Open Internet Policy
Cable Co-op, Inc.
Broadband Internet Access Services
Network Management Practices, Performance Characteristics, and Commercial Terms and Conditions for Fixed Services
Cable Co-op, Inc., (“Cable Co-op”) has adopted the following network management practices, performance characteristics, and commercial terms and conditions for its broadband Internet access services in compliance with the Federal Communications Commission’s (“FCC’s) Open Internet Framework requirements (GN Docket No. 09-191 and WC Docket No. 07-52). These practices, characteristics, terms, and conditions are intended to help keep the Internet an open framework that enables choice, freedom of expression, end-user control, competition, and freedom to innovate without permission, while permitting Cable Co-op to manage its network reasonably. All practices, characteristics, terms and conditions have been in effect since January 1st, 2015. Cable Co-op reserves the rights to add, delete, or modify certain practices, performance characteristics, terms and conditions at its discretion. Cable Co-op will provide clear written notice of any changes on this website, but will not notify subscribers, content providers, applications providers, or service providers unless specifically required to do so by federal or state authorities. Cable Co-op will provide as much advance notice as practicable. Cable Co-op will normally attempt to provide written notice on this website thirty days before changes become effective but reserves the right to use a shorter notice period when regulatory, operational, technical or other circumstances demand.
- Network Management Practices
Cable Co-op manages its network with the goal of providing the best possible broadband Internet experience to its subscribers. Within the scope of its resources, it attempts to deploy and maintain adequate capacity and facilities within its own network, and to acquire enough middle mile capacity or facilities outside its service area to connect with the Internet. Cable Co-op and its staff use their best efforts to monitor, address and minimize (but do not guarantee that they can prevent) the effects of spam, viruses, attacks, congestion, and other issues that can degrade the service of its members.
A. Congestion Management Practices
Congestion is an Internet access service problem that can slow web browsing, downloading, streaming, and other activities of members during certain peak usage periods. Congestion may be caused by capacity limits, bottlenecks, malicious activity, or by limitations of the middle mile transport that service providers must purchase from unrelated entities to carry the traffic of their subscribers between their service areas and the Internet. As of January 2015, Cable Co-op has experienced very little issues with congestion.
If significant congestion problems arise, Cable Co-op’s approach is to determine the source of the problem, and to remedy the situation as soon as possible and in the most reasonable way possible. However, certain fixes cannot be accomplished instantaneously as they may require negotiations, authorizations and agreements with multiple unrelated entities. If the solution cannot be deployed on a timely or reasonable basis, Cable Co-op reserves the right to monitor and identify which customer accounts are using the greatest amount of bandwidth during periods of heavy congestion, and to contact those “high-volume subscribers” to work out a solution to the problem. Cable Co-op reserves the right to temporarily manage the Internet traffic of “high-volume subscribers” during periods of significant congestion until such periods of congestion pass. This temporary traffic management will be accomplished by technically and commercially feasible methods that are available or that become available in the future. Affected “high-volume subscribers” will still be able to access the Internet and engage in any and all online activities they desire. However, during periods of congestion they may experience conditions such as longer times to download or upload files, slower web surfing, lower quality streaming and/or slower movements during online game playing.
Customers should note that any temporary traffic management practices employed by Cable Co-op will impact only identified and notified “high-volume subscribers” during periods when congestion problems are experienced and will not be based upon the types of content, applications, services, or devices such customers use. As of January 2019, Cable Co-op expects that periods of temporary traffic management, if any, will be brief and infrequent. For purposes of its congestion management practices, Cable Co-op will consider a period in which a “congestion problem” arises and exists to be one where bandwidth usage on a given link or interface exceeds 90% of its designed capacity or when one of Cable Co-op’s two connections to its middle mile provider are unavailable. It will consider a “high-volume customer” as one that uses more than 100 Giga Bytes of data during any 30-day period.
B. Application-Specific Behavior Practices
Cable Co-op only limits applications based on industry standard best practices to reduce vulnerability to malicious traffic or attacks. Cable Co-op does not normally monitor the contents of the traffic or applications of its subscribers. Cable Co-op undertakes no obligation to monitor or investigate the lawfulness of the applications used by its members. If any party contacts Cable Co-op with a substantial allegation that an application being used by a customer is unlawful, Cable Co-op will not investigate the matter unless directed and required to do so by a a court order. Customers may occasionally develop their own applications or modify commercially available applications. Cable Co-op will not prohibit the use of subscriber-developed or modified applications unless there is a reasonable belief that such applications will cause harm to its network. Cable C-op only blocks protocols or protocol ports based on industry standard security best practices. Cable Co-op does not rate-control specific protocols or protocol ports and does not modify protocol fields in ways that are not prescribed by the applicable protocol standards.
C. Device Attachment Rules
Cable Co-op does not have any approval procedures that must be satisfied before a device can be connected to its network. Members may use any lawful, compatible, type-accepted and commercially available device which they desire on the network, if such device does not harm the network. Cable Co-op does not normally monitor the devices used by its members. Cable Co-op undertakes no obligation to monitor or investigate the lawfulness of the devices used by its customers. If any party contacts Cable Co-op with a substantial allegation that a device being used by a customer is unlawful, Cable Co-op will not investigate the matter unless directed and required to do so by a recognized legal entity. Customers may occasionally develop their own devices or modify commercially available devices. Cable Co-op will not prohibit the use of lawful customer-developed or modified devices unless there is a reasonable belief that such devices will cause harm to its network.
