What is the difference between Dedicated Internet Access (DIA) and Shared Internet Circuits?
Federal Communications Commission
Washington, DC 20554
REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS
California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these replies to comments filed in response to the Commission’s NPRM proposing reforms to the Commission’s competitive overlap process in legacy rate-of-return (“RoR”) study areas.
GeoLinks is proud to service the largest coverage area of any single fixed wireless Internet service provider in the state the California and was recently named one of the ten most trusted networking solution providers for 2018. As the Company has grown its territory has grown, as well, expanding availability of its broadband and VoIP offerings into many rural areas of the state.
As GeoLinks has noted in several proceedings before the Commission, 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 often provide high-speed broadband to consumers in these areas for a fraction of the cost. Therefore, GeoLinks believes that the Commission should consider changes to the high-cost program that reflect efficiencies that may be offered by competitive carriers.
Many commenters voice strong opinions regarding the Commission’s 100% overlap process and it is clear that there is stark contrast between the opinions of RoR incumbent local exchange carriers (“ILECs”) and competitive carriers in this regard. As an initial matter, GeoLinks commends the Commission on its inquiry into whether this challenge process should be revised and urges the Commission to make a determination based on what challenge process will “maximize available funding for broadband networks.” Specifically, GeoLinks urges the Commission to revise its 100% overlap process to account for current competitive realities.
As the Commission explains, “to date there has been little participation by unsubsidized competitors.” The RoR ILECs try to explain that this lack of participation is indicative of some shortcoming on the part of competitive carriers. WTA provides examples of unsuccessful attempts to prove 100% overlap. However, instead of showing that the problem is the “nature and quality” of the services offered by competitive carriers, these examples illustrate the inherent problem with the current 100% overlap process – that it ignores the overlap that does exist, no matter how significant, if it is anything less than 100%.
The reality is that the 100% overlap process does not account for the way in which competitive carriers structure their networks and service territories. Unlike ILECs, competitive carriers do not have “study areas.” Instead, competitive carriers’ networks have formed based on consumer demand and market forces. As such, a competitive carrier may have a large network area that overlaps a portion of an RoR ILEC’s service area (perhaps a significant portion) but may not cover 100% of the study area. In addition, as the Commission notes, while one competitive carrier may not cover a signification portion of a RoR ILEC study area by itself, a combination of competitive carriers might. The lack of overlap by one competitive carrier of an entire study area should not negate the reality that overlap is occurring and that competition exists within those areas of overlap.
As even NTCA – The Rural Broadband Association notes, “the entire point of the competitive overlap process is to ensure that support does not flow to areas where overlap exists.” It is difficult for GeoLinks to understand the argument by RoR ILECs that less than 100% overlap should be ignored while also acknowledging that the fund should not subsidize areas where overlap occurs. For these reasons, GeoLinks urges the Commission to revise its 100% overlap process.
As NCTA notes, RoR ILECs are “continuing to receive support in areas that are significantly served by other providers that receive no high-cost support.” This is an inefficient use of funds in areas where there may be significant overlap. As WISPA notes, “a reverse auction mechanism in areas where there is significant, but less than 100%, competitive overlap will better serve consumer needs while more effectively making use of the limited funds available to promote high-quality fixed broadband deployment in high-cost areas.” GeoLinks strongly agrees with WISPA and NCTA that the Commission should introduce an auction approach in any study area where there is significant, but less than 100%, overlap.”
As explained above, competitive solutions, such as those offered by fixed wireless broadband technology, can often provide high-speed broadband to consumers in sparsely populated areas for a fraction of the cost of traditional fiber/cable-based networks. The same concept is applicable to the RoR ILEC study areas at issue here. As NCTA suggests, in these areas, non-incumbent carriers could compete to receive only the amount of funding needed to serve high-cost and unserved areas (which may be significantly less than what it might cost a RoR ILEC to serve the same area). GeoLinks believes this would promote more efficient use of high-cost funds, which could ultimately free up additional funding for additional broadband deployment efforts.
