Hawaiian Telcom Broadband Policy

1 Hawaiian Telcom's Broadband Network Management

Hawaiian Telcom strives to provide its customers with non-discriminatory broadband Internet access at high speeds and at a reasonable price. In order to meet this goal, Hawaiian Telcom employs a number of reasonable network management practices.

This describes the reasonable network management practices that apply to services and usage provided on Hawaiian Telcom’s network. Hawaiian Telcom is not responsible for delays, congestion or any network management techniques that occur on the Internet or the networks of other carriers.

Subject to the reasonable network management practices, Hawaiian Telcom does not block the ability of its customers to access lawful websites nor will Hawaiian Telcom block applications that compete with its voice or video services.

2 Service Description

Hawaiian Telcom offers a variety of broadband high-speed Internet (HSI) options for residential consumers and small businesses. The offerings vary by download and upload speeds.

Hawaiian Telcom uses various technologies to provide HSI service and the technology deployed in a given geographical area determines the speed tiers that are available to consumers. Not all speed tiers and technologies are available in all areas.

3 Service Technology & Performance

Hawaiian Telcom operates a number of technology platforms:

xDSL – Hawaiian Telcom uses both asymmetrical digital subscriber line (ADSL2+) and VDSL2 technology to deliver HSI service using existing cooper loops; and

Fiber-to –the-Home (FTTH) - uses gigabit passive optical network (GPON) technology to deliver HSai in areas where fiber has been deployed to individual homes or within Multiple Dwelling Units (MDUs – Apartment Buildings, condominiums, townhomes). While Hawaiian Telcom categorizes each HSI offering based on maximum speeds, the actual speed a customer experiences will vary depending upon numerous factors, many of which are beyond Hawaiian Telcom's control.

Common factors that can affect the actual speeds that a consumer receives include, but are not limited to:

• the capabilities or limitations of the customer's computer or other device;
• the number of computers or other devices in use in the customer's home network;
• the means of connecting to the Hawaiian Telcom network (e.g., the condition of the home's inside wire or the type and condition of WiFi router).
• the distance of the home from the Hawaiian Telcom broadband network aggregation point;
• the performance of the content and application providers the consumer is accessing as well as their host network;
• and the use of specialized services, such as IPTV, over last mile facilities.

Performance can also vary depending upon the level of congestion on the network at a given time. ¹ For example, consumers may experience slower speeds during peak usage times when many users are accessing the Internet simultaneously. The peak congestion period is typically between 7:00 pm – 11:00 pm Monday through Friday for wireline broadband Internet access.

Some applications and services share capacity with broadband Internet access service over the last-mile facilities that connect an ISP’s network to the consumer’s premises. These “specialized services” can reduce the bandwidth available for Internet service. Hawaiian Telcom’s IPTV is a specialized service that may impact the performance of some subscribers broadband Internet access service.

IPTV is a delivery system through which television services are delivered using Internet Protocol standards over a packet-switched network instead of being delivered through traditional terrestrial RF cable television formats or satellite signals. Hawaiian Telcom TV

¹ “Congestion” is a period during which customer demand exceeds network capacity. Congestion can occur due to high usage or consumer demand during certain times of the day (i.e. during peak times), particularly in highly populated locations.

(HTTV) service delivered using VDSL technology deployed over fiber-to-the-curb facilities is an IPTV service. When using the TV and Internet simultaneously, bandwidth is allocated first to the TV streams with the remainder available for Internet applications. All IPTV video streams take priority over high speed Internet traffic. Each high definition (HD) video stream requires approximately 7Mbps per stream and a Standard Definition video stream requires approximately 3 Mbps per stream.

Estimated median download and upload speeds, as well as latency for each speed tier during peak hours. offered by Hawaiian Telcom is shown in the table below. Performance was estimated by applying results from latest available report from the FCC titled "FCC Measuring Broadband America - Fixed Broadband Report" ( https://www.fcc.gov/reports-research/reports/measuring-broadband-america/measuring-fixed-broadband-report-2016). Actual performance of an individual's broadband service may vary.

Performance of Hawaiian Telcom High Speed Internet Service Offerings

Product (Speed Tier)	*Download Speed (Mbps)	*Upload Speed (Mbps)	*Latency
Fiber 1 Gig/500 Mbps (FTTH)	~940	~500	~5-10ms
Fiber 800/600 Mbps (FTTH)	~800	~600	~5-10ms
Fiber 600/600 Mbps (FTTH)	~600	~600	~5-10ms
Fiber 400/400 Mbps (FTTH)	~400	~400	~5-10ms
Fiber 100/100 Mbps (FTTH)	~100	~100	~5-10ms
50 Mbps/3 Mbps(xDSL)	~50.15	~22	~20-25ms
20 Mbps/1 Mbps(xDSL)	~16	~1.28	~20-25ms
15 Mbps/1 Mbps (xDSL)	~12.75	~1.28	~20-25ms
11 Mbps/ 1 Mbps (xDSL)	~8.8	~0.85	~30ms
7 Mbps/1 Mbps (xDSL)	~5.6	~0.85	~30ms
3 Mbps/1 Mbps (xDSL)	~2.4	~0.85	>30ms

*The above rates are based on testing using RFC 6349 testing. This may differ from the results obtained using the sites such as "speedtests.net" or "fast.com". There are also many variables that can affect the results produced by these speedtest server sites, such as the time of day the tests are run. If others are running tests on the same server simultaneously the results will likely be affected.

