Net Neutrality Policy Discloser Statement of:

South Central Rural Telephone Cooperative Corp., Inc.

and South Central Telcom, LLC

jointly deemed SCRTC

The following policies apply to Fixed Broadband Internet services offered by SCRTC.  SCRTC also offers enterprise level services that can be individually tailored to customer needs.  Information on enterprise services, not covered under this discloser, can be obtained by contacting SCRTC Business Office at 270-678-2111. It is SCRTC’s policy to provide reliable access to the Internet for all of its residential and commercial end user customers. Because network resources are shared by all users, SCRTC has implemented the following policies to govern Fixed Broadband Internet service.  These policies are designed to: (i) ensure that shared network resources are allocated fairly among all users; (ii) allow users and prospective users to understand service policies and any significant limitations on the service;  and (iii) provide a foundation that assures customers that they can rely on consistently receiving the level and quality of service to which they subscribe.  SCRTC does not block access to, nor discriminate against, any lawful website or Internet application and, with respect to fixed Internet access services, supports the ability of users to select and attach the equipment of their choice to the network so long as that equipment: (i) is used for a lawful purpose consistent with SCRTC Acceptable Use Policy (AUP) found at the following link: (http://www.scrtc.com/index.php?option=com_wrapper&Itemid=92); and (ii) does not harm the network or degrade network performance for other users. Customers are encouraged to familiarize themselves with the following policies which are deemed part of their Service Agreement.  By using SCRTC Internet service, the customer accepts, agrees to be bound by and to strictly adhere to, these policies.  The customer also agrees to be responsible for compliance with these policies by third parties, such as friends, family members or guests that make use of the customer’s service accounts or equipment to access the network for any purpose, with or without the permission of the customer.

I.                SYSTEM PERFORMANCE

SCRTC provides residential and commercial customers with a choice of data plans to meet their needs.  SCRTC also provides enterprise level services that are custom tailored to a specific project and individually priced based on the needs and criteria established by the Enterprise customer. SCRTC offers the following residential and commercial services and typical speed ranges.  These speeds were calculated based upon test made from customer premise equipment to bandwidth test sites at the far edge of SCRTC’s network. As of October 2011 SCRTC’s monthly network monitoring reports show utilization below 100% at peak periods indicating that its network consistently provides speeds as expected by customers with little or no degradation in service. These results were effective as of the dates / times indicated and may be updated from time to time at SCRTC’s discretion. Latency reading provided below are composite average reading based upon three or more test through each of the foregoing listed services.

Service                        Download (Mbps)      Upload (Mbps)           Latency (Ms)

512K/384k                  .512m                          .384m                          29

1.5M/512K                 1.5m                            .512m                          29

3M/768K                    3.0m                            .768m                          29

8M/1M                        8.0m                            1.0m                            29

10M/1.5M                   10.0m                          1.5m                            29

12M/2M                      12.0m                          2.0m                            29

15M/2M                      15.0m                          2.0m                            29

While SCRTC provisions  its’ network  and equipment to ensure that its customers can enjoy the speeds to which they subscribe, Internet speeds generally result from a “best effort” service and are dependent on a number of variables, many of which are outside the control of an Internet Service Provider.  Such variables include: the age and processing capability of the user’s terminal device or computer;  the number of applications running simultaneously;  the presence of viruses or malware; whether the terminal equipment is connected to the network by wire or by wireless; the distance the data packets must travel between  the user and the website; the presence of congestion on and technical configuration of any intervening networks; any gating or congestion management schemes employed by websites to limit download or upload speeds in cases where multiple users are served simultaneously.  ISP does not guarantee that a customer will achieve the speeds set forth above at all times. Rather, the foregoing data speeds represent the best information available to SCRTC of the typical speeds a customer can expect to experience under normal operating conditions.