Moreover, in considering an auction mechanism, the Commission should disregard RoR ILEC’s weak arguments that competitive carriers are somehow unable to offer service in unserved areas. As made clear in the Connect American Fund II Auction proceeding, numerous competitive carriers have been deemed financially and operationally qualified to bid on eligible areas. Obviously, the Commission has seen the benefits of what competitive providers can offer and should not now be persuaded otherwise.
In conclusion, GeoLinks urges the Commission to revise its 100% overlap process and create an auction mechanism that will allows for more efficient used of high-cost funds.
/s/ Skyler Ditchfield, Chief Executive Officer
/s/ Melissa Slawson, General Counsel/ V.P of Government Affairs and Education
June 25, 2018
Headquartered in Southern California, GeoLinks is a leading telecommunications company, competitive local exchange carrier, and regulated public utility, nationally recognized for its innovative Internet and Digital Voice solutions. The company delivers Enterprise-Grade Internet, Digital Voice, SD-WAN, Cloud On-ramping, Layer 2 Transport, and both Public and Private Turnkey Network Construction expertly tailored for businesses and Anchor Institutions nationwide.
GeoLinks’ accelerated success is largely due to its flagship product, ClearFiber™, which offers dedicated business-class Internet with unlimited bandwidth, true network redundancy, and guaranteed speeds reaching up to 10 Gbps. Named “Most Disruptive Technology” in the 2018 Central Coast Innovation Awards, GeoLinks’ ClearFiber™ network is backed by a carrier-grade Service Level Agreement boasting 99.999% uptime and 24/7 in-house customer support. With an average installation period of 4 to 7 days, GeoLinks is proud to offer the most resilient and scalable fixed wireless network on the market.
Recognized as a thought-leader in closing the digital divide, GeoLinks proudly sits on an array of national boards, coalitions, and working groups including the Schools, Healthcare & Libraries Broadband (SHLB) Coalition, the Wireless Internet Service Providers Association (WISPA), the Broadband Consortium of the Pacific Coast (BCPC), and the FCC’s Broadband Deployment Advisory Committee’s (BDAC) Streamlining Federal Siting Working Group.
The Passionate Leader
Born in Ojai, California, Skyler Ditchfield is the Cofounder and CEO of GeoLinks, which is the No. 1 Fastest Growing Fixed Wireless ISP in the country, and Inc. Magazine’s Fastest Growing WISP in America. Nationally recognized for its innovative Internet and Hosted Voice Solutions, and dedication to closing the U.S. Digital Divide, GeoLinks is determined to bring connectivity to every unconnected Anchor Institution in America over the next seven7 years.
To accomplish this goal, Skyler is aggressively looking to change the landscape of Internet across America by influencing the reform of broadband funding and spectrum policy on both the state and federal levels. Believing that action fuels influence, Skyler led GeoLinks to successfully connect more schools than any other ISP in both 2016 and 2017 and was an instrumental lobbyist in the passing of AB1665, the Internet for All Act, which brought $330m in new funding to the state of California.
Within his company, Ditchfield is passionate about cultivating the best company culture around—one that combines respect, collaboration, and a “best idea wins mantra.” Both his dedication to closing the digital divide and commitment towards developing an exceptional company culture have won Skyler a variety of accolades including “World’s Top 5 Best Businessmen of 2017”, “Top Innovator in Diversity and Inclusion,” and “2018 Entrepreneur of the Year”.
Thriving on Challenges
According to GeoLinks, the telecom industry is heavily dominated by multi-billion dollar virtual monopolies that receive massive tax credits and federal subsidies. Furthermore, the regulatory landscape and funding on both the state and federal level are tilted heavily to favor these “incumbent” providers—furthering their “perceived” monopoly status. However, GeoLinks thrives on challenges, and are aggressively working to reform and overcome these obstacles. GeoLinks’ ongoing strategy is to out-maneuver incumbent providers in competitive markets nationwide by providing a quality of service they can’t offer and maintain, and by going after businesses they either don’t want or can’t service. It’s in GeoLinks’ DNA to consistently innovate new methods and technologies that pushes it far ahead of the crowd.
