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CITIZENS TELEPHONE COMPANY Broadband Internet Service Network Management Policy

Citizens Telephone Company ("Citizens" or "Company") provides this Policy in order to disclose its network management practices in accordance with the FCC's Open Internet Rules. Information about Citizens' other policies and practices are available at www.sowega.net ("Citizens Website").

Citizens manages its network to ensure that all of its customers experience a safe and secure broadband Internet environment that is fast, reliable and affordable. Citizens 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 and videoconferencing.

Citizens manages its network for a number of reasons, including optimization, as well as congestion- and security-protocol-management. But, very few of Citizens' customers are impacted by the protocols and practices that Citizens uses to manage its network.

Citizens' Network Management Practices

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

I. Managing Congestion

Citizens periodically monitors the connections on its network in the aggregate to determine the rate of utilization. If congestion emerges on the network, Citizens will engage in the re-routing of Internet traffic to relieve congestion. In order to reduce instances of congestion, Citizens adds capacity to its network when utilization has reached a level of at least 70%. On our core and access networks, Citizens may increase capacity by adding FTTH nodes, transport, Internet aggregation routers and bandwidth, as needed.

On Citizens' 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 when instances of congestion do occur on Citizens' network.

Customers whose conduct abuses or threatens Citizens' network or which violates the Company's Acceptable Use Policy or Internet service Terms and Conditions 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.

Citizens' 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. Citizens' network management does not relate to any particular customer's aggregate monthly data usage.

II. Network Security

Citizens 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 providing resources to its customers for identifying and reporting such threats as spam, viruses, firewall issues, and phishing schemes. Citizens also deploys spam filters in order to divert spam from an online customer's email inbox while allowing the customer to control which emails are identified as spam.

As its normal practice, Citizens does not block any protocols, content or traffic for purposes of network management except that the company 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. Citizens also has a port filtering policy aimed at reducing the spread of computer-related viruses and protecting your computer from intruder access.

Except as may be provided elsewhere herein, Citizens does not currently engage in any application-specific behaviors nor does it employ any device attachment rules for its network. Citizens does currently block certain well-known ports that are commonly exploited on the Internet.

II. Technology

Citizens' network management employs a variety of industry-standard tools, applications and devices to monitor, secure and maintain its network. Citizens uses MRTG software to monitor and manage its network

IV. Monitoring Schedule

Citizens uses network management software to conduct periodic monitoring of the network in order to detect abnormal traffic flows, congestion, network security breaches, malware, loss, and damage to the network.

V. Network Performance

Citizens takes measurements of various components for network performance, analysis of the measurements to determine normal levels, and determination of appropriate threshold values to ensure required levels of performance for its network. Citizens measures such components as mean upload/download speeds, latency, internal testing, and consumer speed tests to gauge network performance. The Company monitors the values of these components to determine the overall performance of the network. The following is a best approximation of Citizens' Network Management Performance based on the measured components:

Citizens 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 Citizens' network.  Citizens measures availability, latency, and aggregate utilization on the network and strives to meet internal service level targets. Citizens' average latency speed is 29 milliseconds.  However, customer's service performance may also be affected by one or more of the following: (1) the particular websites being accessed; (2) capacity in the public Internet beyond Citizens' network; (3) customer's computer and equipment (including wireless router); and (4) inside wiring at customer's premise. Citizens actual Download and Upload speeds average 80-90% of advertised speeds. VI. Specialized Services

Company does not currently offer any specialized services. Accordingly, customers' broadband experiences will not be impacted.

VII. Commercial Terms

A description of Citizens' service offerings and rates may be found on Citizens' website at the following link: sowega.net. Citizens' Privacy Policy may be found on Citizens' website at the following link:sowega.net.

For questions, complaints or requests for additional information, please contact Telephone Company at:

Sumter County (229) 874-2230
Dooly and Crisp Counties (229) 268-0230
All Other Areas 1-(800) 267-2053