Archive for month: June, 2020

GeoLinks Ex Parte – 06.01.2020

June 1, 2020

 

VIA ELECTRONIC DELIVERY

Marlene H. Dortch, Secretary

Federal Communications Commission

445 12th Street, SW

Room TW-A325

Washington, DC 20554

 

Re:

Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction, AU Docket No. 20-34

Rural Digital Opportunity Fund, WC Docket No. 19-126

Connect America Fund, WC Docket No. 10-90

 

Dear Ms. Dortch:

On May 29, 2020, GeoLinks CEO Skyler Ditchfield, President and COO Ryan Adams and General Counsel and V.P. of Government Affairs and Education Melissa Slawson attended a telephone call Chairman Ajit Pai and Advisor Preston Wise.

During this call, GeoLinks expressed the importance of the Rural Digital Opportunity Fund (“RDOF”) auction and discussed the Company’s concerns regarding certain of the proposed rules set forth in the Draft Procedures Public Notice that, in the Company’s opinion, could lead to failures to perform or defaults if service providers are not adequately vetted.[1]  Specifically, GeoLinks expressed concern regarding allowing service providers with no operational history of providing Gigabit speeds to bid at the Gigabit Tier in the auction.  GeoLinks explained that while some companies, like GeoLinks, have been successful at offering and delivering Gigabit+ speeds to customers throughout their service territory, this is the result of stringent equipment vetting and detailed network design, particularly in rural and remote areas.

As GeoLinks explained, without real-world operating experience providing Gigabit services to customers, GeoLinks is concerned that some companies may rely blindly on manufacturers’ specifications and data sheets when designing a proposed RDOF network plan (and when developing an RDOF bidding strategy).  The possible result is companies defaulting on their RDOF obligations when RDOF funds end up not being sufficient to properly engineer and deploy the network necessary to offer Gigabit services.

GeoLinks explained that specific performance of individual equipment types is dependent on many factors including available spectrum, weather, topography, topology, the number of customers being served, oxygen absorption and, most importantly, engineering.  GeoLinks emphasized that it is prepared for scenarios that can affect throughput and has extensive, successful experience engineering a Gigabit+ network across numerous types of terrain (spanning some of California’s most challenging topographies and topologies) utilizing various equipment types and accounting for potential equipment shortfalls.  GeoLinks has also worked to develop relationships with equipment manufacturers to develop proprietary equipment offerings that offer higher throughputs and reduce the effects of various environmental conditions.  However, GeoLinks fears that this is likely not the case for inexperienced providers hoping to provide Gigabit+ speeds to unserved rural areas.

To avoid network operators without experience offering Gigabit services from potentially “biting off more than they can chew” during the Auction, GeoLinks proposed that the Commission return to its original proposal to prohibit certain service providers who have not previously offered Gigabit services to customers (and have not reported doing so via their Form 477s) from being able to bid the Gigabit Tier during RDOF.  In the alternative, GeoLinks strongly urged the Commission to ensure that the short-form vetting process is rigorous and relies on more than equipment manufacturers’ claims.

During the call, GeoLinks shared the question it received during its call with from the Rural Broadband Auction Task Force (“RBATF”) staff on May 27, 2020 regarding certain manufacturers’ claims that equipment may support Gigabit speeds under certain conditions.[2]  Specifically, RBATF staff asked GeoLinks to comment on the information set forth in Footnote 238 of the Public Notice.  GeoLinks explained to Chairman Pai and Mr. Wise that while the claims made regarding throughput are technically attainable, in GeoLinks’ experience, real world throughput, even in a very clean environment, never comes close to as-advertised over-the-air (“OTA”) link rates.  In fact, GeoLinks finds that, in general, the equipment it procures obtains about 1/3 to 1/2 the capacity of the manufacturer’s OTA rate in real world deployments with a 10% reduction for each additional client added.  It is simply not realistic to expect full modulation on every link, especially with point-to-multipoint (“P2MP”) deployments or as additional customer connections are added to the same equipment.

GeoLinks shared the following information with Chairman Pai and Mr. Wise regarding the claims cited in Footnote 238 of the Public Notice:

 

Cambium:

According to the specifications sheet GeoLinks was able to locate, the equipment referenced in Footnote 238 does not have a sector capacity of 1.6 Gbps but instead 1.2 Gbps.[3]  While GeoLinks is unclear whether this is a typo or outdated information, this is sector capacity and not applicable to end user speed.  To fully understand the capabilities of the Cambium cnMedusa (“450m”), one must look at the manufacturers’ specifications more closely.  Cambium states that the 450m has a maximum data rate of 172 Mbps, and can utilize Multi User Multiple in Multiple Out (“MU-MIMO”) to stream data to up to seven client radios simultaneously for a total sector capacity of 1200 Mbps (172mbps x 7 clients).  This means the maximum capacity per client is limited to 172mbps aggregate in perfect conditions.  However, not all connected clients will meet “perfect conditions.”

 

Siklu:

According to Siklu’s specifications sheet for its MultiHaul P2MP product,  maximum data rates, as advertised, are 2300 Mbps OTA and 1000 Mbps aggregate with a footnote stating that “actual throughput varies with traffic patterns.”[4]  An aggregate throughput of 1000 Mbps is not sufficient to meet the Commission’s 1000 Mbps/ 500 Mbps service tier.

 

IgniteNet:

In its Ex Parte filing from May 15, 2020, the Wireless Internet Service Providers Association (“WISPA”) states that JAB Wireless, Inc. is using equipment manufactured by IgniteNet that operates in the 57-71GHZ bands.[5]  GeoLinks has extensive experience working with IgniteNet and its executive team.  Specifically, the Company worked with IgniteNet for over 3 years trying to get spectrum utilization in the upper 60 GHz and lower 70 GHz bands.  In GeoLinks’ experience, and based on their own documentation, their equipment only supports use to 65 GHz, thus vastly limiting the broadcast distance.[6]  While IgniteNet claims 2.4 Gbps of sector capacity,[7] its use of an 802.11ac based chipset makes it subject to differential in its OTA and TCP/IP throughput rates. In GeoLinks own internal testing, IgniteNet devices obtained a capacity of about 1/3 the layer 1 OTA link rate.  The best GeoLinks was able to achieve was approximately 650 Mbps aggregate.

 

Ericsson:

In GeoLinks’ experience, Ericsson’s data rates of 4.3 Gbps in a single one-way session is accurate with 800mhz of available spectrum.  However, to the best of GeoLinks’ knowledge, Ericsson does not make this equipment commercially available today.  Moreover, Footnote 238 notes that the speeds cited were achieved in a trial – not a real-world deployment scenario.

 

Starry:

As noted in Footnote 238, Starry’s equipment uses an 802.11ac chipset.  As discussed in detail below, 802.11ac chipsets only achieve actual end user speeds of about 1/3 of their OTA link rate capacity.  Therefore, GeoLinks estimates actual capacity at a full 160 MHz channel is closer 566 Mbps. Thus, the claim of 6.9 Gpbs of sector capacity, while technically accurate, is not relevant to end user speed.

 

As exemplified by the above, there is a distinct difference between what certain equipment manufacturers claim to be capable of (and may be in laboratory-type settings) vs. what they are more likely capably of in real-world settings.  GeoLinks asserts that the above information shows clearly why the Commission cannot rely on information provided by service providers wishing to bid the Gigabit tier what simply parrot the information provided from the manufacturer(s) whose equipment they plan to utilize, and which is also not applicable to end user speed (as discussed below).  Instead, as emphasized during the call, if the Commission is to allow service providers with no experience providing Gigabit services to bid in the Gigabit tier, it must hold them to strict scrutiny regarding their network engineering plans.

During the call, Mr. Wise asked GeoLinks what information the Company suggested the Commission look to when undertaking its short-form review process to ensure it is robust.  Similar to GeoLinks’ response to the same question posed by RBATF staff, GeoLinks emphasized the need for strong vetting procedures.  In furtherance of the information offered during the call with Chairman Pai and Mr. Wise, GeoLinks asserts that the Commission consider the claimed capacities of client premises equipment (“CPEs”) offered by various equipment manufacturers in addition to actual aggregate TCP/IP capacity.  Notably, CPE capacity is not discussed in Footnote 238, however GeoLinks believes that information regarding the speeds that can be supported by various manufacturers’ CPEs is a vital component to determining whether Gigabit+ services can be supported by a proposed network engineering plan.

GeoLinks asserts that client radio capacity needs to be a minimum of 1000 Mbps/ 500 Mbps true TCP/IP throughput in order to effectively ensure delivery of Gigabit service speeds.  This is how all standardized and Commission testing is done.  However, as discussed above, many manufacturers, such as Starry, utilize 802.11ac Chipsets.  With adequate spectrum (160 MHz), 802.11ac chipsets are capable of OTA link rates of up to 1700 Mbps per client radio (layer 1 OTA rate) and can utilize MU-MIMO to stream data to up to four client radios simultaneously for a total sector capacity of 6800 Mbps. (1700 Mbps to each of four clients).  However, this doesn’t mean a sector has 6800 Mbps of TCP/IP throughput (actual customer throughput) nor does the 1700 Mbps OTA rate translate to a TCP/IP capacity of 1700 Mbps.  These are layer 1 OTA link rates and are typically used for marketing and are not applicable for TCP/IP throughput.  In GeoLinks’ experience, in real-world observed applications, 802.11ac-based devices typically have a layer 2 (customer) capacity of about 1/3 of their layer 1 OTA link rate.  In other words, the links rates claimed by 802.11ac-based devices do not translate to the speeds an end-user actually receives.[8]  To further corroborate the above, according to support information available on Netgear’s website, “user activities like file transfer and web content browsing happen at the application layer. The rate obtained at the application layer will be much lower than the physical layer rate. In fact, [an OTA] link rate of ‘300 Mbps’ usually corresponds to 50 to 90 Mbps speed on the TCP/UDP layer.”[9] Notably, none of the discussion cited in Footnote 238 mentioned end user capacity.

It is GeoLinks’ strong suggestion, based on the forgoing, that the Commission implement the following to ensure stringent short-form review during the RDOF process.  First, the Commission should only allow for equipment that has a capacity of at least 1500 Mbps aggregate on the client device, so that full 1000 Mbps/500 Mbps data rates can be achieved in all real-world applications.  A higher threshold of 1750 Mbps aggregate to ensure adequate headroom for varying link conditions would be ideal.  Second, the Commission should require all applications to make a showing that throughput capacity of their intended end user equipment meets or exceed the above standards in TCP/IP testing.

Pursuant to Section 1.1206(b) of the Commission’s rules, I am filing this letter electronically in the above referenced dockets.  Please contact me directly with any questions.

 

Sincerely,

 

/s/ Skyler Ditchfield

 

Skyler Ditchfield

Chief Executive Officer

GeoLinks

 

cc:

Chairman Ajit Pai

Preston Wise

 

 

[1] Public Notice, Rural Digital Opportunity Fund Phase I Auction Scheduled for October 29, 2020; Notice and Filing Requirements and Other Procedures for Auction 904, AU Docket No. 20-34 and WC Docket Nos. 19-126 and 10-90, FCC CIRC2006-01 (May 19, 2020) (“Draft Procedures Public Notice”).

[2] Public Notice at para. 103.

[3] Available at: https://cdn.cambiumnetworks.com/wp-content/uploads/2016/06/Spec_PMP_450m_cam-10046_000v016.pdf

[4] Available at: https://www.balticnetworks.com/docs/MultiHaul-Point-to-Multipoint-V2.pdf

[5] Comments of the Wireless Internet Service Providers Association, AU Docket No. 20-34 (filed. March 27, 2020), at 13.

[6]Available at: https://www.ignitenet.com/downloads/datasheets/MetroLinq-2.5G-60-BF-Sector-Datasheet.pdf., citing channel 4.5 support its highest frequency (65 GHz)

[7] See Id.

[8] For instance, assuming good wireless conditions and the 1700 Mbps link rate is achieved, actual TCP/IP capacity will be somewhere around 566 Mbps, not the 1500 Mbps aggregate required for 1000 Mbps/ 500 Mbps levels of service needed for RDOF “Gigabit Tier” service.

[9] https://kb.netgear.com/19668/Link-Rate-and-Transfer-Speed

 

GeoLinks Ex Parte – 05.29.2020

May 29, 2020

 

VIA ELECTRONIC DELIVERY

Marlene H. Dortch, Secretary

Federal Communications Commission

445 12th Street, SW

Room TW-A325

Washington, DC 20554

 

Re:

Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction, AU Docket No. 20-34

Rural Digital Opportunity Fund, WC Docket No. 19-126

Connect America Fund, WC Docket No. 10-90

 

Dear Ms. Dortch:

On May 27, 2020, GeoLinks CEO Skyler Ditchfield, President and COO Ryan Adams and General Counsel and V.P. of Government Affairs and Education Melissa Slawson attended telephone calls with (1) Joseph Calascione, Advisor to Commissioner Carr; and (2) members of the Rural Broadband Auctions Task Force (“RBATF”) including Michael Janson, Heidi Lankau, Daniel Habif, Katie King, Jonathan Campbell, Lauren Garry, Alexander Minard, Mark Montano, Margaret Wiener, and Martha Stancill.  On May 28, 2020, Mr. Ditchfield, Mr. Adams, and Ms. Slawson attended a telephone call with Arielle Roth, Advisor to Commission O’Rielly.

During these calls, GeoLinks expressed the importance of the Rural Digital Opportunity Fund (“RDOF”) auction and discussed the Company’s concerns regarding certain of the proposed rules set forth in the Draft Procedures Public Notice that, in the Company’s opinion, could lead to failures to perform or defaults if service providers are not adequately vetted.[1]  Specifically, GeoLinks expressed concern regarding allowing service providers with no operational history of providing Gigabit speeds to bid at the Gigabit Tier in the auction.  GeoLinks explained that while some companies, like GeoLinks, have been successful at offering and delivering Gigabit+ speeds to customers throughout their service territory, this is the result of stringent equipment vetting and detailed network design, particularly in rural and remote areas.

As GeoLinks explained during the meetings, without real-world operating experience providing Gigabit services to customers, GeoLinks is concerned that some companies may rely blindly on manufacturers’ specifications and data sheets when designing a proposed RDOF network plan (and when developing an RDOF bidding strategy).  The possible result is companies defaulting on their RDOF obligations when RDOF funds end up not being sufficient to properly engineer and deploy the network necessary to offer Gigabit services.

GeoLinks explained that specific performance of individual equipment types is dependent on many factors including available spectrum, weather, topography, topology, the number of customers being served, oxygen absorption and, most importantly, engineering.  For example, as explained in response to questions asked by Ms. Roth, in order to provide service at the 1000 Mbps/ 500 Mbps level, a total of 1500 Mbps aggregate throughput is needed.

GeoLinks emphasized that it is prepared for scenarios that can affect throughput and has extensive, successful experience engineering a Gigabit+ network across numerous types of terrain (spanning some of California’s most challenging topographies and topologies) utilizing various equipment types and accounting for potential equipment shortfalls.  GeoLinks has also worked to develop relationships with equipment manufacturers to develop proprietary equipment offerings that offer higher throughputs and reduce the effects of various environmental conditions.  However, GeoLinks fears that this is likely not the case for inexperienced providers hoping to provide Gigabit+ speeds to unserved rural areas.

To avoid network operators without experience offering Gigabit services from potentially “biting off more than they can chew” during the Auction, GeoLinks proposed that the Commission return to its original proposal to prohibit certain service providers who have not previously offered Gigabit services to customers (and have not reported doing so via their Form 477s) from being able to bid the Gigabit Tier during RDOF.  In the alternative, GeoLinks strongly urged the Commission to ensure that the short-form vetting process is rigorous and relies on more than equipment manufacturers’ claims.  In addition, GeoLinks asked the Commission to take whether service providers that have been offering Gigabit service and have been filing the availability of such services via their Form 477s into account during the short-form vetting process.

During the call with RBATF, GeoLinks was asked about certain manufacturers’ claims that equipment may support Gigabit speeds under certain conditions.[2]  Specifically, RBATF staff asked GeoLinks to comment on the information set forth in Footnote 238 of the Public Notice.  GeoLinks explained that while the claims made regarding throughput are technically attainable, in GeoLinks’ experience, real world throughput, even in a very clean environment, never comes close to as-advertised over-the-air (“OTA”) link rates.  In fact, GeoLinks finds that, in general, the equipment it procures obtains about 1/3 to 1/2 the capacity of the manufacturer’s OTA rate in real world deployments with a 10% reduction for each additional client added.  It is simply not realistic to expect full modulation on every link, especially with point-to-multipoint (“P2MP”) deployments or as additional customer connections are added to the same equipment.

In furtherance of GeoLinks’ response to RBATF’s question, GeoLinks provides the following information to provide guidance to the Commission regarding the claims cited in Footnote 238 of the Public Notice:

 

Cambium:

According to the specifications sheet GeoLinks was able to locate, the equipment referenced in Footnote 238 does not have a sector capacity of 1.6 Gbps but instead 1.2 Gbps.[3]  While GeoLinks is unclear whether this is a typo or outdated information, this is sector capacity and not applicable to end user speed.  To fully understand the capabilities of the Cambium cnMedusa (“450m”), one must look at the manufacturers’ specifications more closely.  Cambium states that the 450m has a maximum data rate of 172 Mbps, and can utilize Multi User Multiple in Multiple Out (“MU-MIMO”) to stream data to up to seven client radios simultaneously for a total sector capacity of 1200 Mbps (172mbps x 7 clients).  This means the maximum capacity per client is limited to 172mbps aggregate in perfect conditions.  However, not all connected clients will meet “perfect conditions.”

 

Siklu:

According to Siklu’s specifications sheet for its MultiHaul P2MP product,  maximum data rates, as advertised, are 2300 Mbps OTA and 1000 Mbps aggregate with a footnote stating that “actual throughput varies with traffic patterns.”[4]  An aggregate throughput of 1000 Mbps is not sufficient to meet the Commission’s 1000 Mbps/ 500 Mbps service tier.