Tackling Bad Patches and Preparing for a Better Future
In its early days, cousins and co-founders Ditchfield, CEO, and Ryan Hauf, CTO, decided that they will build their Internet Service Provider (ISP) business model to compete head-tohead with all the big guys—which was not very traditional for a smaller ISP provider. GeoLinks decided that to be successful and to make its goal of becoming a major national carrier a reality, they needed to penetrate the most competitive markets.
Over the past seven years, GeoLinks’ innovative flagship product, ClearFiber™, named “Most Disruptive Technology” in the 2018 Central Coast Innovation Awards, the organization’s superior customer service, and its industry leading Service Level Agreement has led the organization to become the fastest growing telecom in California.
When reflecting on the company’s rapid growth, Ditchfield comments that every struggle has been unique in its needs and solutions. In the beginning, many of these hurdles were finance-based, as the telecom didn’t have a significant financial backer. The organization had to remain as fiscally responsible as possible and fold all its revenue back into the company. As a business, it has learned that being honest and putting customers first always pays off in the long-run. So even in the case of a wrong step, GeoLinks has admitted it, fixed it, and been able to move on swiftly.
In the near future, you can expect to see GeoLinks continuing to expand rapidly delivering gigabit and multigigabit access to new markets across the United States. This also includes working on new technologies and experimental spectrum to deliver gigabit speeds to residential clients. Furthermore, leadership plans to partner with like-minded organizations to expand into sensor networks and specific projects that encompass public safety, research, education, and much more
Skyler Ditchfield is the Co-Founder and CEO of GeoLinks, the No. 1 Fastest Growing Fixed Wireless ISP in the country, and Inc. Magazine’s No. 2 Fastest Growing ISP in America. Nationally recognized for its innovative Internet and Hosted Voice Solutions, and dedication to closing the U.S. Digital Divide, GeoLinks is determined to bring connectivity to every unconnected Anchor Institution in America over the next 7 years.
To accomplish this goal, Skyler is aggressively looking to change the landscape of Internet across America by influencing the reform of broadband funding and spectrum policy on both a state and federal level. Believing that action fuels influence, Skyler lead GeoLinks to successfully connect more schools than any other ISP in both 2016 and 2017, and was an instrumental lobbyist in the passing of AB1665, the Internet For All Act, that brought $330m in new funding to the state of California.
Within his company, Ditchfield is passionate about cultivating the best company culture around—one that combines respect, collaboration and a “best idea wins mantra.”
Federal Communications Commission
Washington, DC 20554
In the Matter of Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band | GN Docket No. 18-122
REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS
California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these reply comments in response to comments received on the Public Notice issued on May 1, 2018.
GeoLinks believes that the 3.7-4.2 GHz band is well-suited to support point-to-multipoint (“P2MP”) broadband access. As GeoLinks has previously stated, P2MP service options are ideal because they allow a wireless service provider to provide dedicated high-speed broadband connections to several end-users (i.e. several households throughout a community) from one location, requiring fewer towers and less equipment than point-to-point connections. This is especially beneficial in rural and high-cost areas and can provide much-needed competition to incumbent providers in urban and suburban areas. With the appropriate rules, the Commission can ensure P2MP use is feasible in the band, which will result in more affordable, high-speed broadband and increased broadband competition.
