Middle Mile Interconnection Policy

NONDISCRIMINATION, INTERCONNECTION, AND NETWORK MANAGEMENT POLICY

This policy is set forth in compliance with the requirements for the Middle Mile Broadband Infrastructure Grant Program. Infrastructure Investment and Jobs Act, 60401(d)(2)(B). This policy is intended for Middle Mile Grant funded projects/facilities, subject to exceptions discussed below.

INTERCONNECTION

It is the policy of Concho Valley Electric Cooperative, Inc. (“CVEC”) to provide access to Middle Mile Grant (MMG) funded facilities and service at the nodes listed on our Wholesale Fiber Map. Additional nodes may be added per request when technically and economically feasible. New Nodes shall not exceed current or reasonably anticipated capacity limitations. CVEC shall grant requests on a non-discriminatory basis from parties seeking physical interconnection for the exchange of traffic or connection to the internet. The rates and terms established by CVEC are reasonable and nondiscriminatory.

For all requesting parties making bona fide requests for interconnection or wholesale services, CVEC will negotiate in good faith for commercially-reasonable terms and conditions. Telecommunications carriers and Internet service providers seeking information regarding these services are encouraged to contact CVEC at 325-655-6957.

CVEC is further prepared to do the following:

  1. Wholesale a direct connection that it has built to the customer (i.e. loop or lateral);
  2. Provide transport services to a last mile provider that is serving the customer (e.g. backhaul, internet access).

In accordance with grant requirements, CVEC will make all reasonable efforts to allow all requesting parties to interconnect with CVEC facilities.

If a party requests to interconnect with MMG-funded facilities where no point of interconnection currently exists, the requesting party should bear any reasonable cost to improve the facilities to allow for interconnection.

CVEC maintains that all services are provided under reasonable and nondiscriminatory terms. Wholesale services will be provided to customers at CVEC’s standard quality. Provisioning, installation, repair, and maintenance will likewise be provided on the standard terms and conditions made available to all customers.

CVEC shall make available and publish how to request information regarding network routes, points of interconnection, and other related matters. Similarly, CVEC shall publish the process to make service requests of the type contemplated in this policy. Upon receipt of the request, CVEC must acknowledge within 10 days. Standard rates are to be supplied at the request of interested parties.

Standard terms and conditions of service are to be made publicly available for inspection by interested parties. As required, executed service agreements are to be made available to the grantor.

CVEC shall work with approved service providers to enable interconnection to CVEC facilities. Interconnection may occur at established CVEC nodes, carrier hotels, and IXP locations. Additional interconnection locations can be negotiated with technically and economically feasible locations along the route upon review of each request and provided that such access does not exceed current or anticipated capacity limitations.

Interconnection services provided:

  • Carrier Ethernet
  • Dedicated Internet Access
  • Co-location/Data Center
  • Private Line
  • SD-WAN
  • Wavelength services
  • Dark Fiber

NONDISCRIMINATION

It is the policy of CVEC to provide wholesale fiber services on the following bases:

  1. Wholesale customers are entitled to access the lawful Internet content of their choice.
  2. CVEC provides standard interfaces.
  3. Wholesale customer my use any electronics which meet the CVEC Standard equipment that does not harm the network.

In addition to the above, CVEC does not prioritize lawful Internet applications and content over others. CVEC does not manage, throttle, block or otherwise limit the content of communications traffic transiting CVEC’s MMG-funded facilities, except to the extent necessary to maintain reliable service and prevent network harm.

CVEC’s network management policies will be publicly available and are applied consistent with the above principles. CVEC’s network management practices do not involve preferential routing of traffic on the basis of content or provider. CVEC utilizes neutral traffic routing and enables connections to other carriers and to the public Internet. CVEC displays its network management policies in a prominent location on its website, and will provide notice of changes to these policies.

NETWORK MANAGEMENT POLICY

CVEC uses various tools and industry standard techniques to manage its network and deliver fast, secure and reliable Internet service. CVEC believes in full transparency and conducts the following as part of its network management practices:

  • A. Congestion Management. CVEC monitors the connections on its network in the aggregate on a daily basis to determine the rate of utilization. If congestion emerges on the network, CVEC will take the appropriate measures to relieve congestion. CVEC’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.
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  • B. Network Security. CVEC promotes the security of its network and patrons by protections from such threats as spam, viruses, firewall issues and phishing schemes. As its normal practice, CVEC does not block any protocols, content or traffic for purposes of network management except that it may block or limit such traffic as spam, viruses, malware, or denial of service attacks to protect network integrity and the security of customers.
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  • C. Device Attachment Rules & Application Specific Behaviors. Except as may be provided elsewhere herein, CVEC does not currently engage in any application-specific behaviors nor does it employ device attachment rules for its network.
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  • D. Monitoring Schedule. CVEC employs a variety of industry-standard tools, applications and devices to monitor, secure and maintain its network, including one or more of the following:
    • Network graphing solutions;
    • Software to monitor SNMP network devices;
    • Port monitors;
    • Electronic alert notifications;
    • Diagnostic protocols;
    • Spam and virus protection on inbound & outbound email

EXCEPTIONS

Law enforcement and reasonable network management may require disruptions or decline in service from time to time. CVEC reserves the right to employ generally accepted technical measures to provide acceptable service levels to all customers.

The terms in this Policy shall not change the parameters of existing facilities, agreements, or non-MMG funded projects/programs. To the extent non-MMG funded projects/programs become a part of the MMG funded project/program, then this policy shall control, subject to further guidance from the grantor.