 

IgniteNet:

In its Ex Parte filing from May 15, 2020, the Wireless Internet Service Providers Association (“WISPA”) states that JAB Wireless, Inc. is using equipment manufactured by IgniteNet that operates in the 57-71GHZ bands.[5]  GeoLinks has extensive experience working with IgniteNet and its executive team.  Specifically, the Company worked with IgniteNet for over 3 years trying to get spectrum utilization in the upper 60 GHz and lower 70 GHz bands.  In GeoLinks’ experience, and based on their own documentation, their equipment only supports use to 65 GHz, thus vastly limiting the broadcast distance.[6]  While IgniteNet claims 2.4 Gbps of sector capacity,[7] its use of an 802.11ac based chipset makes it subject to differential in its OTA and TCP/IP throughput rates. In GeoLinks own internal testing, IgniteNet devices obtained a capacity of about 1/3 the layer 1 OTA link rate.  The best GeoLinks was able to achieve was approximately 650 Mbps aggregate.

 

Ericsson:

In GeoLinks’ experience, Ericsson’s data rates of 4.3 Gbps in a single one-way session is accurate with 800mhz of available spectrum.  However, to the best of GeoLinks’ knowledge, Ericsson does not make this equipment commercially available today.  Moreover, Footnote 238 notes that the speeds cited were achieved in a trial – not a real-world deployment scenario.

 

Starry:

As noted in Footnote 238, Starry’s equipment uses an 802.11ac chipset.  As discussed in detail below, 802.11ac chipsets only achieve actual end user speeds of about 1/3 of their OTA link rate capacity.  Therefore, GeoLinks estimates actual capacity at a full 160 MHz channel is closer 566 Mbps. Thus, the claim of 6.9 Gpbs of sector capacity, while technically accurate, is not relevant to end user speed.

 

As exemplified by the above, there is a distinct difference between what certain equipment manufacturers claim to be capable of (and may be in laboratory-type settings) vs. what they are more likely capably of in real-world settings.  GeoLinks asserts that the above information shows clearly why the Commission cannot rely on information provided by service providers wishing to bid the Gigabit tier what simply parrot the information provided from the manufacturer(s) whose equipment they plan to utilize, and which is also not applicable to end user speed (as discussed below).  Instead, as emphasized during the calls, if the Commission is to allow service providers with no experience providing Gigabit services to bid in the Gigabit tier, it must hold them to strict scrutiny regarding their network engineering plans.

During the call with RBATF, GeoLinks was asked what information the Company suggested the Commission look to when undertaking its short-form review process to ensure it is robust.  GeoLinks emphasized the need for strong vetting procedures.  In furtherance of the information offered during that call, GeoLinks asserts that the Commission consider the claimed capacities of client premises equipment (“CPEs”) offered by various equipment manufacturers in addition to actual aggregate TCP/IP capacity.  Notably, CPE capacity is not discussed in Footnote 238, however GeoLinks believes that information regarding the speeds that can be supported by various manufacturers’ CPEs is a vital component to determining whether Gigabit+ services can be supported by a proposed network engineering plan.

GeoLinks asserts that client radio capacity needs to be a minimum of 1000 Mbps/ 500 Mbps true TCP/IP throughput in order to effectively ensure delivery of Gigabit service speeds.  This is how all standardized and Commission testing is done.  However, as discussed above, many manufacturers, such as Starry, utilize 802.11ac Chipsets.  With adequate spectrum (160 MHz), 802.11ac chipsets are capable of OTA link rates of up to 1700 Mbps per client radio (layer 1 OTA rate) and can utilize MU-MIMO to stream data to up to four client radios simultaneously for a total sector capacity of 6800 Mbps. (1700 Mbps to each of four clients).  However, this doesn’t mean a sector has 6800 Mbps of TCP/IP throughput (actual customer throughput) nor does the 1700 Mbps OTA rate translate to a TCP/IP capacity of 1700 Mbps.  These are layer 1 OTA link rates and are typically used for marketing and are not applicable for TCP/IP throughput.  In GeoLinks’ experience, in real-world observed applications, 802.11ac-based devices typically have a layer 2 (customer) capacity of about 1/3 of their layer 1 OTA link rate.  In other words, the links rates claimed by 802.11ac-based devices do not translate to the speeds an end-user actually receives.[8]  To further corroborate the above, according to support information available on Netgear’s website, “user activities like file transfer and web content browsing happen at the application layer. The rate obtained at the application layer will be much lower than the physical layer rate. In fact, [an OTA] link rate of ‘300 Mbps’ usually corresponds to 50 to 90 Mbps speed on the TCP/UDP layer.”[9] Notably, none of the discussion cited in Footnote 238 mentioned end user capacity.