As stated in the Public Notice, the Commission must assess “the feasibility of allowing commercial wireless services” in the 3.7-4.2 GHz band and submit a report to Congress on its findings. While the Commission could draft a standalone report in compliance with this directive, GeoLinks believes that this presents an opportunity for the Commission to do a deeper dive into how best to utilize the band. As stated in its opening comments, GeoLinks believes that the 3.7-4.2 GHz band offers an opportunity for the Commission to allocate spectrum resources in a way that will promote competition and help bridge the digital divide while protecting current users of the band. Issuing an NPRM in this proceeding would allow the Commission to create a robust record regarding potential uses of the band and technical guidance regarding sharing mechanisms that it may be able to apply to other bands, as well. As such, GeoLinks agrees with T-Mobile that the Commission should open an NPRM in this proceeding and base any report provided to Congress based on the record created as a result.
There is a common theme echoed by the mobile wireless commenters that the 3.7-4.2 band should allocated “for mobile broadband use on a flexible basis” and that the “adjacency to the 3.5 GHz band” justify the “allocating and repurposing” of a large swath of the band for 5G services. However, earmarking the band for mobile broadband services exclusively is not the best use of the band to promote immediate utilization and public interest.
Spectrum is, first and foremost, a public resource and should be allocated in ways that promotes immediate and robust use of it. As GeoLinks noted in its opening comments, the Company agrees with the Broadband Access Coalition (“BAC”) that the band “is not now, and will not for several years, be suitable for mobile use given the existing deployment of FSS earth stations and FS P2P links.” In its opening comments, even T-Mobile acknowledges this fact stating that “T-Mobile recognizes that not all 500 MHz may be available immediately for exclusive terrestrial operations in all locations.” In part, this is because optimal mobile use of the band would require the FCC to repack existing users into another portion of the band or to another band all together. Or, in the alternative, would request that FSS stations be forced to utilize fiber connections to replace downlinks to earth station receivers or even relocate earth stations to more remote locations.
As the Satellite Industry Association (“SIA”) explains, the satellite industry has already invested significant resources into the 3.7-4.2 GHz band. Forcing license holders to shift to a new portion of the band (potentially requiring new transmission equipment), to physically relocate infrastructure (requiring construction and potentially triggering environmental review), or to completely restructure technology platforms could require these companies to lose the benefit of their investments and potentially force them to incur significant costs.
GeoLinks fails to see the public interest argument for requiring license holders to incur potentially significant costs or for additional administrative oversight to repack the band when the band could be utilized now, as is. GeoLinks asserts that P2MP technology can be utilized in the band almost immediately without interfering with existing users and without requiring existing users to uproot their existing systems and infrastructure.
Contrary to claims made by some commenters, sharing IS possible in the 3.7-4.2 GHz band. While CTIA, for example, is correct that it is not possible for existing users of the band to share with mobile broadband providers, this does not apply to fixed broadband providers.
As explained in its opening comments, GeoLinks (as well as other fixed wireless broadband providers) can coordinate its use of a frequency around any fixed point that may be necessary (i.e. an FSS earth station). Unlike mobile wireless, fixed wireless technology uses directional antennas and fixed transmission points that travel in a designated path. Between those connection points, fiber optic technology is used. This is demonstrated in the figure below.
FIGURE 1: GeoLinks ClearFiber™ Distribution
Compare this figure to that provided in NCTA’s comments, showing directional transmission connections between satellites and fixed, terrestrial points. So long as the transmission path between towers and receiving equipment is engineered to avoid overlap with another signal utilizing the same spectrum, interference can be avoided. With respect to the 3.7-4.2 GHz band, if the locations of FSS earth stations and their transmission paths are known, this can be accomplished.
To that end, if an FSS earth station is properly registered and identified within the band, it can be protected from interference – and should be. However, as SIA notes, up to 90% of earth stations are unregistered. GeoLinks agrees with Google that “unregistered or incorrectly registered earth stations should not be entitled to interference protections.” This includes FSS stations that do not timely file their registrations with the FCC. GeoLinks commends the Commission on its efforts to update its FSS earth station database and believes this is an important first step to better utilization of the band.
