Archive for month: December, 2017

Promoting Investment in the 3550-3700 MHz Band

Before the Federal Communications Commission Washington, DC 20554

In the Matter of Promoting Investment in the 3550-3700 MHz Band Petition for Rulemaking Regarding the Citizens Broadband Radio Service

GN Docket No. 17-258 RM-11788 (Terminated) RM-11789 (Terminated


California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these comments in response to the Notice of Proposed Rulemaking and Order Terminating Petitions (“Notice and Order”) issued October 24, 2017.


GeoLinks is proud to service the largest coverage area of any single fixed wireless Internet service provider (“ISP”) in the state the California.  While the Company had previously focused on business and enterprise customers, in 2016 GeoLinks expanded its customer base to include nearly 30 rural school districts and surrounding communities throughout the state that previously had not had access to any high-speed broadband service.  As the Company expands, it strives to reach more unserved and underserved areas within California and beyond.  GeoLinks provides these comments to urge the Commission to adopt rules with respect to the 3550-3700 MHz Band (the “3.5 GHz Band”) that promote competition and adopt general spectrum practices that allow small and mid-sized ISPs to deliver competitive high-speed broadband services to help close the digital divide.

As GeoLinks has explained before, millions of Americans lack what is, by today’s standards, considered high-speed broadband access – especially in rural areas. Sparsely populated rural areas are not well suited for traditional, wired broadband service given the cost to build and deliver a cable/ fiber-based network.  However, fixed wireless broadband technology can provide high-speed broadband to consumers in these areas for a fraction of the cost.  For this reason, it is imperative that spectrum resources be allocated in ways that allow fixed wireless ISPs to deploy services to these regions.

GeoLinks understands that the 3.5 GHz Band is gaining traction as “one of the core mid-range bands for 5G network deployments throughout the world” and acknowledges that any rules the Commission develops for this band will be primarily for 5G mobile wireless use.[1]  However, this band is also well suited for other wireless technologies that can be deployed quickly to start closing the digital divide.  GeoLinks urges the Commission to develop rules for this band that support 5G deployment without closing off the 3.5 GHz Band to other uses, such as fixed wireless service.


A. Licenses Should Be Granted in a Manner that Promotes Competition

In its comments on the Public Notice issued June 22, 2017, GeoLinks supported a longer PAL license term.[2]  The Company believes that longer terms will allow license holders time to better utilize the spectrum.  Specifically, the expectation of extended use of a specific band of spectrum creates certainty that will allow license holders to work with equipment manufacturers to develop and produce new equipment at lower costs.  These lower costs will, in turn, allow license holders to invest more resources into their networks to promote higher speeds, additional roll out, etc.  However, in supporting these longer license terms, GeoLinks urged the Commission to ensure that any licenses granted in the 3.5 GHz Band are allocated in ways that allow for robust competition.[3]  Specifically, spectrum resources should not be available to only those companies with large amounts of capital or those who would purchase it as an asset with no intention of utilizing it to its full potential.

To ensure such competition can flourish within the 3.5 GHz Band and that it can be used as a tool to help close the digital divide, GeoLinks suggests the following approaches:

i. The Commission Should Ensure Adequate PAL Allocation to Promote Competition

The Commission should consider the role various technologies may play with the 3.5 GHz Band and ensure PALs are allocated in ways that promote competition.  Fixed wireless ISPs can offer a competitive choice to traditional, wired broadband service providers for a fraction of the cost.  These technologies can be rolled out quickly and are the most cost-effective way to connect unserved consumers throughout the country.  Allocating PALs within the 3.5 GHz Band in a way that allows these technologies to compete will help ensure the Commission’s stated goal of promoting competition.

One way in which the Commission can ensure competition within the 3.5 GHz Band is by keeping its existing spectrum aggregation limit in place.  In the Notice and Order, the Commission asks whether it should modify or remove its current 40 MHz spectrum aggregation limit.[4]  GeoLinks asserts that allocating more than 40 MHz of spectrum to one PAL holder will essentially close off the band to any other provider that could use that spectrum to provide high-speed broadband service.  Moreover, allocating more than 40 MHz to one PAL holder that is not positioned to utilize the band immediately (e.g. a mobile wireless carrier planning to utilize the band for future 5G services) could mean that the 3.5 GHz Band would not be utilized fully for an indefinite amount of time.  The Commission should reject any rule changes that could promote inefficient use of spectrum or spectrum warehousing.  Along this vein, the Commission should also create rules to ensure that an entity cannot circumvent this aggregation limit by acquiring another PAL license holder.  In the case of an acquisition, the remaining PAL holder should be required to relinquish any spectrum in excess of 40 MHz in the band within the specific geographic license area.

In addition, PALs should be distributed in a way that ensures a mixture of technologies are able to utilize the 3.5 GHz Band.  Specifically, GeoLinks suggests that the Commission create a licensing scheme that distributes PALs amongst technology types as equally as possible.  For example, if mobile wireless service providers and fixed wireless ISPs apply for PALs within the same geographic area, the Commission should ensure that both types of technologies are able to obtain PALs in that area.  In other words, the Commission should not let one technology type dominate the entire band within a geographic area.  This will help ensure that the specific characteristics of the 3.5 GHz Band are utilized in more efficient and technology neutral manner.

ii. The Commission Should Require PAL Holders to Meet Rigorous Performance Requirements Focused on the Deployment of High-Speed Broadband to Unserved Areas

In the Notice and Order, the Commission asks whether “if we adopt longer term, renewable PALs, it would serve the public interest to adopt certain performance requirements to ensure that the spectrum is put to its best use in an efficient and effective manner.”[5]  As an initial matter, GeoLinks believes that any spectrum license should carry with it the requirement to serve the public interest.  Spectrum is, first and foremost, a public resource and should be allocated accordingly.  GeoLinks asserts that PALs should be awarded in a way that promotes the Commission’s interests in closing the digital divide.

GeoLinks proposes that the Commission implement a requirement to provide broadband service over the 3.5 GHz Band to some minimum portion of the geographic license area within a reasonable time frame (regardless of how large or small the license area may be).  Specifically, GeoLinks recommends that this minimum be set high enough to ensure that unserved areas (if applicable) within the license area are not left behind.  In addition, if a PAL is renewed, it should carry a new set of buildout or network improvement requirements to ensure PAL holders do not sit on spectrum licenses without fully utilizing them.

GeoLinks urges the Commission to require license holders to provide status updates regarding their deployment/ network improvements within the 3.5 GHz Band by census block.  Reporting should be required on a quarterly basis for the first year of the initial license period or renewal and annually thereafter.  In addition, the Commission should develop rules to require relinquishment, partition, or disaggregation of the PAL if deployment requirements are not met (as discussed in more detail below). These requirements will alleviate the risk of spectrum warehousing within any given license area and encourage rapid deployment of high-speed broadband by license holders.

iii. If PAL Holders are Unable or Unwilling to Fully Utilize a PAL, the Commission Should Create Rules to Allow (or Require) that Excess Spectrum to be Partitioned and Disaggregated

As noted above, spectrum is a public resource and it should be managed in a way that more effectively and efficiently serves the public need.  Regardless of what license area the Commission may adopt, the Commission must implement rules for PAL holders that prohibit spectrum warehousing.

GeoLinks believes that it will be inevitable that some PAL holders may be unable or unwilling to expand their services over the 3.5 GHz Band throughout an entire license area.  Without rules to allow (or require) relinquishment, partition and/ or disaggregation of the remaining license area, PAL holders could merely sit on the unused spectrum.  The likely result would be that urban areas within a license area would receive the benefit of services offered over the Band while rural areas would be left behind and spectrum that could otherwise be used for broadband deployment would be left unused.  To avoid this potential problem, the Commission should create rules that would allow other interested parties to acquire the unused portion of the PAL license areas.

In making this recommendation, GeoLinks does not advocate that PAL holders should be able to set the price or terms for transferring unused spectrum to an interested party.  GeoLinks firmly believes that if a PAL holder is not willing to utilize the 3.5 GHz Band throughout the entire license area or does not meet certain mandatory buildout requirements (such as those suggested above), the holder should not reap a benefit.  GeoLinks urges the Commission to create rules that discourage spectrum warehousing by ensuring that PAL holders do not obtain a windfall for poor spectrum management and allowing other interested parties to obtain unused spectrum resources.

B. Geographic Areas Should Be Determined in a Manner that Promotes Competition and Accounts for Regional Broadband Needs

In its comments on the Public Notice, GeoLinks did not oppose the use of PEAs in licensing PALs but urged the Commission to consider the unique characteristics of rural vs. more populated areas when determining how those areas should be licensed.  Specifically, GeoLinks suggested that the Commission consider whether rural areas would benefit more from using smaller geographic areas (such as by census tract or county) vs. PEA if it would ensure more timely broadband access to rural communities.

