Network TRANSPARENCY statement
Foothills Communications (“Foothills” or “Company”) provides this Network Transparency
Statement in accordance with the FCC’s Restore Internet Freedom Rules to ensure that you
have sufficient information to make informed choices about the purchase of broadband
services. Information about Foothills’ other policies and practices concerning broadband are
available at www.foothills.net (“Foothills Website”).
Foothills engages in network management practices that are tailored and appropriate for
achieving optimization on the network considering the particular network architecture and
technology of its broadband Internet access service. Foothills’ goal is to ensure that all of its
customers experience a safe and secure broadband Internet environment that is fast, reliable
and affordable. Foothills wants its customers to indulge in all that the Internet has to offer,
whether it is social networking, streaming videos and music, to communicating through email
Foothills’ network management includes congestion- and security-protocol-management and
customers generally will not be impacted by the protocols and practices that Foothills uses to
manage its network.
A. Foothills’ Network Transparency Disclosures
Foothills uses various tools and industry standard techniques to manage its network and deliver
fast, secure and reliable Internet service. Foothills believes in full transparency and provides
the following disclosures about its network management practices:
1. Blocking: Foothills does not block or discriminate against lawful content.
2. Throttling: Foothills does not throttle, impair or degrade lawful Internet traffic.
3. Affiliated Prioritization: Foothills does not prioritize Internet traffic and has no plans to
4. Paid Prioritization: Foothills has never engaged in paid prioritization. We don’t prioritize
Internet for consideration to benefit particular content, applications, services or devices.
Foothills does not have plans to enter into paid prioritization deals to create fast lanes.
5. Congestion Management: Foothills monitors the connections on its network in the
aggregate on a continuous basis to determine the rate of utilization. If congestion
emerges on the network, Foothills will take the appropriate measures to relieve
On Foothills’ 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 do occur on
Customers using conduct that abuses or threatens the Foothills 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.
Foothills’ 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. Foothills’ network
management practices do not relate to any particular customer’s aggregate monthly
Foothills monitors its network on a continuous basis to determine utilization on its
network. Foothills also checks 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 complaint, Foothills provides notification to the
customer via email, phone or mail. If a violation of Foothills’ policies has occurred
and such violation is not remedied, Foothills may seek to suspend or terminate that
6. Application-Specific Behavior: Except as may be provided elsewhere herein, Foothills
does not currently engage in any application-specific behaviors on its network.
Customers may use any lawful applications with Foothills.
7. Device Attachment Rules: For best results, network gateways used on the Foothills
broadband network should be provided by Foothills. Customers may attach devices
of their choosing to their ONT/Fibernet Ethernet connection, including wired or
wireless routers, laptops, desktop computers, video game systems, televisions, or
other network-enabled electronics equipment. However, customers are responsible
for ensuring that their equipment does not harm Foothills’ network or impair the
service of other customers. Foothills is not responsible for the functionality or
compatibility of any equipment provided by its customers. Customers are
responsible for securing their own equipment to prevent unauthorized access to
Foothills’ broadband network by third parties and will be held responsible for the
actions of such third parties who gain unauthorized access through unsecured
8. Network Security: Foothills knows the importance of securing its network and
customers from network threats and annoyances. The company promotes the
security of its network and patrons by protections from such threats as spam,
viruses, firewall issues, and phishing schemes. Foothills also deploys spam filters in
order to divert spam from an online customer’s email inbox into a quarantine file
while allowing the customer to control which emails are identified as spam.
Customers may access the spam files through the email. Spam files may be
automatically deleted if not accessed within 30 days.
As its normal practice, Foothills does not block any protocols, content or traffic for
purposes of network management, but Foothills may block or limit such traffic as
spam, viruses, malware, or denial of service attacks to protect network integrity and
the security of our customers.
B. Network Performance
1. Service Descriptions
Foothills deploys Internet access to its subscribers via Fiber to the Premises (“FTTP”)
technology. The service will be media converted from the fiber optic uplink (GPON, P2P) to a
normal 10/100/1000mbps Ethernet connection using a device called an Optical Network
Terminal (“ONT”). In some cases, a business may purchase a special internet service that may
handoff directly using fiber where a ONT is not required.
2. Network Performance
Foothills makes every effort to support advertised speeds and will dispatch repair technicians to
customer sites to perform speed tests as needed to troubleshoot and resolve speed and
application performance caused by Foothills’ network. Foothills measures availability, latency,
and aggregate utilization on the network and strives to meet internal service level targets.
However, the bandwidth speed at which a particular distant website or other Internet
resources may be downloaded, or the speed at which your customer information may be
uploaded to a distant website or Internet location is affected by factors beyond Foothills’
control, including the speed of the connection from a distant web server to the Internet,
congestion on intermediate networks, and/or limitations on your own computer equipment,
including a wireless router. In addition, your service performance may be affected by the inside
wiring at your premise. Accordingly, you, the customer, must consider the capabilities of your
own equipment when choosing a Foothills broadband service. Your computers and/or wireless
or other networks in your homes or offices may need an upgrade in order to take full advantage
of the chosen Foothills broadband plan.
Foothills tests each service for actual and expected access speeds at the time of network
installation to demonstrate that the service is capable of supporting the advertised speed.
Customers may also test their actual speeds using the speed test located at
http://foothills.speedtest.net/ and may request assistance by calling our business office at 606-
297-3501 or by email at [email protected]
DOWNLOAD & UPLOAD SPEEDS
50 Mbps 50 Mbps 0%
100 Mbps 100 Mbps 0%
250 Mbps 251 Mbps 0%
500 Mbps 501 Mbps 0%
1 Gbps* 941 Mbps -6%
50 Mbps 50 Mbps 0%
100 Mbps 100 Mbps 0%
250 Mbps 250 Mbps 0%
500 Mbps 500 Mbps 0%
1 Gbps* 939 Mbps -6%
* TCP Throughput shown in table. Service is provided over a 1 Gbps Ethernet Connection
running at line rate, however due to overhead of protocols such as IP and TCP the TCP
throughput is lower than 1 Gbps.
3. Impact of Non-BIAS Data Services
Real time services, such as Non-BIAS services, include Voice over Internet Protocol (VoIP) and
Internet Protocol (IP) video services, command optimal bandwidth. As Non-BIAS traffic is
combined with general Internet traffic on Foothills’ network, broadband customers could
experience service delays, although very unlikely, if there is an occurrence of congestion on
Foothills’ network. In any such event, the Non-BIAS traffic is given priority over general
Foothills provides Voice-over-the-Internet-Protocol (VoIP) to its customers. The VoIP traffic
uses private RFC 1918 addresses, dedicated paths for VoIP and QoS on the routers/switches it
touches. Where VoIP traffic is combined with best effort Internet traffic and QoS priority is
employed, the network could endure marginal delays if there are instances of bandwidth
contention, although very unlikely.
The Company offers IP video service to end-users. This non-BIAS data service does not
adversely affect the last-mile capacity available for the Company’s broadband Internet access
services, or the performance of such services. Customer should note that significantly heavier
use of non-BIAS services (particularly IP video services) may impact the available capacity for
and/or the performance of its broadband Internet access services. The Company will monitor this
situation and appreciates feedback from its customers.
C. Commercial Terms
Pricing and additional service information may be found here.
In addition to this Network Transparency Statement, patrons may also find links to the
following on the Foothills Website:
▪ Acceptable Use Policy
For questions, complaints or requests for additional information, please contact Foothills at: