Fighting Fire with Data: Wildfire Detection, Prevention, & Situational Awareness Systems

Fighting Fire with Data: Wildfire Detection, Prevention, & Situational Awareness Systems

The unprecedented scale and scope of recent catastrophic wildfires show that larger swaths of California are at risk than previously understood. Smart investments in strategic technologies may serve to limit the loss of life and property damage. One promising — and proven — line of defense is connecting remote cameras and weather sensors across the state to a vast mesh of wireless and fiber-optic cable to relay data. The collected data is combined and analyzed to produce information that supports wildfire prevention, detection, and management.

This system — ALERTWildfire (University of Nevada, Reno, University of California, San Diego, and the University of Oregon) — is actively collaborating and partnering with local firefighters, GeoLinks, and CENIC. During the 2016-2017 fire seasons, such a system provided critical information for over 350 fires, and in 2018, has assisted in more than 150 fires so far.

Statewide expansion of this proven system would offer strategic advantages for early fire detection, situational awareness for first responders, fire mapping, predictive simulations, and evacuation planning. Rapid investment in this shovel-ready system would soon save lives, property, habitat, and infrastructure across California, and the state would see an almost immediate return on its investment. Additional partners that would benefit from this effort and so might be approached for financial support are the insurance industry, technology accelerators, and local community organizations.

How It Works

ALERTWildfire uses a network of cameras to continuously capture images of high-risk California landscape, while weather sensors on many of the same towers collect data on wind, humidity, fuel moisture, and other factors. The data is passed along via GeoLinks’s fixed wireless microwave technology and then handed off to CENIC’s high-capacity, optical-fiber network that runs throughout California. WIFIRE then analyses the data to create real-time simulations, wildfire path predictions, and visualizations of wildfire behavior and provides these visuals to firefighters to inform evacuation and containment planning. Data visualization is also supported by the California Institute for Telecommunications and Information Technology’s (Calit2) Qualcomm Institute.

For example, early fire detection by ALERTWildfire provides immediate input to burn models that incorporate weather, fuels, and topography. Such a collaboration exists between ALERTWildfire and WIFIRE (San Diego Supercomputer Center) to provide first responders with burn models almost in real time. WIFIRE was launched in October 2013 with a grant from the National Science Foundation and has been advised by representatives from CAL FIRE, US Forest Services, US Bureau of Land Management, National Institute of Standards and Technology, and Los Angeles Fire Department. WIFIRE’s “Firemap” software rapidly and accurately predicts and visualizes wildfire rates of spread. In late 2017, over 800,000 public users accessed information with the Firemap tool over 8 million times. Since grant funding ended this year, WIFIRE is operating under an annual subscription model for the fire departments of Los Angeles, Orange, and Ventura Counties.

What Is Needed Now

While these efforts have prevented significant loss of life and property during recent California wildfires, this fire monitoring network is geographically limited in its current deployment. Now is the time to expand the use of this proven system across the state while systematically integrating it with local networks. Some possible next steps:

  • Include language allowing for data, communications, and broadband strategies to support wildfire data applications in future legislation;
  • Extend towers, cameras, and fixed wireless capacity throughout the state to provide first responders with powerful, contemporary tools;
  • Where wireless towers exist on state property, work with ALERTWildfire to support the installation of cameras and other equipment to expand coverage;
  • Explore opportunities to coordinate this system with FirstNet to augment the reach of this national first-responder network.

In light of the devastating effects of wildfires on California, scaling this work to create a vast data relay mesh across the state, in partnership with first responders, utility companies, and the State, would significantly protect Californians and lead the way for other states that are also fighting fires of unprecedented scale.

This article is available in PDF format for convenient dissemination.

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GeoLinks CEO Joins FCC Broadband Committee

GeoLinks Chief Executive Skyler Ditchfield has been appointed to a working group of the Federal Communications Commission’s Broadband Deployment Advisory Committee.

As a member of the Disaster Response and Recovery Working Group, Ditchfield will contribute to recommending measures to improve the broadband infrastructure before disasters happen and to restore them afterwards.

Ditchfield is the only California representative and the only fixed wireless broadband provider in the working group. His Camarillo company is a mid-sized internet service provider.

He was honored and excited to be part of the working group, Ditchfield said, adding that in the past few fire seasons his staff at GeoLinks has gained experience at restoring connectivity during natural disasters.

