Archive for month: March, 2020

GeoLinks Comments on Competitive Bidding Procedures


California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these Comments on the Public Notice, seeking input on proposed pre-auction and bidding processes proposed for Phase I of the upcoming Rural Digital Opportunity (“RDOF”) reverse auction.[1]


GeoLinks is one of the fastest growing Internet and phone providers in America and the #1 fastest growing fixed wireless service provider in California.[2]  While the Company had previously focused on business and enterprise customers, in 2016, GeoLinks began expanding its customer base to include unserved and underserved areas throughout California and beyond.  GeoLinks was the largest construction grant winner for California K-12 schools and libraries in 2016 and 2017, providing highspeed broadband to rural school districts and surrounding communities throughout the state that previously had not had access to any high-speed broadband service.  In 2019, GeoLinks was awarded Connect America Fund Phase II (“CAF”) Auction funding to connect more than 11,000 unserved locations making it the largest CAF winner in California and the fifth largest overall.

GeoLinks largely supports the pre-auction and bidding procedures and processes for the Rural Digital Opportunity Fund (“RDOF”) proposed in the Public Notice and believes they strike the right balance to ensure a fair and successful auction.  However, GeoLinks believes that some of the proposals set forth in the Public Notice risk allowing certain bidders to participate that should either be limited in what tiers they can bid or excluded from the auction all together.  GeoLinks provides these comments to provide input into the Commission’s proposed RDOF pre-auction and bidding processes.


The Commission Should Limit Satellite Providers and Those That Have Never Filed a Form 477 From Bidding Gigabit and Above Baseline Performance Tiers

In the Public Notice, the FCC proposes to limit “geostationary satellite providers from bidding in the Gigabit and Above Baseline performance tiers.”[3]  In doing so, the Commission explains that there is “no evidence that geostationary satellite providers already offer service that meets all the requirements for these performance tiers.”[4]  As the Commission notes, satellite technologies generally cannot achieve speeds of at least 100/20 (noting that the only satellite provider that has reported via its Form 477 that it can offer 100 Mbps of downstream service only bid at the 10/1 and 25/3 speed tiers in the CAF auction).[5]  For this reason, it makes sense to limit these service providers from bidding in the Gigabit and Above Baseline performance tiers because there is no reported basis for believing the technology could achieve Gigabit and Above Baseline speeds.   Therefore, GeoLinks supports this proposed limitation.   In addition, GeoLinks urges the Commission to extend this limitation to low-earth orbit satellite service, as well.  Similar to other satellite providers, to the best of GeoLinks knowledge, there are no Form 477 filings to show that any low-earth orbit satellite operators have successfully offered Gigabit or Above Baseline speeds.  For the same reasons the Commission seeks to limit geostationary satellite providers from bidding the higher speed tiers, GeoLinks asserts that low-earth orbit satellite service should be limited, as well.

Along this vein, GeoLinks urges the Commission to implement one additional limitation in the RDOF auction.  GeoLinks asserts that the Commission should exclude service providers that have never filed a Form 477 from bidding the Gigabit and Above Baseline speed tiers.[6]  Only service providers with a track record for providing broadband service (and for complying with regulatory reporting requirements) understand the rigors associated with designing, deploying, and supporting high-speed broadband networks.  Limiting participation at these tier levels to only providers who have previously filed Form 477s will protect RDOF funding and save Commission resources by weeding out companies that may not be able to meet the rigors of the long form application process before they take part in the auction.

DOF Rules Must Prohibit Service Providers from “Double Dipping”

In addition to the above, the Commission should also be asking whether certain providers should be prohibited for another very important reason – if they have already received some incentive from the Commission to deploy high-speed broadband facilities to serve the areas eligible for RDOF funding (i.e. double dipping).  Specifically, GeoLinks believes that service providers that have received spectrum rights, deployment rights, merger approval, etc. from the Commission contingent upon buildout obligations that overlap with RDOF funding areas should not be eligible for grant funding for those areas.

GeoLinks uses SpaceX as its prime example.  SpaceX has been an active participant in the RDOF proceeding, undoubtedly with the goal of being able to participate in the auction.  However, SpaceX has already received hefty spectrum rights and operating authority from the Commission for extensive satellite deployments that will purportedly result in global broadband deployment.  Because these would presumably be the same satellites that SpaceX would use for any RDOF-related services, allowing SpaceX to participate in RDOF for the same deployment would essentially allow it to “double dip” from the Commission, resulting in wasteful use of limited RDOF funding.