4 Network Congestion Management

Network congestion is similar to traffic congestion it is the result of an excessive amount of traffic (data packets) making simultaneous use of limited infrastructure (broadband networks). All Internet Service Providers (ISPs) rely upon some shared facilities to deliver services to the end user.

ISPs cannot guarantee that the full bandwidth of each user's connection will always be available on demand, as the performance of traffic that traverses the Internet is beyond the control of any single service provider.

Congestion can be caused either by long-term trends, such as increased demand for Internet services, or by short-term and unexpected demand surges. Significant new developments, popular content releases, and even computer virus outbreaks can drive short-term spikes in utilization that can significantly affect bandwidth consumption.

Hawaiian Telcom is constantly analyzing traffic patterns and upgrading services and facilities to keep up with this demand. Hawaiian Telcom's goal is to provide the highest possible speeds to the largest number of consumers at a reasonable price and on a non-discriminatory basis.

Congestion typically occurs in the aggregation layer of the network. The aggregation layer is found at the location where the facility to a customer premise joins the larger network and where traffic is routed over shared network facilities. For DSL-based services (ADSL and VDSL), aggregation begins in the part of the network known as the digital subscriber line access multiplexer (DSLAM). For GPON-based services, the analogous device/aggregation point is known as an optical line terminal (OLT). At the DSLAM and OLT, customers’ services are aggregated onto a single circuit or path for delivery to the rest of the network. The uplink speeds and specific topologies at these aggregation points vary based on demand, availability, and the limitations of the particular DSLAM or OLT equipment.

Although Hawaiian Telcom continually upgrades its facilities to address the long-term increases in Internet traffic, these upgrades cannot alleviate congestion caused by short-term spikes in demand that consumers may experience. During such periods of congestion when the amount of traffic attempting to traverse the network exceeds the available capacity at an aggregation point, all traffic passing through that aggregation point will be slowed until demand decreases. In other words, all traffic is treated the same and no consumers or applications are given priority. This is often referred to as Best Effort routing.

5 Customer Devices Connecting to Hawaiian Telcom's Network

Hawaiian Telcom provides all HSI subscribers with the appropriate gateway/modem (i.e., an ADSL gateway/modem or fiber/GPON gateway/modem, as applicable) configured to provide optimal performance with their service. In order to receive Hawaiian Telcom’s HSI service the subscriber’s network must meet minimum system requirements and include the hardware and software provided by Hawaiian Telcom. Hawaiian Telcom does not prohibit the use of lawful, non-harmful, third-party supplied modems, routers, or gateways on the Hawaiian Telcom copper, or fiber cable networks. However, if a customer connects his or her own device, Hawaiian Telcom cannot guarantee the service will work and may not be able to provide support in the event of a problem.

Customers do not need approval to connect their devices (routers, modems) provided they are installed past the point of demarcation. For xDSL based services, this is the jack where the xDSL services are presented to the customer.

For all other services (Fiber based), the demarcation point is considered to be the Ethernet port on the Network Interface Device (NID) installed at the customer's premise.

6 Security

Hawaiian Telcom monitors network fault and performance 24 hours a day, 365 days a year to quickly detect and respond to service degradation or impairment. Threats to network health can take many forms such as port scanning, wherein one customer attempts to open multiple sessions with hundreds or thousands of other users in hopes of discovering exploitable vulnerabilities, or Denial of Service (DOS) attacks in which one or more users direct an unreasonably high amount of traffic at a particular destination in an effort to overwhelm its capacity to respond. In many cases, this type of malicious traffic originates from a customer whose computer has itself been compromised or infected with a virus. When such a threat is detected, Hawaiian Telcom engineers will evaluate the impact or the potential for impact and take appropriate steps to mitigate damage to the network and Hawaiian Telcom’s customers.

7 Impact to Broadband Services by Non-Broadband Services

Hawaiian Telcom’s Fiber to the Home product also delivers regular telephone service as well as internet and TV over the same fiber facility. The non-broadband service (ie POTS) is applied in addition to the bandwidth required for either internet or TV (or both), and does not take away from the total bandwidth available to the customer for internet traffic.