“I am confident our working group can not only improve the resiliency of broadband infrastructure before disasters occur nationally, but also ensure that connectivity is both maintained and restored as quickly as possible,” Ditchfield said in a statement.

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FCC Chairman Ajit Pai Appoints GeoLinks’ CEO Skyler Ditchfield to the BDAC Disaster Response and Recovery Working Group

The panel is tasked with developing best practices to improve broadband outage response caused by local, state, and national disasters

CAMARILLO, Calif.–(BUSINESS WIRE)–On Thursday, November 1, 2018, Federal Communications Commission (FCC) Chairman, Ajit Pai, announced GeoLinks’ CEO Skyler Ditchfield’s appointment to the FCC’s Broadband Deployment Advisory Committee (BDAC) Disaster Response and Recovery Working Group.

As stated in the FCC’s formal news release, The Disaster Response and Recovery Working Group is tasked with recommending measures to improve the resiliency of broadband infrastructure before disasters occur, as well as actions that can be taken to more quickly restore broadband infrastructure following a disaster. The Chairman has also charged the working group with developing best practices for coordination among wireless providers, backhaul providers, and power companies during and after a disaster.

“Broadband communications have become essential to the delivery of life-saving information in a disaster,” Chairman Pai said. “It’s critical to public safety that our broadband networks are as resilient as possible to prevent outages in a disaster and also can be restored as quickly as possible when an outage occurs.”

Led by Chair Red Grasso, FirstNet State Point of Contact for the North Carolina Department of Information Technology, and Vice-Chair Jonathan Adelstein, President & Chief Executive Officer of the Wireless Infrastructure Association, Ditchfield is the only California-based representative, and the only fixed wireless broadband provider in the group.

“I am both honored and excited to be part of this working group,” said GeoLinks’ co-founder and CEO Skyler Ditchfield. “Throughout the past few fire seasons in California, my team and I have gained extensive experience in recovering from and restoring connectivity during natural disasters. During the Thomas Fire, for example, we were able to re-establish services in less than 24 hours, whereas many terrestrial providers remained down for months. From solar and wind powered towers, to backup generators, we also have significant expertise in utilizing alternative power methods, technologies that become critical during catastrophic weather events. Locally, I am actively working on a large-scale, state-wide project that will utilize a multitude of technologies, including mobile relay stations, to create true network resilience, ultimately preserving connectivity during disasters. Every region and every disaster in our country has its own subset of challenges. I am confident our Working Group can not only improve the resiliency of broadband infrastructure before disasters occur nationally, but also ensure that connectivity is both maintained and restored as quickly as possible.”

While the first formal meeting of the group has not been publicly announced, a complete list of members is available at

For media inquiries or interview requests, please contact Lexie Smith at [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 first in category on Inc. Magazine’s Inc. 5000 Fastest Growing Companies in America in both 2017 and 2018, GeoLinks delivers Enterprise-Grade Internet, Digital Voice, SD-WANCloud 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.

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Disaster Response and Recovery Working Group


Read Official Notice here:

Released:  November 1, 2018

GN Docket No. 17-83

This Public Notice serves as notice that Federal Communications Commission (Commission) Chairman Ajit Pai has appointed members to serve on the Disaster Response and Recovery Working Group of the Broadband Deployment Advisory Committee (BDAC).  The members of this working group are listed in the Appendix.

The BDAC is organized under, and operates in accordance with, the Federal Advisory Committee Act (FACA).[1]  The BDAC’s mission is to provide advice and recommendations to the Commission on how to accelerate the deployment of high-speed Internet access.[2]

The BDAC’s Disaster Response and Recovery Working Group is charged with making recommendations on measures that can be taken to improve resiliency of broadband infrastructure before a disaster occurs, strategies that can be used during the response to a disaster to minimize the downtime of broadband networks, and actions that can be taken to more quickly restore broadband infrastructure during disaster recovery.  It is also charged with developing best practices for coordination among wireless providers, backhaul providers, and power companies during and after a disaster.

