HMP&L Network Management Policy

Network Management Policy Version 1 – July 23, 2024

Henderson Municipal Power and Light (“HMP&L” or “Company”) is committed to providing our customers with the best online experience possible. HMP&L uses reasonable network management practices consistent with industry standards and uses minimally invasive tools and technologies. Just as the Internet continues to evolve, so too, will our network management policies. Should HMP&L not apply reasonable network management practices, our customers could be subject to the negative effects of, among other risks, security attacks, viruses, and spam, resulting in possible degradation of services. You may also access our most current Acceptable Use Policy (AUP) on our website, https://www.hmplfiber.com. 

Network Overview 
HMP&L operates a state-of-the-art broadband network whereby fiber optic cable is brought past each home and business. HMP&L builds a fiber drop from the street to connect to any home or business that purchases services and where access is granted. (It should be noted that not all residential apartment buildings and multi-tenant office buildings allow access.) The broadband network enables us to bring the benefits of the extraordinary bandwidth carrying capacity of fiber Optics to each HMP&L Fiber subscriber.     

Information Regarding Our Network Practices 
The FCC requires us to provide descriptions of our Network Management Practices to include Application-Specific Behavior Practices, Device Attachment Rules, Security Practices, Performance Characteristics, Privacy Policies, and Customer Redress Options. 

Congestion Management: 
Given the current bandwidth capacity, limited congestion management practices are being employed today. HMP&L utilizes network policies to prioritize phone and enterprise services to maintain Quality of Service (QoS) standards in the event of unlikely network congestion.  HMP&L reserves the right to employ additional congestion management practices in the future. 

Application-Specific Behavior: 

Does HMP&L block or rate-control specific protocols?   
• HMP&L may block certain traffic to protect HMP&L broadband subscribers from malicious applications such as spam, viruses, bots, hackers and other malicious activities, as needed. HMP&L may block traffic network sources that are known by the industry to spread malware and from applications that are known to propagate these malicious activities.   
• If HMP&L did not block and/or control in-turn types of activities, HMP&L high speed Internet subscribers’ computers could become infected with all manner of viruses and other malware that could in-turn affect other networks through the Internet.  
• HMP&L does not block any other kinds of traffic. HMP&L applies the philosophy of complete network neutrality, and we treat traffic to and from all subscribers the same. 

Does HMP&L modify protocol fields in ways not prescribed by protocol standard? 
• HMP&L does not modify protocol fields not prescribed by protocol standards. 

Does HMP&L inhibit or favor certain applications or classes of applications? 
• HMP&L does not inhibit or favor applications or classes of application over its HighSpeed Internet/broadband data network. All traffic is treated in a “protocol-agnostic” manner, which means management is not based on the applications and is also content neutral.   

Device Attachment Rules: 

Does HMP&L restrict the types of devices that it allows to connect to the network? 
• HMP&L Home/Residential service does not allow customers to connect switches or hubs directly to the IP port. A customer is limited to one (1) MAC/IP address per service port.   
• HMP&L Business/Enterprise Service may include additional IP address space if purchased as an additional service.  If there are restrictions, is there an approval procedure for devices connecting to the network? 
​• For any questions regarding the types of devices allowed or required, customers should contact support at 270-631-0640 or email: [email protected]. While there are no formal approval procedures to get a specific device approved for connection to the network, all devices must be UL certified and carry the FCC Part 64 certification. 

Security: 

What are the practices used to ensure end-user security or security of the network? 
• HMP&L uses the following practices to ensure end-user security and network security:  o HMP&L employs protocols that can identify traffic on the network and what part of the network the traffic originated on and the portion of the network the traffic is trying to reach. The use of these types of protocol helps HMP&L understand the flow of network traffic in order to best engineer the network as well as to troubleshoot the network.   
o HMP&L utilizes anti-spoof software which is intended to identify and isolate one user’s hardware from impersonating another user’s hardware. 
o HMP&L utilizes the industry practice of blacklisting and blocking access from other ISP networks that are spreading malicious software. 
o The HMP&L network utilizes encryption to stop unlawful access to specific traffic. 
• HMP&L utilizes protocols and practices to protect and secure subscriber data as well as to protect the HMP&L broadband network for the benefit of all subscribers.  These protocols allow HMP&L to comply with federal CALEA and other Law Enforcement requirements. 

What conditions trigger a security mechanism to be invoked?   
• HMP&L monitors the network, and triggers security mechanisms upon discovery or customer reported instances of unwanted network intrusion on the network. HMP&L would react in a timely manner to such an intrusion and would refer to Law Enforcement Agencies as needed.   