8 Commercial Terms & Pricing

Hawaiian Telcom’s current promotional pricing and offers can be found at: hawaiiantel.com. The rate that applies at the end of any promotional period will be the standard rate in effect when the promotion expires. Consumers should call Hawaiian Telcom Customer Service at 643-3456 (Residential) or 643-4411 (Business) prior to the end of their promotional period to determine the standard rate that will apply. All plans include unlimited data usage. Hawaiian Telcom provides all HSI subscribers with the appropriate gateway/modem (i.e., an ADSL gateway/modem or fiber/GPON gateway/modem, as applicable) configured to provide optimal performance with their service. In order to receive Hawaiian Telcom’s HSI service the subscriber’s network must meet minimum system requirements and include the hardware and software provided by Hawaiian Telcom. Subscribers are assessed a monthly Wireless Gateway Service Fee that covers the maintenance of our Hawaiian Telcom broadband network and allows our High-Speed Internet customers to have use of the wireless gateway with guaranteed maintenance, support, and replacement if necessary for the life of their High-Speed Internet service. The Wireless Gateway Service Fee is not tied to the cost of the actual modem, therefore, the Wireless Gateway Service Fee will still be charged if the customer purchases their own modem. When terminating service, the modem and power cord must be returned to Hawaiian Telcom. Charges will apply for non-returned equipment. Visit hawaiiantel.com/standardrates for more information. A one-time Activation fee may apply.

9 Privacy Policy

Hawaiian Telcom will treat your personal information in accordance with its current Privacy Policy, subject to change from time to time, and posted on the Website at hawaiiantel.com/privacypolicy. You agree to the terms of the Privacy Policy, which describes Hawaiian Telcom's use and disclosure of information about your account and your use of the Service. Hawaiian Telcom respects your right to privacy. We adhere to a set of privacy principles which form the basis of our privacy policy. When you visit this site you may provide information on two different levels about your visit:. Anonymous statistics collected as you browse the site, and personal information you knowingly give us for ordering service or requesting technical assistance.

10 Redress Options

Questions or concern regarding Hawaiian Telcom’s broadband Internet service should be directed to 643-3456 (Residential) or 643-4411 (Business) or online at hawaiiantel.com. Consumers may also utilize the FCC’s informal or formal complaint process by contacting the FCC at 1-888-225-5322 or on-line via: https://consumercomplaints.fcc.gov

11 Law Enforcement Obligations

Nothing in these network management practices supersedes or limits the ability of Hawaiian Telcom to address the needs of emergency communications or law enforcement, public safety or national security authorities, consistent with or as permitted by applicable law

Glossary

ADSL - Asymmetric Digital Subscriber Line is a type of Digital Subscriber Line technology, a data communications technology that enables faster data transmission over copper telephone lines than a conventional voice band modem can provide. It does this by utilizing frequencies that are not used by a voice telephone call.

ADSL 2+ - extends the capability of basic ADSL by doubling the number of downstream bits.

Aggregation device - various methods of combining multiple network connections in parallel to increase throughput beyond what a single connection could sustain, and to provide redundancy in case one of the links fails.

CO - Central office, in telecommunications, data, video and telephony

Download - is the speed of the connection when receiving data from the Internet to your computer.

DSLAM - Digital Subscriber Line Access Multiplexer is a network device, located in the telephone exchanges of the telecommunications operators. It connects multiple customer Digital Subscriber Line (DSL) interfaces to a high-speed digital communications channel using multiplexing techniques

FTTC - Fiber-to-the-curb – is fiber going to a cabinet to get closer to the user's premises; typically within 300m.

FTTH - Fiber-to-the-home - fiber reaches the boundary of the living space, such as a box on the outside wall of a home.

GPON - Giga Passive Optical Network is a point-to-multipoint, fiber to the premises network architecture in which unpowered optical splitters are used to enable a single optical fiber to serve multiple premises, typically 16-128. A PON consists of an optical line terminal (OLT) at the service provider's central office and a number of optical network terminals (ONTs) near end users.

Latency - is commonly measured as the time it takes for a data packet to travel back and forth over the broadband provider's network. Lower latency means better quality, but a small amount of latency associated with the distance travelled is unavoidable. It is measured either one-way (the time from the source sending a packet to the destination receiving it), or round-trip (the one-way latency from source to destination plus the one-way latency from the destination back to the source).

Modem - modulator-demodulator is a device that modulates an analog carrier signal to encode digital information, and also demodulates such a carrier signal to decode the transmitted information.

Packet Loss - is commonly measured as the percentage of packets that enter the broadband provider's network but are not delivered. The most common cause of packet loss is network congestion. Lower packet loss means better quality, but a small amount of packet loss is expected, and some applications adjust their sending rate by measuring packet loss.

Router - is a home networking device, used as a gateway to connect devices in the home to the Internet or other WAN.

Throughput - is the sum of the data rates that are delivered to all terminals in a network.

Upload – is the speed of the connection when sending data from your computer to the Internet.

VDSL2 - Very-high-bit-rate digital subscriber line 2 is an advanced standard of digital subscriber line (DSL) broadband wireline communications designed to support the wide deployment of triple play services such as voice, video, data, high definition television (HDTV) and interactive gaming. VDSL2 enables operators and carriers to gradually, flexibly, and cost-efficiently upgrade existing xDSL infrastructure.

Hawaiian Telcom Terms of Service for Residential Customers

Hawaiian Telcom Terms of Service for Business Customers

Hawaiian Telcom Terms of Service for TV