Net Neutrality Disclosure

BURLINGTON TELECOM

BROADBAND INTERNET SERVICE DISCLOSURES

Update November 14, 2011

Consistent with FCC regulations,[1] the City of Burlington d/b/a Burlington Telecom (“BT”) provides this information about our broadband Internet access services.  We welcome questions or comments about this information.  You may contact us at (802) 540-0007

Network Practices

General description.  We provide a variety of broadband Internet access service offerings to our residential and business customers.  We provide the services over fiber optic lines connecting to the Internet.  We monitor our network and traffic patterns and make changes we deem necessary to manage and improve overall network performance.  We use reasonable, nondiscriminatory, network management practices to improve overall network performance to ensure a high-quality online experience for all users.  Our network management practices do not target any specific content, application, service, or device.  As network management issues arise and as technology develops, we may employ additional or new network management practices.  We will update these disclosures as necessary.

Related documents aAnd disclosures.  Use of our Internet service is also governed by: 

• Burlington Telecom Internet Acceptable Use Policy, available at http://www.burlingtontelecom.net/customer_support/terms.htm#.
• Burlington Telecom Privacy Policy, available at http://www.burlingtontelecom.net/customer_support/terms.htm#.

Congestion Management.  We describe in this section network management practices used to address congestion on our network.

Congestion management practices used.

Network monitoring.  We monitor our network for utilization trends.  We monitor network traffic and congestion on a daily basis.  We use this information to plan increases in bandwidth available, port additions, or additional connectivity to the Internet.  We place no limitations on data usage.

Types of traffic affected.  Our congestion management practices do not target any specific content, application, service, or device. 

Purposes of congestion management practices.  Our Internet network is a shared network.  This means that our customers share upstream and downstream bandwidth.  The goal of our congestion management practices is to enable better network availability and speeds for all users.  Our congestion management practices serve to:

• Help us adapt and upgrade our network to maintain or improve network performance as demand for our Internet service increases.
• Help us adapt and upgrade our network to maintain or improve network performance as demand for higher bandwidth applications increases.  Some examples of higher bandwidth applications are gaming, streaming movies, and streaming high definition video.
• Help us identify potential bandwidth abusers.

Congestion management criteria.  Our network monitoring provides data to help us plan upgrades to our network, equipment, technology, and connectivity to the Internet.  As demand for our Internet service increases, and as demand for higher bandwidth applications increases, we monitor effects on network performance and plan upgrades as we deem necessary to meet advertised speeds.

Effects on end user experience.  Because our Internet service network is a shared network, periods of high network demand may result in Internet traffic congestion.  Our network monitoring practices are continually conducted and adjustments made accordingly to provide end users with the best possible experience.

Typical frequency of congestion.  Congestion tends to occur during periods of peak demand for higher bandwidth applications. Generally, the frequency of congestion tends to increase from 7 pm – 11 pm, especially on Friday and Saturday nights as well as holidays.

Application-Specific Practices.  We do not manage congestion by restricting or managing any specific protocol ports, fields, or applications. If at any time, Burlington Telecom changes this practice, we will update these disclosures as necessary.

Device Attachment Rules.  This section addresses any limitations on attaching lawful devices to our network.

General restrictions on types of devices to connect to network.

While we do not have specific device restrictions, to use our Internet service a customer’s computer must include a Network Interface Card (“NIC”), in order to access the internet. Beyond that, our service works with most types of PCs and laptops including Macs.  If a customer or potential customer believes they have an unusual configuration, our help desk help determine if there is an equipment compatibility problem.  

Fiber-to-the-Home Internet Service.  Our fiber-to-the-home service requires connection of a residential gateway device and Optical Network Terminal (ONT) to our network.  We provide and install the ONT, and you can obtain a residential gateway device from us or you may purchase one from most retail electronics sellers. 

“Hot Spots” Wireless Service.  Our Access Points require a device that is able to receive a radio signal. We install Access Points throughout the City of Burlington, a list of these hot spots can be found at http://www.burlingtontelecom.net/wi-fi/index.htm.

Network and End User Security. This section provides a general description of the practices we use to maintain security of our network and end users, including triggering conditions.

Practices used to ensure network and end-user security, including triggering conditions.  In general, we promptly address any event originated by a customer or customer equipment that negatively affects others’ use of the network.  Our practice is to first contact the customer causing the problem, and if we received no response, we terminate that customer’s service until the problem is corrected. 

Practices used to ensure network security, including triggering conditions.

Hostile port blocking.  We do not currently block ports. If Burlington Telecom changes this current practice, these disclosures will be updated as necessary.

Virus and Spam filtering.  We filter all outbound email traffic for viruses and spam.  Our inbound virus and spam filtering is performed by a third-party provider.  Our contractor performs industry standard virus scanning and prevention techniques on our email platform for mail inbound from the public network.  Should an email message be found to contain a virus or other harmful content, the message will be deleted without notification given either to the sender or the intended recipient(s).

Misuse of System Resources.  To protect and maintain high availability of all its servers, activities designed to cause harm to or monopolize the resources of any server in our network are strictly prohibited.