It is GeoLinks’ strong suggestion, based on the forgoing, that the Commission implement the following to ensure stringent short-form review during the RDOF process.  First, the Commission should only allow for equipment that has a capacity of at least 1500 Mbps aggregate on the client device, so that full 1000 Mbps/500 Mbps data rates can be achieved in all real-world applications.  A higher threshold of 1750 Mbps aggregate to ensure adequate headroom for varying link conditions would be ideal.  Second, the Commission should require all applications to make a showing that throughput capacity of their intended end user equipment meets or exceed the above standards in TCP/IP testing.

In addition to the above, during the call with Mr. Calascione, GeoLinks emphasized that RDOF should not limit participation by fixed wireless providers to only those services that utilize licensed spectrum.  The Company explained that while licensed spectrum has advantages over unlicensed, fixed wireless providers (including numerous Connect America Fund Phase II auction winners like GeoLinks) are successfully using unlicensed spectrum to provide high-speed, high-quality broadband services customers.  The Commission should not preclude the use of unlicensed spectrum in RDOF.

During the call with Ms. Roth, GeoLinks discussed the Commission’s RDOF challenge process. While GeoLinks did not submit a challenge to the Commission’s proposed locations, the Company explained that it supports the filings by the Wireless Internet Service Providers Association (“WISPA”) in response to certain filings by Charter Communications, Inc. and Frontier Communications Corporation and emphasized the need to scrutinize broad sweeping challenges submitted by some larger service providers.[10]

Pursuant to Section 1.1206(b) of the Commission’s rules, I am filing this letter electronically in the above referenced dockets.  Please contact me directly with any questions.

 

Sincerely,

 

/s/ Skyler Ditchfield

 

Skyler Ditchfield

Chief Executive Officer

GeoLinks

 

cc:

Arielle Roth

Joseph Calascione

Michael Janson

Heidi Lankau

Daniel Habif

Katie King

Jonathan Campbell

Lauren Garry

Alexander Minard

Mark Montano

Margaret Wiener

Martha Stancill

 

 

[1] Public Notice, Rural Digital Opportunity Fund Phase I Auction Scheduled for October 29, 2020; Notice and Filing Requirements and Other Procedures for Auction 904, AU Docket No. 20-34 and WC Docket Nos. 19-126 and 10-90, FCC CIRC2006-01 (May 19, 2020) (“Draft Procedures Public Notice”).

[2] Public Notice at para. 103.

[3] Available at: https://cdn.cambiumnetworks.com/wp-content/uploads/2016/06/Spec_PMP_450m_cam-10046_000v016.pdf

[4] Available at: https://www.balticnetworks.com/docs/MultiHaul-Point-to-Multipoint-V2.pdf

[5] Comments of the Wireless Internet Service Providers Association, AU Docket No. 20-34 (filed. March 27, 2020), at 13.

[6]Available at: https://www.ignitenet.com/downloads/datasheets/MetroLinq-2.5G-60-BF-Sector-Datasheet.pdf., citing channel 4.5 support its highest frequency (65 GHz)

[7] See Id.

[8] For instance, assuming good wireless conditions and the 1700 Mbps link rate is achieved, actual TCP/IP capacity will be somewhere around 566 Mbps, not the 1500 Mbps aggregate required for 1000 Mbps/ 500 Mbps levels of service needed for RDOF “Gigabit Tier” service.

[9] https://kb.netgear.com/19668/Link-Rate-and-Transfer-Speed

 

[10] See Comments of The Wireless Internet Service Providers Association and Reply Comments of The Wireless Internet Service Providers Association, WC Docket No. 19-126 (filed April 21, 2020 and April 28, 2020, respectively); see also Request for Expedited Commission Inquiry Under Section 403, WC Docket No. 19-126 (filed April 27, 2020).

GeoLinks Ex Parte – 12.03.2019

December 4, 2019

 

VIA ELECTRONIC DELIVERY

 

Marlene H. Dortch, Secretary

Federal Communications Commission

445 12th Street, SW

Room TW-A325

Washington, DC 20554

 

Re:     

 

Rural Digital Opportunity Fund, WC Docket No. 19-126;

Connect America Fund, WC Docket No. 10-90

 

Dear Ms. Dortch:

On December 3, 2019, Melissa Slawson, General Counsel and V.P. of Government Affairs and Education for California Internet, L.P. dba GeoLinks (“GeoLinks”), and Elizabeth Bowles, President and CEO for Aristotle Unified Communications, LLC (“Aristotle”) met with Nicholas Degani, Senior Counsel for Chairman Pai.