GeoLinks reiterates that any spectrum license should carry with it the requirement to serve the public interest – including for shared or light licensed spectrum. Any additional use of the 3.7-4.2 GHz band should be subject to strict buildout and service requirements to help promote broadband deployment in rural areas. These requirements will alleviate the risk of spectrum warehousing and encourage rapid deployment of high-speed broadband by band users.
In conclusion, GeoLinks urges the Commission to open an NPRM in this proceeding to consider the feasibility of and create rules for commercial wireless services under a shared, light licensed regime with robust build out requirements.
/s/ Skyler Ditchfield, Chief Executive Officer
/s/ Melissa Slawson, General Counsel/ V.P of Government Affairs and Education
June 15, 2018
No entrepreneur is an island — every day, business owners rely on the help of suppliers, accountants, attorneys, marketers and other service providers to keep their operations running smoothly.
1. Look For Well-Known Past Clients
I would advise any business owner looking for a local vendor they can trust to simply do their research. Begin by conducting a Google search for firms that have done work for major businesses in the past. An example would be noticing if a law firm has worked with brands such as Facebook or Snapchat in the past. Once you confirm that, you then get enough credibility to move forward with them. – Toyosi Azeez, Swiftdine
2. Check Online Review Sites Like Yelp
3. Ask For Referrals
Every company is going to present a sales pitch either in person or their website about why they are the best. Therefore, my advice is to always go off of referrals. Once you collect referrals from the people you know and trust, then really do your own due diligence and make some phone calls to find out what it’s really like to work with them. – Skyler Ditchfield, GeoLinks
I’ve attended conference events and made good use of digital resources. I’ve met people who became trusted partners who do work I don’t do, such as build and manage websites and connect to the podcasting community. I’ve used LinkedIn to find my bookkeeper and I’ve used Reddit to find my first full-time employee. Facebook groups are also good resources. – Robert Brill, Brill Media Company
Trust with a vendor is built through communication and time — this is how you see if a vendor is reliable, has good communication skills, is a good problem-solver and is consistent. Though reputation goes a long way, time is really key here. The joy of local vendors is that they are people and can become part of your extended family and stay the course with you through thick and thin. – Jennifer Piette, Out of the Box Collective
For Immediate Release:
June 6, 2018
Communications Manager, SHLB Coalition
Washington, DC (June 6, 2018) – The Federal Communications Commission (FCC) Chairman Ajit Pai circulated today a draft order to raise the cap of the Rural Health Care (RHC) program from $400 million to $571 million to reflect inflation over the past twenty years. The Schools, Health & Libraries Broadband (SHLB) Coalition, a broad-based membership organization that includes health providers and telehealth networks, has been advocating for RHC funding and reform since December of 2015 and commends the Chairman’s announcement in favor of more funding.
The following statement can be attributed to John Windhausen, Jr., Executive Director of SHLB:
“The SHLB Coalition is extremely pleased with Chairman Pai’s intention to increase funding for the Rural Health Care program. This increase is long overdue, as the $400 M cap on the RHC program has remained set in stone for over twenty years. This proposal also addresses our concerns about the retroactive funding reductions for FY 2017 by ensuring that applicants in the current funding year can be fully reimbursed. This action will avoid the unfortunate 15% to 25% reductions that had been announced for the current funding year. While we have not seen the entire proposal, we are encouraged that Chairman Pai has taken our concerns to heart and is responding to the SHLB Coalition’s Emergency Waiver Petition and the request by 31 US Senators – led by Senators Heitkamp and Hoeven – for more funding for the program.”
The FCC launched a proceeding to reform the RHC program in December of 2017. In our comments filed with the FCC, the SHLB Coalition estimated that the number of eligible entities has more than doubled since the $400 million cap was set in 1997 and asked for the cap to be raised to $800 M to account for future demand. The SHLB Coalition also filed an Emergency Waiver Petition earlier this year asking the FCC to fully fund applicants for FY2017 and to avoid the retroactive rate increases on services provided as of July 1, 2017. SHLB has pointed out that the $400 M cap does not reflect the enormous changes in the rural health care marketplace, including the closure of scores of rural hospitals, the improvements in telemedicine, the growth of electronic medical records, the doubling of eligible health care providers, and the rural broadband gap.