Performance Characteristics

General Service Description.  Our fiber-to-the-home Internet service product includes wiring, an Optical Network Terminal (ONT) and a residential gateway device.  Our Access Points include external and internal rated equipment to service locations inside and outside.  Through our Internet service products, we serve as a local Internet service provider.  Our Internet service products enable residential and commercial subscribers to access all lawful content, applications, and services of their choice available on the Internet

Fiber-to-the-Home Internet service technology.  We deliver our fiber-to-the-home service over our fiber optical network.  Customers access our network using a residential gateway device.  To connect from our network to the Internet, we use equipment called an Optical Network Terminal (ONT) and a residential gateway device that acts as a gateway to the Internet for our customers’ personal computer or routers. This is a shared network, which means that our customers share upstream and downstream bandwidth.

Hot Spots Wireless Internet service technology.  We deploy our access points through our internet network via fiber with some using ONT’s and some using point to point fiber connections, all connecting through our internet switch.   

Expected and Actual Speeds and Latency. We offer customers a variety of Internet service levels. We provide a description of the expected maximum transfer speeds associated with each residential service level at http://www.burlingtontelecom.net/residential_services/internet/index.htm. We test our network routinely to address any issues concerning network congestion.  Our goal is provide the customer with the speeds they have subscribed to.

Speed.  The speeds we identify for each Internet access service level are the maximum upload and download speeds that customers are likely to experience.  We provision and engineer our network to deliver the speeds to which our customers subscribe.  However, we do not guarantee that a customer will actually achieve those speeds at all times.  A variety of factors can affect upload and download speeds, including customer equipment, network equipment, congestion in our network, congestion beyond our network, performance issues with an Internet application, content, or service, and more.

Latency.  Latency is another measurement of Internet performance.  Latency is the time delay in transmitting or receiving packets on a network.  Latency is primarily a function of the distance between two points of transmission, but also can be affected by the quality of the network or networks used in transmission.  Latency is typically measured in milliseconds, and generally has no significant impact on typical everyday Internet usage.  As latency varies based on any number of factors, most importantly the distance between a customer's computer and the ultimate Internet destination (as well as the number and variety of networks your packets cross), it is not possible to provide customers with a single figure that will define latency as part of a user experience.

Actual speed and latency performance.  Actual speed and latency performance for our service follows.

Fiber-to-the-Home service. The FCC has reported that customers of fiber-to-the-home based broadband Internet services receive mean download speeds that are within 114% of advertised speeds during non-peak hours, and 113.5% of advertised speeds during peak hours.[2]  In addition, the FCC has reported that these same customers experience average latency[3] delays of 17 milliseconds, increasing by an average of 18 milliseconds during peak hours.  Our data indicates our fiber-to-the-home service latency ranges from 1to 3 milliseconds.

Hot Spots Wireless service.  Burlington Telecom’s Hot Spots receive mean download speeds that are within 95% of advertised speeds during non-peak hours, and 93% of advertised speeds during peak hours.

Customer Speed Test.  We provide a customer speed test for our customers, available at http://speedtest.burlingtontelecom.net/.  Should a customer experience a problem, we will dispatch a service technician within a 24 hour period.

Suitability of the Service for Real-time Applications.  Each of our Internet services are suitable for typical real-time applications including messaging, voice applications, video chat applications, gaming, and Internet video.  If users or developers have questions about particular real-time applications, please contact us at (802) 540-0007

Commercial Terms

Prices. Monthly prices for our Internet access services are available at[a1] 

Privacy Policies.  From time to time, we may need to disclose anonymized network traffic information to third parties solely for purposes of providing and maintaining our Internet service product or if required by law.  We reserve the right to do so.  For further information on our privacy policies, see our Internet Acceptable Use Policy and Privacy Policy located at http://www.burlingtontelecom.net/customer_support/terms.htm#.

Illegal or Indecent Content.  Use of any Burlington Telecom service to make any illegal, indecent or obscene content available via transmission, storage, or display of such material is prohibited.   Accounts maintaining such content are subject to suspension or termination without notice.

Inspection of network traffic. We routinely monitor network and traffic patterns.

Virus and Spam filtering. We filter all outbound email traffic for viruses and spam.  Our inbound virus and spam filtering is performed by a third-party provider.  Our contractor performs industry standard virus scanning and prevention techniques on our email platform for mail inbound from the public network.  Should an email message be found to contain a virus or other harmful content, the message will be deleted without notification given either to the sender or the intended recipient(s).

Storage of network traffic information.  Dynamic Host Configuration Protocol (DHCP) information is a code included in all network traffic that associates that traffic with a particular cable modem or customer equipment sending or receiving the traffic.  We store DHCP information for at least 6 months. 

Provision of network traffic information to third parties.  We may disclose network traffic information to third parties solely for purposes of providing and maintaining our Internet service product or if required by law in accordance with our Privacy Policy.

Use of network traffic information for non-network management purposes.  Burlington Telecom does not currently use network traffic information for non-network management purposes. In the event this practice changes, Burlington Telecom will update these disclosures as applicable.  

Redress Options; end-user complains and questions. End users or edge providers with complaints or questions relating to these disclosures should contact our help desk at (802) 540-0007 or use our website customer care link, available at http://www.burlingtontelecom.net/contact_us/index.php, to submit complaints or questions. We will endeavor to answer questions promptly via email or voice.  For complaints, we will provide an initial response in writing within 15 business days of receipt. We will attempt to resolve complaints informally, escalating the matter to senior management if needed.