PEAs differ in size as well as in urban vs. rural make up.  For example, PEA 2 in Southern California,[6] encompasses very populous areas like Los Angeles and Orange Counties as well as large rural areas that are currently deemed “unserved” by high-speed broadband such as San Bernardino and Kern Counties.[7]  Conversely, PEA 192 is only comprised of Cumberland County, NC, which encompasses Fayetteville.  These PEAs are undoubtedly very different and a licensing scheme appropriate for one would not necessary be appropriate for the other.

GeoLinks recommends that the Commission develop PAL licensing rules that account for the differences between areas like PEA 2 vs. PEA 192.  Logic dictates that areas such as PEA 2 should be divvyed up in a way that would account for differences between the different regions and sub-regions within it.  Because census areas are widely used and understood, division by census area (tract or even block group) would likely be easier to implement that some other metric.  However, the Company urges the Commission to use its expertise in assessing broadband deployment and population centers to develop a licensing scheme that is in the best interests of the specific area that license falls within.

Regardless of what geographic area(s) the Commission adopts for PALs within the 3.5 GHz Band, as discussed above, GeoLinks urges the Commission to develop and enforce strict buildout/ service requirements and develop robust relinquishment, partition and/ or disaggregation rules to ensure that license holders utilize the spectrum within the entire license area held.  This will help ensure that rural, sparsely populated areas that may not be attractive to some license holders are not left with no way to benefit from this band.

C. Connect America Fund Phase II Recipients Should Get Priority Access to PALs within Auction Award Areas

As GeoLinks has previously expressed to the Commission, the Company believes that the Connect America Fund Phase II Auction (“Phase II Auction”) presents an opportunity for the Commission to develop spectrum licensing policies specifically focused on unserved and rural areas.  Specifically, GeoLinks urged the Commission to allow Phase II Auction awardees the opportunity to obtain priority access to spectrum resources with which to serve eligible areas.  GeoLinks believes that this priority access could be considered in developing rules for the 3.5 GHz Band.

GeoLinks proposes that Phase II awardees (or, depending on timing, Phase II applicants that pass the short form phase of the application process) that rely on spectrum resources be allowed “first crack” at a PAL covering applicable eligible areas.  The 3.5 GHz Band offers a broadcast range that would allow fixed wireless ISPs such as GeoLinks the ability to provide high-speed broadband service across large rural areas with minimal tower construction.  Therefore, GeoLinks asserts that access to spectrum resources in this band (especially resources sufficient enough allow point-to-multipoint (“P2MP”) services) would ensure the speed tiers that the Commission seeks from Phase II applicants could be met at a fraction of the cost of traditional wired networks.  GeoLinks suggests that the Commission develop licensing rules for the 3.5 GHz Band that will maximize the benefit of the Phase II auction.

D. If the 3.5 GHz Band Will be Allocated Primarily for 5G Services, the Commission Should Allocate Other Spectrum Bands for Fixed Wireless Services

As stated above, GeoLinks asserts that the Commission should make the 3.5 GHz Band available to different technology types on an equal basis.  Doing so would allow consumers to benefit from different service offerings and ensure competition opportunities.  However, as noted, GeoLinks understands that the 3.5 GHz Band will be primarily be allocated for 5G mobile wireless use.  If that is the case, the Company urges the Commission to allocate other bands primarily for fixed wireless technology uses and implement rules similar to those proposed herein to ensure that spectrum is fully utilized.

As an initial matter, mobile wireless carriers have more spectrum than they need to meet current service requirements and 5G technology is still years from being fully developed and deployed.  It makes little sense to allocate most, if not all, of 3.5 GHz Band plus other mid-band spectrum plus the spectrum that wireless carriers already control to a technology that is still being developed and won’t be ready for deployment for an indefinite amount of time.  Instead, the Commission should develop spectrum allocation policies that allow for immediate deployment of high-speed broadband services, specifically in rural areas. These policies are imperative to closing the digital divide.

In the recent Restoring Internet Freedom Order, the Commission determined that “network investment is key to closing the digital divide, spurring competition and innovation that benefits consumers.”[8]  To reach this goal and spur this network investment, the Commission must create avenues by which competition can flourish and alternative providers can enter the market.  With respect to wireless technologies, this can be accomplished by making additional spectrum resources available.  Access to dedicated spectrum will allow fixed wireless ISPs to utilize clean spectrum connections to deliver robust, high-speed service.  Specifically, access to dedicated licenses for P2MP connections will allow for high-speed broadband connections to numerous locations from a single transmission point, resulting in additional bandwidth and deployment opportunities at a fraction of the cost of traditional, wired broadband services.  GeoLinks believes there are numerous bands well suited for P2MP technologies (in addition to the 3.5 GHz Band), including 3.7-4.2 GHz, 5.925-6.425 GHz, 10-11 GHz, and 23-24 GHz.[9]  The Company encourages the Commission to continue its work to develop new spectrum allocation policies and, in doing so, urges the Commission to ensure these policies create the competitive opportunities that will promote network investment.









In conclusion, GeoLinks urges the Commission to adopt rules with respect to spectrum licensing in the 3.5 GHz band that do not close off the band to fixed wireless service providers, ensure efficient use of the band, prohibit spectrum warehousing, and promote broadband deployment and competition.

Respectfully submitted,


/s/ Skyler Ditchfield, Chief Executive Officer

/s/ Melissa Slawson, General Counsel/ V.P of Government Affairs and Education

December 28, 2017



[1] Notice and Order at para. 2.

[2] See Comments of California Internet, L.P. DBA GeoLinks, GN Docket No. 12-354 (filed August 8, 2017), at 2

[3] Id.

[4] Notice and Order at para 27.

[5] Notice and Order at para 17.

[6] PEA 2 is comprised of Kern, Los Angeles, Orange, Riverside, San Bernardina, San Luis Obispo Santa Barbara, and Ventura Counties.

[7] See (last visited on December 22, 2017).

[8] Public Notice, “FCC Acts to Restore Internet Freedom; Reverses Title II Framework, Increases Transparency to Protect Consumers, Spur Investment, Innovation, and Competition,” WC Docket No. 17-108 (rel. Dec 14, 2017).

[9] In developing new spectrum policies, GeoLinks urges the Commission to undertake rulemakings to develop rules to allow for P2MP services in the 11 and 23 GHz bands (which are currently only for point-to-point services).  GeoLinks asserts that any new rules developed for any band should include the rigorous reporting and buildout requirements discussed herein and should set forth a process for relinquishment of any unused spectrum.

GeoLinks Re-Building Burned CA Tower Sites

California-based GeoLinks is working to replace towers burned in the wildfires. That’s key, as the latest news indicates the return of powerful winds is making the Thomas fire dangerous again.

GeoLinks is based in Camarillo, which is in Ventura County. The company has hundreds of telecom towers in Ventura, Santa Barbara and Los Angeles Counties. GeoLinks personnel battle flames as they work to rebuild burned down sites and restore service, according to Marketing Director Lexie Olson. “Driving through Ventura was pretty surreal, lots of smoke and multiple fires visible from the street,” she wrote in a blog post, sharing the personal account of a GeoLink infrastructure technician.

“Driving up to the actual tower was disheartening at first, just because of how much was burned; one of the posts holding up the gate was completely destroyed, leaving the gate lying on the ground. It was there we first noticed a fence post smoking…but we continued on,” according to the account.

The crew got the destroyed site back up in a couple of hours but as they began their trek down the mountain, they noticed the fence post they saw smoking on their way up the mountain grew “to multiple en-flamed posts, threatening the surrounding area. We immediately turned around, went back to the tower site where we had stored a fire extinguisher, and returned to put out the fires. It was a real-life example of how quickly these fires can spread,” according to the infrastructure technician.

The GeoLinks team, some of whom lost their homes, repaired 12 destroyed sites throughout Ventura and Ojai as of December 14, accounting for more than 500 square miles of coverage area. They continue this work today.

GeoLinks rebuilds sites with Mimosa gear as Thomas Fire burns in Southern California

Original Article

GeoLinks employees are literally putting out fires as they strive to replace damaged telecom sites throughout the area where fires are destroying homes and threatening lives in Southern California.

The company, based in Camarillo, which is in Ventura County, has been working around the clock since the Thomas Fire started on Dec. 4. At times, workers have used the fire extinguishers stored in emergency packs in company vehicles to douse hot spots they see along the way to fixing infrastructure.

As of Dec. 14, the GeoLinks team—some of whom have lost or damaged homes—had repaired 12 sites that were destroyed throughout Ventura and Ojai, accounting for more than 500 square miles of coverage area. The company uses licensed and unlicensed gear from Mimosa Networks.

“A lot of our employees live in these communities,” and they were evacuated, including one employee who was still working remotely even though he lost everything he owned, said GeoLinks employee Lexie Olson, who had to be evacuated in the middle of the night but whose home is still standing. “It’s something that is impacting our direct community in every way. It’s pretty intense.”

The company is in close communication with fire, police and National Guard teams so they know when it’s safe to go into a particular area for repairs. On Thursday, the fire took the life of a fire apparatus engineer from San Diego, the second death attributed to the blaze.