Speed tests that allow customers to test the upload, download and latency performance of their broadband data services are available free of charge from a number sources. Generally, these tests are influenced by the same variables that affect Internet speed set forth above.  Accordingly, the speed results would not be expected to match a test of SCRTC network conducted under laboratory conditions.  Please note, however, that all speed tests use different methodologies to calculate Internet connection speed so each of the tests would be expected to yield different results.  Accordingly, each of these tests should be viewed as a helpful guide rather than as a definitive measurement of performance. The following sites, affiliated with SCRTC’s network partner, are provided to perform bandwith speed testing:

http://bgspeedtest.blue.net

http://etspeedtest.blue.net   

Alternate sites, unaffiliated with SCRTC, are provided below.

http://www.speedtest.net

http://netalyzr.icsi.berkeley.edu

http://www.broadband.gov/qualitytest/about/

II.              NETWORK MANAGEMENT

SCRTC utilizes a fully redundant network architecture that is designed to provide users with true broadband speeds and reliability even during times of peak demand. The network has been constructed to meet projected traffic demands and is fully scalable to allow for capacity to be added to meet customer needs and to support newly developing and increasingly sophisticated applications well into the future.  However, congestion can occur on any IP network, and, when it does, packets can be delayed or dropped, leading to service degradation and delays.   In cases where demand exceeds capacity, it is possible that the data traffic of any user, without discrimination, could be delayed.

SCRTC employs a protocol congestion management policy that does not discriminate against particular applications.  Users remain free to access the websites of their choice and run the applications of their choice consistent with the AUP.  SCRTC deploys network management servers and software that constantly monitor aggregate network traffic levels.  While automated traffic load control is not used in SCRTC’s network, SCRTC reserves the right to take appropriate steps to prevent any particular customer from causing degradation of service to other network user.

III.            Device Attachment/Application Policy

SCRTC provides fixed broadband data services.

 With respect to SCRTC’s fixed broadband services, users may generally attach the devices of their choice and run the applications of their choice, subject to the limitations of their data plan and the terms of their service agreement and AUP. While many devices such as routers, Bluetooth and WiFi cards, laptops,  notebooks and tablets are readily available from third party sources, such as consumer electronics retailers, other devices, such as DSL modems and proprietary network gateways must be provided by or leased from SCRTC.  Users are advised to contact SCRTC technical support at 270-678-2615 before purchasing any third party equipment to ensure compatibility with the network.  SCRTC is not responsible for the compatibility, suitability or functionality of any equipment that is provided by the customer or any third party, and the customer remains fully responsible for ensuring that any such equipment does not cause any harm to the network or degrade the service of other users.

All users of SCRTC’s fixed broadband Internet service are fully responsible for securing their equipment, including wireless routers, to prevent unauthorized access to the network by third parties and will be held fully responsible for the actions of such third parties that gain unauthorized access to the network through unsecured end user equipment.

IV.            COMMERCIAL TERMS

Commercial terms can be found at: http://www.scrtc.com/index.php?option=com_content&task=view&id=23&Itemid=77.

V.              PRIVACY POLICY RELATED TO NETWORK MANAGEMENT PRACTICES

SCRTC does not collect information about your use of our products and services for the purpose of tailoring and/or allowing or disallowing service availabilities. Any information of internet usage collected by SCRTC is collected for the purpose of maintaining the integrity and service functionality of our network. Such information may also be used determine compliance with applicable AUP and Service Agreements. This information is solely for the internal use of SCRTC and will not be released to any third party except as required by law.

If you subscribe to SCRTC Internet access services, we may automatically measure and monitor network performance and the performance of your Internet connection to improve your, or our, overall service levels. If you contact us for service support, we also may access information about your computer, wireless device or other device settings to provide customized technical support or to install specific applications or services that you use or that are necessary to the applications or services you use.

SCRTC will not gather information from your use of our Internet access services to direct customized advertising specifically to you based on your visits over time and across different non-SCRTC websites, unless we first provide you with notice of our plan and obtain your affirmative consent.

Please note that SCRTC is not responsible for information, content, applications or services provided by others. Before you access, use, link to or download a service or application on your computer or wireless device, you should review the associated terms of service and privacy policy. Personal information you submit in those contexts may be read, collected or used by the service or application provider and others associated with these forums in a manner different from that described here.