In 2018, the Commission granted SpaceX authorization to “construct, deploy, and operate” its proposed satellite system, “comprising 4,425 satellites for the provision of fixed-satellite service (FSS) around the world” and the rights to do so over certain spectrum within the Ku- and Ka-band frequencies.[7]  In exchange for these rights and authorizations, the Commission mandated that SpaceX meet certain conditions related to, among other things, deployment milestone and geographic coverage requirements.[8]   Specifically, the Commission’s rules require SpaceX to launch and operate “50 percent of the total number of satellites in the constellation” no later than 6 years after grant of the authorization” and “to provide service coverage to (i) all locations as far north as 70 degrees latitude and as far south at 55 degrees latitude for at least 75% of ever 24-hour period and (ii) on a continuous basis through the fifty states, Puerto Rico, and the U.S. Virgin Islands.”[9]

SpaceX has made clear that by utilizing the authorizations and rights already granted by the Commission, it will launch thousands of satellites and “once fully deployed,” will “provide full time coverage to virtually the entire planet.”[10]  Moreover, SpaceX has repeatedly explained to the Commission that it is already actively deploying its satellites.[11]  SpaceX’s commitments were all made without the promise of RDOF funding.  In fact, these commitments were all made before the RDOF auction was even contemplated.[12]  SpaceX should not now be permitted to seek RDOF funding to complete commitments it has already made to the Commission.

GeoLinks urges the Commission to craft its rules in a way that protects RDOF funding from would-be bidders that seek to subsidize broadband infrastructure that they have already made commitments to the Commission to deploy in exchange for something of value (i.e.  operating authority, merger approval, usage rights, etc.).  While GeoLinks does not oppose making RDOF funding available for service providers proposing new projects in RDOF-eligible areas (separate and apart from any previously made commitments), GeoLinks believes that allowing service providers to apply for RDOF funds to complete commitments already made would result in wasteful use of finite universal service support and promote “double dipping.”


GeoLinks largely supports the pre-auction and bidding procedures and processes proposed in the Public Notice.  However, GeoLinks urges the Commission to take steps to protect RDOF funds by limiting satellite providers and those that have never filed a Form 477 from bidding Gigabit and Above Baseline performance tiers and precluding service providers from participating in the auction if they have already received some incentive from the Commission to deploy high-speed broadband facilities to areas eligible for RDOF funding.


Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

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


March 27, 2020


[1] See Public Notice, “Comment Sought on Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction (Auction 904),” AU Docket No. 20-34 and WC Docket Nos. 19-126 & 10-90 (rel. Mar. 2, 2020) (“Public Notice”).

[2] Inc. Magazine’s 37th Annual List of America’s Fastest-Growing Private Companies—the Inc. 5000 (

[3] Public Notice at paras. 49 and 50.

[4] Id. at para 50.

[5] Id.

[6] This includes low-earth orbit satellite providers such as SpaceX, who seek to participate in the RDOF auction.

[7] Memorandum Opinion, Order and Authorization, In the Matter of Space Exploration Holdings, LLC Application for Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System; Application for Approval for Orbital Deployment And Operating Authority for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System Supplement, IBFS File Nos. SAT-LOA-20161115-0018, Call Sign S2983, and SAT-LOA-20170726-00110, Call Sign S3018 (released March 29, 2018) (“SpaceX Order”), at para. 1.

[8] SpaceX Order at paras. 31-33.

[9] Id. at paras. 31 and 33.

[10] SpaceX Order at para. 33.

[11] See SpaceX Notice of Ex Parte Communications, WC Docket No. 19-126, WC Docket No. 10-90 (filed January 20, 2020) stating that “SpaceX is targeting service in the Northern U.S. and Canada in 2020, rapidly expanding to near global coverage of the populated world by 2021.”  See also SpaceX Notice of Ex Parte Communications, WC Docket No. 19-126, WC Docket No. 10-90 (filed February 20, 2020) stating that “SpaceX has already launched over 300 satellites…and has an aggressive launch rate that will ensure full coverage to the entire United States.”

[12] The SpaceX Order was released on March 29, 2018 – 16 months before the Commission released its Notice of Proposed Rulemaking for RDOF.  See generally RDOF Order.

GeoLinks Joins Pledge to Keep Americans Connected

California-based telecommunications provider GeoLinks, has joined the Federal Communications Commission’s pledge to “Keep Americans Connected” during the coronavirus outbreak. The formal joining of the pledge is a vow from the company to ensure that its customers remain connected to vital information infrastructure during these uncertain times.

The Keep Americans Connected Pledge reads as follows:

Given the coronavirus pandemic and its impact on American society, GeoLinks pledges for the next 60 days to:

(1) not terminate service to any residential or small business customers because of their inability to pay their bills due to the disruptions caused by the coronavirus pandemic;

(2) waive any late fees that any residential or small business customers incur because of their economic circumstances related to the coronavirus pandemic; and

(3) open its Wi-Fi hotspots to any American who needs them.

“When my cousin (Chief Technical Officer, Ryan Hauf) and I founded GeoLinks in 2011, it was our mission to improve people’s lives by connecting them to information,” said CEO, Skyler Ditchfield. “We continue to stand behind that mission today and we are dedicated to making sure that our customers remain connected during this challenge.”

GeoLinks is also taking additional steps to ensure that its residential customers have access to enhanced levels of service by increasing speeds for customers who are working remotely due to social distancing guidelines, when possible.

In a news release, FCC Chairman Ajit Pai commended businesses such as GeoLinks for taking these additional steps. “I applaud those companies that have already taken the Keep Americans Connected Pledge” said Chairman Pai. “They are stepping up to the plate and taking critical steps that will make it easier for Americans to stay connected during this pandemic and maintain much-needed social distancing. I urge other companies to join them. This may be a difficult time for our nation, but if we all work together, I am confident that we can rise to the challenge.”