D. Security Practices
Cable Co-op does not normally monitor the traffic of its subscribers. It undertakes no obligation to monitor or protect such customer traffic from spam, viruses, denial-of-service attacks, or other malicious, unlawful or unwanted activities. Cable Co-op recognizes that subscribers can purchase spam filtering and anti-virus software from commercial vendors to meet their needs. Members are free to obtain anti-spam and/or anti-virus software or services from any source they desire, if such software or services do not disrupt or degrade the traffic of other members or harm the network. A member that is subjected to a denial-of-service attack, or similar malicious, unlawful or unwanted activity, is urged to take action to protect yourself (unplug), then call a network / computer expert to help fix the issue. The FBI and/or local law enforcement may help if a crime has been committed. Cable Co-op employs commercially appropriate security procedures to protect its network and its subscriber records from unauthorized access by third parties. Cable Co-op does not guarantee that it can protect members from any and/or all security breaches.
E. Traffic Blocking
Cable Co-op does not block any lawful content, applications, devices, and/or non-harmful devices. The only potential exceptions where blocking may occur entail the unlawful or harmful circumstances set forth in Sections I.A through I.D above. Cable Co-op believes that all such circumstances constitute reasonable network management practices. Cable Co-op does not knowingly and/or intentionally impair, degrade or delay the traffic on its network of any content, applications, services and/or non-harmful devices. However, Cable Co-op notes that congestion may from time to time impair, degrade, or delay some traffic. Cable Co-op does not charge edge service providers of content, applications, services and/or devices any fees simply for transporting traffic between them and its members.
II. Performance Characteristics
Many of the service and performance characteristics of Cable Co-op’s broadband Internet access services are contained in the service offering portions of this website. Cable Co-op offers different tiers of service at different prices, and changes these from time to time.
A. General Service Description
Cable Co-op uses a hybrid fiber optic and co-axial network. Internet access speeds are based on levels of service and range from 12 Mbps to 1000 Mbps. Actual access speeds and time delays (latency) are impacted by the length, capacity and congestion of middle mile transport facilities (between the Cable Co-op’s service area and Internet) as well as the characteristic of Cable Co-op’s own network. Cable Co-op’s service is suitable for real-time applications.
B. Impact of Specialized Services
As of March 2018, Cable Co-op offers streaming services via WTVE. This service has not adversely affected the capacity available to our subscribers, or the performance of our network for any of our members.
C. Impact of Middle Mile Capacity Constraints
Cable Co-op must purchase middle mile capacity and/or services from other entities for routes between Cable Co-op’s service area and the closest Internet nodes. Cable Co-op cannot guarantee that it will be able to obtain additional middle mile capacity at commercially reasonable prices if and when needs for additional middle mile capacity arise.
III. Commercial Terms and Conditions
The commercial terms and conditions of Cable Co-op’s broadband Internet access services are contained in detail on their website, www.oberlin.net/services/internet-access. This section provides a brief overview or reference to terms and conditions detailed elsewhere, plus discussions of other terms and conditions required by the FCC.
A. Pricing Terms and Conditions
Cable Co-op offers different levels of service at different prices, and changes these from time to time. These service prices are detailed in the service offering portion of their website. Cable Co-op does not impose usage-based fees on levels of its service. Cable Co-op does not impose fees for early termination. Cable Co-op assesses fees for additional network services on a case-by-case basis. In addition, Cable Co-op is willing to consider and negotiate prices for customized additional network services requested by specific customers or edge service providers if such services can be designed, developed and furnished in a commercially reasonable manner. If such customized services are developed and furnished, Cable Co-op reserves the right to adapt and provide them to other members on a non-discriminatory basis so long as such subsequent provision does not entail disclosure of proprietary or confidential information of the initial subscriber.
B. No Unreasonable Discrimination
Cable Co-op does not unreasonably discriminate in its transmission of traffic over the broadband Internet access services of its subscribers. It endeavors to give its customers as much choice and control as practicable among its different service offerings and among the content, application, service and device offerings of edge service providers. When reasonable network management practices entail differential treatment of traffic, Cable Co-op does not discriminate among specific uses, or classes of uses, of its network. Cable Co-op does not impair, degrade, delay or otherwise inhibit access by its subscribers to lawful content, applications, services or non-harmful devices. Cable Co-op does not impair free expression by actions such as slowing traffic from any websites or blogs. Cable Co-op does not use or demand “pay-for-priority” or similar arrangements that directly or indirectly favor some traffic over other traffic. Cable Co-op does not prioritize its own content, application, services, or devices, or those of its affiliates.
C. Privacy Policies
As indicated above, Cable Co-op’s network management practices do not generally entail inspection of network traffic. Cable Co-op retains and stores certain traffic information (such as the identity of the customer using an IP address during a specific period) for such time as data is useful for network administration or troubleshooting. Such data, as it is available, is made available to local, state, and Federal law enforcement agencies subject to lawfully presented subpoena or court order.
Cable Co-op retains, stores and provides to law enforcement any traffic information requested pursuant to the procedures of the Communications Assistance for Law Enforcement Act (“CALEA”), the Foreign Intelligence Surveillance Act (“FISA”) or other applicable national security or criminal statutes. Cable Co-op does not collect, store or use traffic information to profile its members in order to sell additional
services to them, or for similar non-network management purposes. Cable Co-op’s other privacy policies are listed on their website at; www.oberlin.net/privacy-policy.
D. Redress Options
Please call (440) 775-4001 or contact via email, support@oberlin.net, with any questions, comments, or concerns regarding the foregoing matters. Cable Co-op desires to resolve questions, or concerns of its members and edge service providers in an informal and direct manner that satisfies all interested parties to the greatest extent practicable. Members and edge service providers that are not able to obtain satisfaction from Cable Co-op have the option of invoking the FCC’s informal and formal complaint procedures regarding Open Internet Framework disputes.