Performance Characteristics: 

A general description of the service offered, including Service Technology, Expected and Actual Speeds, Expected and Actual Latency, Suitability of the Service for Real-time Applications follows: 
• Service Technology 
o HMP&L uses a FTTH XGS-PON access system to deliver broadband services to customers.   
o In the HMP&L network, there are no electronics between the fiber network center and the customer. No electronics means that there are fewer failure points in the network and superior service quality for our customers. 
• Expected and Actual Speeds 
o The expected speeds for our products are at the advertised rates, and the actual speeds are within a reasonable variance as advertised. It is possible for customers to experience slower speeds on the open Internet due to the nature of the open Internet and not due to any blockage or congestion on the HMP&L network.   
• Expected and Actual Latency 
o Latency is another measure of Internet performance. Latency is the time delay in transmitting or receiving packets on a network. Latency is primarily a function of the distance between two (2) points of transmission and is typically measured in milliseconds. Within the HMP&L network, the actual latency is generally around 40 milliseconds or less. 
• Suitability of the Service for Real-time Applications  o Customers can achieve the speeds on our network that they subscribe to, 24/7, without slowdowns or blockages on our networks.   

System and Network Security: 

Subscriber and/or Users are prohibited from violating or attempting to violate the security of HMP&L, including, without limitation, (a) accessing data not intended for such Subscriber and/or User or logging into a server or account which such Subscriber and/ or User is not authorized to access, (b) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization, (c) attempting to interfere with, disrupt or disable service to any user, host or network, including, without limitation, via means of overloading, flooding, mail bombing or crashing, (d) forging any packet header or any part of the header information in any E-mail or newsgroup posting, or (e) taking any action in order to obtain services to which such Subscriber and/or User is not entitled. Violations of system or network security may result in civil or criminal liability. We may investigate occurrences that may involve such violations, and we may involve and cooperate with law enforcement authorities in prosecuting Users who are alleged to be involved in such violations. Additional requirements and/or penalties apply as found in HMP&L’s Acceptable Use Policy (AUP). 

Suspension or Termination: 

Any Subscriber or User which HMP&L determines, in its sole discretion, to have violated any element of this Network Management Policy shall receive a written warning, and may be subject at our discretion to a temporary suspension of service pending such Subscriber’s agreement in writing to refrain from any further violations; provided that HMP&L may immediately suspend or terminate such User’s service without issuing such a warning if HMP&L, in its sole discretion deems such action necessary. If we determine that a Subscriber or User has committed a second violation of any element of this Network Management Policy, such Subscriber or User shall be subject to immediate suspension or termination of service without further notice, and we may take such further action as we determine to be appropriate under the circumstances to eliminate or preclude such violation. HMP&L shall not be liable for any damages of any nature suffered by any Subscriber, customer, User, or any third party resulting in whole or in part from HMP&L’s exercise of its rights under this Policy. Additional requirements and/or penalties apply as found in HMP&L’s AUP. 

Service Monitoring: 

HMP&L has no obligation to monitor the services but may do so and disclose information regarding the use of the services for any reason if we, in our sole discretion, believe that it is reasonable to do so, including to satisfy laws, regulations, or other governmental or legal requirements or requests; to operate the services properly, or to protect itself and its Subscribers. 

Network Inspection: 

Do network management practices entail inspection of network traffic? 
• HMP&L may examine traffic to the extent needed to utilize the network safety features listed earlier such as eliminating spam or intercepting malware. HMP&L does not inspect traffic for any purpose other than to keep track at the network level, where traffic flows in order to make certain that the network is adequate for the demands of customers.   

Is traffic information stored, provided to 3rd parties or used by the ISP for non-network management purposes? 
• The only time that any stored information is provided to any 3rd party is in response to a court order from a valid and qualified law enforcement agency. 

Complaint Redress Options: 

What is HMP&L’s practices for resolving end-user and edge provider complaints and questions? 
• HMP&L first logs all complaints of trouble as a trouble ticket in a trouble log system. This allows for numeric identification of each trouble reported on the network. 
• HMP&L assigns a priority to each trouble ticket based upon the perceived severity of the problem.   
• HMP&L attempts to identify and address problems from its Network Operations Center (NOC). If the NOC is unable to clear a reported problem, then a technician in a truck is dispatched to address the problem. 
• If the problem is of such severity that a field technician cannot solve the problem, the problem is escalated to an administrator. If the administrator is unable to solve the problem, it is generally escalated to an external consultant or to the vendor that made the equipment in question. HMP&L contracts with experienced vendors for as-needed troubleshooting and resolution in support of the network.   
• The customer may be notified depending upon the severity and type of problem.   
• Trouble tickets are retained so that HMP&L can view a history of trouble at a specific customer site, a specific neighborhood or with a specific brand or piece of equipment.     

Prohibited Uses and Activities:   

HMP&L’s Acceptable Use Policy (AUP) prohibits uses and activities of the service that interfere with or diminish the use and enjoyment of the service by others, infringe on the rights of others or that are illegal. The AUP is posted on our website. 

No Waiver/Severability: 
Any failure of HMP&L to enforce this Policy shall not be construed as a waiver of any right to do so at any time. If any portion of this Policy is held invalid or unenforceable, that portion will be construed consistent with applicable law, and any remaining portions will remain in full force and effect. 

HMP&L reserves the right to modify this Network Management Policy at any time. We will notify you of any material changes via written, electronic, or other means permitted by law, including by posting it on our website. If you find the changes unacceptable, you have the right to cancel the Services. If you continue to use the Services after receiving notice of such changes, we will consider that as your acceptance of the changes.