Olson estimated 40 GeoLinks people are out working in the field; the company employs about 60 and growing. In some cases, the GeoLinks gear was up and running and able to provide internet service to customers even before their electricity was restored, GeoLinks President Ryan Adams told FierceWirelessTech. That said, “we’re never going to put our employees in dangerous situations where we think they can get hurt,” he added.

Adams and CTO/co-founder Ryan Hauf were watching the situation as it started to unfold last week. “We felt it was our duty to assist folks,” to get back to normal as soon as possible, Adams said. “Our team has been working around the clock” with folks sleeping in the office and cars—but not for long. “We realize we have a responsibility as a telecommunications company to make sure that people have the ability to communicate.”

Adams said the service provider needed a workhorse and something that would support backhaul as well. “We’re big fans of the Mimosa brand,” he said. “We keep a really healthy stock of Mimosa equipment on hand.”

Mimosa’s gear works at 11 GHz licensed and 5 GHz license-free. Depending on the situation, a service provider could get Mimosa’s low-cost gear in the 5 GHz band out into the field right away, according to Mimosa co-founder and CMO Jaime Fink. Alternatively, if a client has more time, they can apply for a 11 GHz license, which may take three to four weeks per link.

Positioning itself as a disrupter going up against the “big four” carriers, GeoLinks was founded in 2011 and started offering fixed wireless internet to rural homes and people in the area who previously didn’t have access to high-speed internet, according to Adams. GeoLinks’ customers include residential and business customers; the company got its start in Ojai, which its where co-founder and CEO Skyler Ditchfield was born and where many employees live.

Ojai, population around 7,461, has been particularly hard hit by the fires.

Knowing that the weather and conditions could change in an instant, they’re watching things closely. “Fortunately we have the best fire departments, we have the best rescue crews and first responders,” Adams said. “I can’t say enough about the way Ventura County has come together.”

Thomas Fire Updates

The Thomas Fire is a massive wildfire burning in Ventura and Santa Barbara Counties. The fire began north of Santa Paula, near Steckel Park and Thomas Aquinas College, on December 4, 2017. It has burned approximately 252,500 acres thus far, making it already the fourth-largest wildfire in modern California history, destroying at least 930 structures, damaging more than 200 others; and forcing upwards of 100,000 residents to evacuate.

Ray Ford / Noozhawk photo


(Ryan Cullom / Ventura County Fire Department photo)

GeoLinks has hundreds of telecom towers located throughout the Ventura, Santa Barbara and LA counties that provide service to thousands of both urban and rural families. Within just hours of the fires’ inception, the GeoLinks’ team sprang into action, literally battling flames as they worked relentlessly to rebuild burnt down sites and restore service.

“Driving through Ventura was pretty surreal, lots of smoke and multiple fires visible from the street. Driving up to the actual tower was disheartening at first, just because of how much was burned; one of the posts holding up the gate was completely destroyed leaving the gate lying on the ground. It was there where we first noticed a fence post smoking…but we continued on.

The view on the drive up was hindered by smoke, we couldn’t see the ocean, or even the Crown Plaza. That’s when everything really hit me… to know we were celebrating and having fun on Saturday at GeoLinks’ holiday party just a couple miles away, and now we were dealing with the horrible fallout of this natural disaster. It was a wild juxtaposition of mindsets to comprehend just over the span of a few days…

From the top of the mountain, the view was incredible, in a very somber way. Smoke spread in every direction, winds whipping sand and ash all around us. Although, we knew what we were doing was important, so we got to work and had the completely destroyed site back up and running in just a couple hours. We then started our trek back down the mountain when we noticed that same smoking fence had grown to multiple enflamed posts threatening the surrounding area. We immediately turned around, went back to the tower site where we had stored a fire extinguisher, and returned to put out the fires. It was a real-life example of how quickly these fires can spread…” — Personal Account Shared from GeoLinks’ Infrastructure Technician.

To date, the GeoLinks team has already repaired 12 destroyed sites throughout Ventura and Ojai accounting for more than 500 square miles of coverage area. However, the Thomas Fire continues to wreak havoc at only 35% containment requiring the GeoLinks’ team to continue to work around the clock to maintain service.

Outside of the field, many GeoLinks employees have been personally affected by the fire as well, some even losing their homes. Ultimately, this ongoing natural disaster has affected both the company and surrounding communities in every way possible.

Check back soon for further updates, but in the meantime please visit the below link if you wish to support and give back to those directly affected by the Thomas Fire. Created by GeoLinks’ employees Lexie Olson and Lindsey Ditchfield, 100% of proceeds of these “Ventura County Strong” shirts will be donated to Ventura County residents directly affected by the Thomas Fire.