During this meeting, GeoLinks and Aristotle provided details about the companies’ recent Connect America Fund Phase II Auction (“CAF”) awards.  The companies provided information regarding their personal experiences with the CAF Letter of Credit requirement, the high costs associated with securing Letters of Credit, the financial constraints Letters of Credit can impose on smaller companies, and their concerns regarding the Commission’s proposal to require a Letter of Credit requirement for the forthcoming Rural Digital Opportunity Fund Auction (“RDOF”).  Specifically, the companies explained how imposing a Letter of Credit requirement under RDOF will result in grant dollars that could be used for broadband network infrastructure instead being used for bank fees and other costs associated with obtaining and maintaining Letters of Credit.

The companies also offered information regarding adopting a performance bond requirement in lieu of a Letter of Credit requirement.  The companies explained that performance bonds carry significantly lower costs than Letters of Credit while still serving to protect the Commission’s investment into the RDOF.

Pursuant to Section 1.1206(b) of the Commission’s rules, I am filing this letter electronically in the above referenced dockets.  Please contact me directly with any questions.

 

Sincerely,

 

/s/ Melissa Slawson

 

Melissa Slawson

General Counsel and V.P. of Government Affairs and Education

GeoLinks

 

cc: Nicholas Degani

Get to Know GeoLinks Business Sales Consultant, Jacques Lee

1. Let’s start with something simple, what’s your role at GeoLinks?

I am a business sales consultant. I generate and close new business. I also educate clients on the solutions we provide.

2. What’s your favorite part about working for GeoLinks?

My favorite part is the camaraderie and the inviting, welcoming vibe we have here. The environment makes me want to come to work every day. Everybody has fun, it feels like home. Feels like I’ve known these people forever.

3. What was the most interesting job you had before working at GeoLinks? 

I worked for MTV in their production department as a production assistant and eventually a production coordinator. I’d scout locations, contact talent, set up for production. It was a pretty fun, exciting, sometimes wild job.

4. What makes GeoLinks’ ClearFiber™ network different from other fixed wireless networks?

Simply put, we’re the best. It’s our customer service. We’re always available to help you. It’s also a dynamic network. We’re constantly evolving and engineering innovative solutions for businesses.

5. Outside of work, what is your favorite past time or hobby?

Hanging out with my kids. I help my youngest son with his sports. I’m a pretty family oriented person so I keep it close to home.

6. What’s something most of your coworkers don’t know about you?

I would say most of them don’t know that I’m an avid snowboarder.

7. What does an average day as a GeoLinks Sales Consultant look like?

We’re always prospecting for new business. I’m following up with potential clients, learning about their business so that I can figure out how I can customize the best solutions for them. At the same time, I’m calling on new opportunities and building new relationships, building our client network.

8. You are allowed to do anything you want, anywhere in the world, for one whole day…what do you do, and where do you go?

I would go to the Giza pyramids with my sons. I just want to feel the energy of that region.

9. Do you have a favorite quote or mantra you live by? Please share!

Mine is a Bible Verse. Matthew 6: 14-15

For if you forgive men their trespasses, your heavenly Father will also forgive you. But if you don’t forgive men their trespasses, neither will your Father forgive your trespasses.

That changed my life.

10. What’s next…what are you most excited for when you think of your future with GeoLinks?

Scalability. The company is growing in the right direction. There are a ton of great opportunities that come with that. As we grow, I want to continue to grow along with the company and continue to be a valuable asset for our customers and for GeoLinks.

GeoLinks Welcomes Technology Veteran Randy Chapman as New Sales Director for Direct, Channel and Wholesale Sales

Networking Expert to Lead Consultative Sales of GeoLinks’ Dedicated Internet, SD-WAN, Hosted Voice, IoT and Cloud Connectivity Services

June 15, 2020 1:30 PM Eastern Daylight Time

CAMARILLO, Calif.–As GeoLinks continues its strong growth trend, the company is pleased to welcome telecommunications industry veteran Randy Chapman as its Director of Sales. With nearly 15 years of experience in the technology sales sector, Chapman will oversee day-to-day and long-term sales strategy for all of the company’s business sales channels, including direct, channel and wholesale.

“In the midst of our rapid growth, this was really the prefect time to bring Randy onto our team,” said GeoLinks Chief Strategy Officer Phillip Deneef. “The experience and knowledge he brings to the table will allow us to execute on our short-term goals to accelerate sales to businesses, while continuing to plan for what we expect to be an extended period of expansion.”

Chapman brings an extensive background in channel sales. His successful tenure as an agent saw him engineer voice, network security, cloud enablement and infrastructure solutions for a broad client base. He also has nearly ten years of experience as a Director of Sales for technology companies in Southern California.

