GVTC Communications
Network Management and Open Internet Policy

Guadalupe Valley Telephone Cooperative, Inc., including its subsidiary Guadalupe Valley Communications Systems, L.P. and other subsidiaries (collectively “GVTC”) provides this Policy to disclose its network management practices in accordance with the FCC’s Open Internet Rules. Additional Information about GVTC’s other policies and practices concerning Internet service, including but not limited to privacy and acceptable use, are also available under the Support section of our website https://www.gvtc.com.

GVTC manages its network to provide its customers with an Internet environment that is fast, reliable and affordable. GVTC wants its customers to indulge in all the Internet offers, whether it is social networking, streaming videos and music, or communicating through email and videoconferencing.

GVTC manages its network for several reasons, including optimization, as well as congestion and security-protocol-management. Such practices are consistent with reasonable network management actions and are intended to improve the overall performance for customers.

GVTC’s Network Management Practices

GVTC uses various tools and industry standard techniques to manage its network and deliver fast and reliable Internet service. Such management tools and practices include the following:

I. Managing Congestion

GVTC manages the traffic on its network in the aggregate to determine the rate of utilization. GVTC manages its network to provide the most economical service with the highest quality. GVTC provides multihomed links in its backbone network to help protect against outages. GVTC monitors and attempts to add capacity to its network before utilization reaches full capacity. GVTC engineers the local facilities to meet the anticipated traffic requirements. GVTC may increase capacity by various means including but not limited to upgrading to fiber-to-the-home (FTTH), splitting coaxial node, adding transport, adding Internet aggregation routers and adding bandwidth, as needed.

On GVTC’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 occur on GVTC’s network.

Customers engaging in conduct that abuses or threatens the GVTC 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. In extreme cases of abuse or conduct which is impacting other users, GVTC may, consistent with its Policies, suspend service without notice.

GVTC’s network and congestion management practices are “application-agnostic”, based on current network conditions, and are not implemented based on customers’ online activities, protocols or applications. GVTC’s network management practices do not relate to any particular customer’s aggregate monthly data usage. GVTC does not prioritize or discriminate against any applications or protocols except for specialized networks.

II. Network Security

GVTC promotes the security of its network and patrons by providing resources to its customers for identifying and reporting threats such as spam, viruses, firewall issues, and phishing schemes. The latest information is posted under Web Scam Alert on our website at https://gvtc.com/gvtc-library/internet/web-scam-alert. GVTC also deploys spam filters to divert spam from an online customer’s email inbox while allowing the customer to control which emails are identified as spam. Spam is quarantined in a separate file that the Customer may access.

As its normal practice, GVTC does not block any protocols, content or traffic, except, for allowable network management purposes the company may filter, up to and including limiting access or blocking if necessary and to the extent necessary, such traffic as spam, viruses, malware, or denial of service attacks to protect network integrity and the security of our customers. GVTC may filter or block ports, including limiting access or blocking access to or from such ports if necessary and to the extent necessary, to reduce the spread of computer-related viruses and protecting customer’s computer from intruder access. If GVTC suspects traffic originated by its customers is virus related, GVTC will contact the suspected party. If there is no response, the customer’s service will be suspended until the issue can be resolved. In extreme cases which are impacting other users or threatening network integrity, GVTC may suspend service without prior notification to the customer.

GVTC does not currently engage in any application-specific behaviors in its network, except as maybe listed in the Specialized Service section of this policy.

III. Monitoring Schedule

GVTC has deployed software that continuously monitors the network for performance and provides performance reports. In the backbone network, alarms or alerts are generated if the performance is degraded. In addition, traffic is analyzed and trended to insure peak performance. GVTC adds capacity to relieve congestion when thresholds are met. GVTC also uses industry standard software tools to check 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 a complaint, GVTC provides notification to the customer via email or phone. If a violation of GVTC’s policies has occurred and such violation is not remedied, GVTC will seek to suspend or terminate that customer’s service.

IV. Network Management Technology

GVTC employs a variety of industry-standard tools, applications and devices to monitor, secure and maintain its network, including the following:

- network graphing solutions;
- latency measurement software; and
- bandwidth and performance measurement platforms.

V. Service Descriptions

GVTC offers Internet service over Cable Modem, DSL, FTTH facilities and leased transport. GVTC offers speeds ranging from 1.5 Mbps to 1 Gbps. Not all service plans are offered on all technologies. Details of the service plans and the rates are listed on the website at https://gvtc.com/residential/internet/internet-plans.

All GVTC’s internet service plans above 1.5 Mbps can support real time applications.

VI. Network Performance

GVTC broadband services are best effort performance services. GVTC makes every effort to support advertised speeds and will perform speed tests as needed to troubleshoot and resolve speed and application performance issues that are caused by GVTC’s network. GVTC measures availability, latency, and aggregate utilization on the network and strives to meet internal service level targets in its network. However, the customer’s performance is also affected by the website being accessed, capacity in the public Internet beyond the GVTC network and the customer’s computer, inside wiring, wireless router, and other customer equipment.

Customers can test their actual speeds using the speed test found on the company website at speed.gvtc.com . GVTC is in the process of developing additional systems/processes that will allow us to measure the performance of the GVTC controlled network compared to advertised speeds. Once these systems are developed, GVTC will disclose the results on its website.

VII. Specialized Services

GVTC does not currently offer any specialized services.

VIII. Device Attachment Rules

Customer will need a Network Interface Card (NIC) installed in the PC or a USB port to use the DSL Modem/Router. In addition, all customer equipment attached to the broadband service should meet standards for consumer electronics and not harm the network.

If GVTC discovers a customer device is harmful to its network, GVTC has the right to request that the customer remove such device.

IX. Commercial Terms

Monthly prices for our broadband Internet access services are available on our website at https://www.gvtc.com.

Usage-based fees/Data allowances 
GVTC does not currently have usage-based fees or data allowance caps. However, GVTC reserves the right, upon notice, to implement changes. In the event of such change this Network Management and Open Internet Policy will be modified to indicate such change.

Fees for early termination  
There may be early termination fees based on the customer’s contractual terms (e.g. if the customer agreed to such terms in exchange for a particular promotion).

Fees for additional network services 
If the customer subscribes to additional network services, applicable fees will be charged. Prices may be found on our website at https://www.gvtc.com.

Privacy Policies 
Privacy policies are applicable and available on our website at https://gvtc.com/support/policies-terms-conditions.

X. Redress Options

We welcome questions about our broadband Internet access service. This section discloses redress options for end users and edge providers.

End user complaints and questions. End users with complaints or questions relating to the service or these disclosures should contact GVTC at (1-800) 367-4882) or https://www.gvtc.com/contactus/index.php 

Questions. We will endeavor to answer questions promptly via email or voice.

Complaints. For written 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.

Edge provider complaints and questions. Edge providers with complaints or questions relating to our broadband Internet access service or these disclosures should contact GVTC at (1-800) 367-4882) or https://www.gvtc.com/contactus/index.php

Questions. We will endeavor to answer questions promptly via email or voice.

Complaints. For written 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.

XI. Other Notices

In addition to this Network Management Policy, customers should also review other Policies and guides applicable to their Service and found at https://gvtc.com/support/policies-terms-conditions. Such Policies and guides include:

Acceptable Use Policy
Privacy Policy
Web Scam Alert
Internet Service Terms and Conditions

For questions, complaints, or requests for additional information, please contact GVTC at (1-800) 367-4882) or Contact Us.