The SHLB Coalition previously filed comments and reply comments in the FCC’s WC Docket No. 17-310 with the following four main recommendations to reform the Universal Service Fund program: 1) Increase the cap to $800 million to meet the current demand; 2) Encourage the formation of consortia in the Healthcare Connect Fund; 3) Establish funding tiers to ensure funds are distributed to the most rural areas; and 4) Improve administrative efficiency, transparency, and protection against waste, fraud, and abuse. Visit http://www.shlb.org/policy/Rural-Health-Care to learn more about SHLB’s advocacy to improve our nation’s telehealth.
Forbes.com – POST WRITTEN BY Skyler Ditchfield | CEO of GeoLinks, the Fastest Growing WISP in America named 2018 “Most Disruptive Technology” for its ClearFiber™ Network.
Any successful entrepreneur has been asked the following question probably more times than they can count: “How did you become successful?” Sometimes the answer is as simple as luck, other times it was the birth of a great idea. What I have found, however, is that the foundation of success starts with having a strong, positive mindset and the will to work. I’ve gone from modest beginnings to running one of the nation’s fastest-growing companies, and I can attribute this success to exercising the following seven routines on a daily basis.
Reframe your mindset daily — keyword, daily.
What you believe becomes reality. We may hear this all the time, but it’s actually true. Do not complain. Complaints are not productive — they leave us dwelling on what is wrong. If you find yourself habitually complaining, reframe and train your mind to work towards possible solutions to those complaints. Then, implement them. Do not wallow. Avoid others that complain or suck you into their pessimism — it is contagious, infectious and will only drag you down.
Create a small list of attainable goals every morning.
If you’ve heard this before, it’s because it works. Write small tasks down on paper, and physically cross them off as you complete each task. This gives you both a feeling of satisfaction and tracks your progress, which is very helpful in keeping yourself mentally engaged.
Allow yourself the luxury of rescheduling.
While this may seem easy, we all do it far too often. In fact, I find myself doing it almost every day. If you can’t get to a certain task or simply don’t have the mental stamina for it, accomplish a smaller or easier item on your list so you can keep your momentum moving forward. Allow yourself to reschedule bigger action items if necessary.
I often feel mentally overwhelmed by my tasks and get stuck dwelling on how much I have to do. I’ve learned it’s critical to take time to organize my list of work, daily and assign priorities. Also, realize that it’s OK to delegate or skip low-priority tasks if you are too pressed for time. After I’ve taken the time to actually organize my to-do list, it is typically smaller than I was initially making it out to be, enabling me to feel much more focused and capable of creating a plan of attack.
Don’t skip your workouts.
This is one that after 20 years I continue to struggle with. A good workout always gives me more energy and a refreshed mind, ultimately encouraging me to dive into tasks I’ve been procrastinating on. It also gives me a renewed amount of self-confidence and strength — a strong body equals a strong mind.
Have an idea that is risky? Find yourself consistently contemplating doing something? Are others warning you of potential negative outcomes? Remember this: only you can make a choice for yourself. I can live with any mistake that I make. What I can’t live with, however, is the mistake of taking the advice of someone else that ends up being wrong. I’ve found that every time I’ve followed someone else’s advice against my own gut, I’ve ended up regretting it. Thus, before making daily decisions, check in with your gut and follow it.
Finally, even if you follow these fundamental daily routines, know this: You will have setbacks. You will have failures. In fact, you will have more of both than you ever anticipated. Successful individuals often lose more than they win — the difference is they keep getting up and trying again. While this seems so simple, so many people succumb to defeat. Take your losses as lessons and learn from them. They are great teachers and character builders. After a defeat, you grow stronger, and it will take much more to knock you down again.