“I’m ecstatic to be joining such a mission-driven team that is on an impressive trajectory of development and progress,” said Chapman. “My experience has taught me to continue pushing during periods of growth while preparing me to consistently evaluate strategy to optimize results.”

Chapman will manage the organization’s sales team, as well as the continued development of partner relationships in the wholesale and master agent channels. To reach him directly, please email [email protected].

About GeoLinks

Headquartered in Southern California, GeoLinks is a leading telecommunications company and competitive local exchange carrier (CLEC) public utility, nationally recognized for its innovative Internet and Digital Voice solutions. Ranked three-years running on Inc. Magazine’s Inc. 5000 Fastest Growing Companies in America, GeoLinks delivers Enterprise-Grade InternetDigital VoiceSD-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 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.

8 Facts to Set the Record Straight About Fixed Wireless Internet

Fixed wireless is one of the most reliable, cost-effective connectivity solutions in the marketplace. Despite a proven track record, many misconceptions persist about fixed wireless service. Some of this confusion stems from the early iterations of fixed wireless, some is the product of Internet rumors and some is based on simple misunderstanding of the different types of wireless connections. In reality, today’s fixed wireless solutions can be game changers for business in terms of cost, reliability, redundancy, speed of deployment and scalability.

To set the record straight, we’ve prepared this quick guide to 8 key facts about fixed wireless Internet services.

 

Fact 1: Fixed Wireless is Not the Same as Satellite

Radio-based fixed wireless broadband connectivity is not the same as satellite-based Internet. There is far less latency with radio-based fixed wireless services and, perhaps more importantly, there’s no throttling that’s common with satellite services. Both are  vitally important at a time when bandwidth-sensitive video content already accounts for more than half of Internet traffic and will account for 80 percent in two years.

 

Fact 2: Fixed Wireless is Just as Reliable as Fiber

A persistent myth dating to the early days of wireless services is that fixed wireless is less reliable than fiber connections. Just as wired connections have moved passed the dialup days of listening to electronic “beeps” and “bongs,” followed by “You’ve got mail!”, wireless technology has undergone quantum leaps forward. A fixed wireless connection running on licensed spectrum is not only as solid as a fiber connection, it’s more reliable, because a jackhammer, backhoe, flood or other disaster (natural or manmade) won’t take it down.

 

Fact 3: Fixed Wireless is Not Only a Rural Solution

While it’s true that fixed wireless makes an excellent rural broadband solution, fixed wireless is a fast and reliable solution in city environments as well. And, it’s more affordable to boot.

 

Fact 4: Fixed Wireless Can Be Installed Rapidly
Due to the glacial installation speeds of bringing wireline broadband connections to new buildings and locations, there is sometimes a misperception that fixed wireless deployment is equally slow to install. In reality, fixed wireless connections can be turned up in days, not months. In fact, many businesses order fixed wireless connectivity as a stopgap while they wait for fiber installations and then find that they don’t need the fiber installation at all.

 

Fact 5: Fixed Wireless Radio Technology is Safe

Fixed wireless connectivity sometimes gets lumped in with Internet conspiracy theories about the supposed (but also mythical) dangers of wireless radiation from mobile phones, Wi-Fi, Bluetooth and other wireless connections. In reality, as you are reading this blog, your body is absorbing up to five times the signal from FM radio and TV stations than you would if you were sitting right next to a wireless base station.

 

Fact 6: Fixed Wireless is Much More Than a Backup Solution

With the world moving to cloud applications, network redundancy and business continuity solutions have become vital to businesses of all sizes. It’s true that, as hurricanes, wildfires and other disruptors have taken down wireline connections, businesses have increasingly turned to fixed wireless solutions for redundancy. But many, once they experience the speed and performance of fixed wireless solutions, turn to fixed wireless for their primary connections as well.

 

Fact 7: Fixed Wireless Is Secure

May people think fixed wireless solutions aren’t secure. This myth could not be further from the truth. Using our own company as a reference point, GeoLinks delivers the same military-grade encryption to business customers that it delivers under government contracts. Your connections are safe, reliable and secure.

 

Fact 8: Fixed Wireless Works in Any Weather

With proper engineering, fixed wireless networks can withstand the elements. GeoLinks’ in-house engineering team begins a deployment by taking into account the terrain, historic weather patterns, rain fade and thermal ducting. Based on that data, the distance between radios and the required bandwidth, they choose the best frequency (or frequencies) and carrier-grade equipment for a weather-proof build. In addition, GeoLink’s adds multiple failover paths as well as a connection to a fiber optic backbone to ensure true network redundancy.

There you have it – just the facts about fixed wireless.

 

Now that you know the facts – Get fixed wireless Internet today!

Contact a GeoLinks ClearFiberTM solutions specialist