“As leaders in the business community, it is our duty to set the right tone,” concluded Ditchfield. “By showing that we are committed to helping our community, we can show the world how to make it through this difficult time, by working together.”

The Importance of Creating Digital Business Certainty

By: Skyler Ditchfield, GeoLinks CEO

As businesses across the country establish and put in place procedures to ensure business continuity in the face of uncertainties surrounding the spread of coronavirus, including a surge in remote-optional work, limited connectivity looms large over the best-intentioned plans. While your place of business may have its network firing on all cylinders, the likelihood that all of your employees have a similar setup at home is low.

Take for instance the fact that on average, business internet speeds tend to be anywhere from two to five times faster than those of residential connections. Add in the probability that most home connections are sharing access with the rest of their neighborhood and have restricted upload speeds. In the unfortunate circumstances we’re witnessing today, many of those homes are going to have business professionals conducting high-volume work on a network that is not prepared for it. You can now start to sense the feelings of frustration cropping up in home offices across the nation.

The issues presented by the sudden surge in remote work don’t stop at intermittent or inconsistent speeds though. Logistical issues such as accessing desk phone lines and voicemail present real-world problems that are difficult to solve without the proper business solutions in place. When customers and clients are conditioned to reaching your employees one way, it can create delays and missed opportunity when those employees don’t have access to these preferred methods of communication.

With so many businesses choosing to offer remote-optional work, we’re also seeing a significant uptick in the amount of video conferencing taking the place of in-person meetings. With the aforementioned circuit overloads, expect many of these video meetings to be interrupted due to sub-enterprise quality bandwidth.

All of this is not to say that solutions do not exist. Fixed wireless internet alone eliminates much of the uncertainty presented by these issues. With a dedicated signal provided to a single location, concerns of reduced speed, network downtime and service interruption are completely dissipated. With a hosted voice solution, employees have the same access to their desk lines of communications that they would have in the office. An SD-WAN solution provides your network with two traffic routes, allowing for optimized and seamless delivery of unlimited data, including video conferencing.

Even in the face of the existential threat that our world is facing, business owners cannot afford to halt their operations. It is often in times of great change and upheaval that we learn what is necessary to survive. In the case of protecting the health of your business, it might just be time to put solutions in place that create certainty in uncertain times.



Closing An Invisible Barrier

By: Skyler Ditchfield, GeoLinks CEO

As schools across the country are forced to close due to the threat of coronavirus infections, a familiar theme, and one that my company is dedicated to solving comes to mind. I’m referring to the Digital Divide that is ever-present, not always seen by those with high-speed connection, but all-too familiar to those without.

Across the country, mostly in rural markets that do not have the fiber infrastructure often utilized for high-speed broadband, homes, schools, libraries and even hospitals operate with a lower degree of connectivity than their urban neighbors. With the recent outbreak of coronavirus affecting the globe, many schools have had to make the difficult decision to close their doors for indeterminate timeframes.

In some fortunate cases, students are still able to access their learning environments through online class portals. In many other cases, including quite often in rural markets with low connectivity, students are losing out on similar opportunities to learn while their schools remain closed. If a school does offer online learning modules, many of its students do not have the home internet access necessary to interact in these portals, highlighting an aspect of the unfortunate phenomenon known as the “homework gap.”

I have firsthand knowledge of what it’s like living in a rural market with severely limited connectivity. Growing up in rural Ojai, Calif., my family and many like us had limited options when it came to internet connectivity. Situations like this create a very real disadvantage for children. When youths grow up with instant access to a world of information at their fingertips, they understandably don’t fully grasp the advantage that it gives them. When children grow up without that connection, they are very well aware of the roadblocks that the lack of connectivity creates.

My cousin, Ryan Hauf and I started GeoLinks in 2011 with a very simple but profound mission; to connect people to information. As we’ve continued to grow and be recognized as one of the Inc. 5000 Fastest Growing Companies in America, our mission has evolved, but the core premise remains. As a company we are dedicated to closing the digital divide that so many people, especially children, are living with every day.

This is why GeoLinks is a proud member of the Schools, Health and Libraries Broadband Coalition (SHLB), promoting government policies and programs that enable these institutions to obtain open, affordable, high-speed broadband connections to the internet. It’s why we partner with the Corporation for Education Network Initiatives in California (CENIC) to provide schools, libraries and research sites in underserved communities with broadband at 50 to 100 times greater speeds than they previously had access to.

Our commitment to closing the digital divide was a key factor in the Federal Communications Commission’s (FCC) decision to entrust GeoLinks with approximately $88 million to deploy high-speed broadband network facilities to rural areas in California and Nevada over the next ten years. These areas are not unlike the rural Ojai of my childhood, or the underserved communities of today that are forced to endure limited to no connectivity, creating greater disadvantage across the digital divide.

It is our mission to connect these areas to a world of information with fiber-fast connection. It is our hope that even when schools are forced to keep students away from their physical learning environment, they will have the option to connect with them in a digital classroom.