to divert spam from an online customer’s email inbox into a quarantine file while allowing the customer to control which emails are identified as spam. Customers may access the spam files through the email. Spam files are automatically deleted if not accessed within 30 days.

As its normal practice, Gtelco does not block any protocols, content or traffic for purposes of network management, but Gtelco may block or limit such traffic as spam, viruses, malware, peer-to-peer protocols used for illegal activity or denial of service attacks to protect network integrity and the security of our customers.

Network Performance Characteristics Service Description:

Gtelco deploys Internet access to its subscribers through hardwired broadband access (DSL, Fiber and Fixed Wireless).

Network Performance:

Gtelco makes every effort to support advertised speeds and will dispatch repair technicians to customer sites to perform speed tests as needed to troubleshoot and resolve speed and application performance caused by Gtelco’ network. Gtelco measures availability, latency, and aggregate utilization on the network and strives to meet internal service level targets.

However, the bandwidth speed at which a particular distant website or other Internet resources may be downloaded, or the speed at which your customer information may be uploaded to a distant website or Internet location is affected by factors beyond Gtelco’ control, including the speed of the connection from a distant web server to the Internet, congestion on intermediate networks, and/or limitations on your own computer equipment, including a wireless router. In addition, your service performance may be affected by the inside wiring at your premise. Accordingly, you, the customer, must consider the capabilities of your own equipment when choosing a Gtelco broadband service. Your computers and/or wireless or other networks in your homes or offices may need an upgrade in order to take full advantage of the chosen Gtelco broadband plan.

For the wireless service, Gtelco measures Bit Error Rate (BER) and the Received Signal Strength Indicator (RSSI) parameters for transmission rates, latency, and traffic every 15 min. For DSL, Fiber and T1 service, Gtelco measures traffic every 5 min. All services are best effort.

Gtelco tests each service for actual and expected access speeds at the time of network installation to demonstrate that the service is capable of supporting the advertised speed. Customers may also test their actual speeds using the speed test located at https://speedtest.lbbroadband.com on LightBurst Broadband’s website and may request assistance by calling our business office at 435-528-7236 or by email at admin@gtelco.net.

Based on the network information Gtelco receives from its monitoring efforts, Gtelco’ network is delivering data transmission rates advertised for the different high-speed Internet services. To be sure, Gtelco has implemented a program of testing the performance of its network by using a test protocol similar to the one sanctioned by the FCC. We installed specific network performance monitoring equipment at aggregation points across our network and conducted a series of tests using this equipment. Gtelco reports the results of this testing below. The results applies to both upload and download data rates, and applies for measurements made both at peak times and over a 24-hour period:

Service Description

Technology

Advertised Speeds

Actual Speeds

Required Latency

Actual Latency

Applications

20/1 Mbps

Asymmetrical DSL

20Mbps downstream / 1 Mbps upstream

20.31Mbps downstream / 1.31 Mbps upstream

100ms

9.89ms

Email, Web browsing, music streaming, standard definition video streaming, social media

40/2 Mbps

Asymmetrical DSL

40 Mbps downstream / 2 Mbps upstream

40.38 Mbps downstream / 2.34 Mbps upstream

100ms

11.08ms

All applications listed above:

60/5 Mbps

Asymmetrical DSL

60 Mbps downstream / 5 Mbps upstream

60.23 Mbps downstream / 5.42 Mbps upstream

100ms

12.16ms

All applications listed above plus: multiple stream SD video streaming, multiple stream HD video streaming, video calling

100/10 Mbps

Asymmetrical DSL

100 Mbps downstream / 10 Mbps upstream

91.53 Mbps downstream / 9.44 Mbps upstream

100ms

13.47ms

All applications

Impact of Non-BIAS Data Services:

The FCC has defined Non-Broadband Internet Access Services (Non-BIAS) to include services offered by broadband providers that share capacity with Broadband Internet Access Services (BIAS) (previously known as “Specialized Services”) also offered by the provider over the last-mile facilities. Real time services, such as Non-BIAS services, include Voice over Internet Protocol (VoIP) and Internet Protocol (IP) video services, command optimal bandwidth. As Non-BIAS traffic is combined with general Internet traffic on Gtelco’s network, broadband customers could experience service delays, although very unlikely, if there is an occurrence of congestion on Gtelco’s network. In any such event, the Non-BIAS traffic is given priority over general Internet traffic.

Commercial Terms Pricing:

Pricing and additional service information may be found at https://lbbroadband.com/res_internet.html and https://lbbroadband.com/res_int_bundle.html .

Privacy Policies:

Information about Gtelco’s other policies and practices concerning broadband are available at https://lbbroadband.com/policies.html. Frequently Asked Questions can be viewed at https://lbbroadband.com/faq_dsl.html.

Redress Options:

For questions, complaints or requests for additional information, please contact the Gunnison Telephone Company business office at 345-528-7236 or email admin@gtelco.net.

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