More information about the BDAC is available at  You may also contact Paul D’Ari, Designated Federal Officer (DFO) of the BDAC, at [email protected] or 202-418-1550; or the Deputy DFOs Deborah Salons at [email protected] or 202-418-0637, or Jiaming Shang at [email protected] or 202-418-1303






Red Grasso, FirstNet State Point of Contact

North Carolina Department of Information Technology



Jonathan Adelstein, President & Chief Executive Officer*

Wireless Infrastructure Association




Skyler Ditchfield, Chief Executive Officer



Andrew Afflerbach, Chief Executive Officer and Director of Engineering, CTC Technology and Energy

National Association of Telecommunications Officers and Advisors


Allen Bell, Distribution Support Manager, Georgia Power Company*

Southern Company


Megan Bixler, Technical Program Manager for Communications Center and 911 Services

Association of Public Safety Communications Officials


Patrick Donovan, Senior Director, Regulatory Affairs



Tony Fischer, Director, Information Technology

City of Germantown, Tennessee


Monica Gambino, Vice President, Legal

Crown Castle


Larry Hanson, Executive Director*

Georgia Municipal Association


David Hartshorn, Chief Executive Officer

Geeks Without Frontiers


Greg Hauser, Communications Branch Manager/Statewide Interoperability Coordinator,

North Carolina Emergency Management Division

National Emergency Management Association


Kurt Jacobs, Corporate Director, Emerging Technology & Solutions

JMA Wireless


Richard Kildow, Director of Business Continuity & Emergency Management



Frank Korinek, Director of Government Affairs



Wyatt Leehy, Information Technology Manager

Great Plains Communications


David Marshack, Telecommunications Regulatory Lead



Jim Matheson, Chief Executive Officer*

National Rural Electric Cooperative Association


Kelly McGriff, Vice President & Deputy General Counsel*

Uniti Group


Wendy Moser, Commissioner, Colorado Public Utilities Commission

National Association of Regulatory Utility Commissioners


Alexandra Fernandez Navarro, Commissioner

Puerto Rico Public Service Regulatory Board


John O’Connor, Director, National Coordinating Center for Communications

Department of Homeland Security


Eddie Reyes, Prince William County Emergency Communications Center

National Public Safety Telecommunications Council


Rikin Thaker, Vice President, Telecommunications and Spectrum Policy*

Multicultural Media, Telecom and Internet Council


Pete Tomczak, Manager, Spectrum Coordination and Clearance



Rocky Vaz, Director of Emergency Management

City of Dallas, Texas


Joseph Viens, Senior Director of Government Affairs



Debra Wulff, Public Safety Director

Confederated Tribes of the Colville Reservation


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Mogul’s Top 1,000 Companies with the Strongest Female Leaders in 2018

Thank you Mogul for recognizing GeoLinks has one of the “Top 1000 Global Companies with the Strongest Female Leaders in 2018”!


Mogul’s Top 1,000 Companies with the Strongest Female Leaders in 2018

Mogul is thrilled to announce the 2018 Honorees for the Top 1,000 Companies with the Strongest Female Leaders.

When determining which companies to include, Mogul focused on the following criteria: current programs implemented within an organization to promote female leadership, the percentage of women on the board and in executive positions, and working conditions that best fit a working mother’s needs.

In an age where women’s issues are at the forefront, and where only twenty-four women were on the 2018 Fortune 500 list, Mogul is honored to highlight the below one thousand companies that are taking strides to bring gender parity to the workplace. It is our hope that more and more companies over time will follow in the below companies’ footsteps, and thus, eventually increase the overall percentage of female executives.

Many of the companies included are established, and are the leaders when it comes to setting the bar for creating office cultures that include paid leave, no harassment policies, and mentorship programs to elevate the next generation of female executives. Alternatively, you will also find the hottest female-founded startups that are establishing safe environments for women from the company’s inception.

Whether you are a recent graduate seeking a new position or a seasoned professional looking to make your next career move, we hope this list will guide you in your search. You can’t go wrong with one of the below companies, and we congratulate our 2018 Honorees.


To view the full list visit:


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Six Options For Finding Local Talent In Los Angeles

Six Options For Finding Local Talent In Los Angeles


Hiring talent can be a difficult task — especially in Los Angeles — because while there are a lot of places to look, it can also be difficult to find the right match. Sometimes the perfect match may be looking for you, and sometimes the perfect match isn’t looking at all. Additionally, there are so many different kinds of talent out there that it can feel impossible to swim through all of the options to find just the right person. Having an area or two to focus on can really help improve the odds.

We asked members of the Forbes Los Angeles Business Council for their advice on where to find top talent to fill open positions. The next time you’re looking to hire someone, consider one of these tools or approaches before narrowing down your search to a few individuals.

Local experts share their tips for finding talent.ALL PHOTOS COURTESY OF INDIVIDUAL MEMBERS.

1. Facebook

Facebook isn’t just one of the most wildly successful social networks online; it’s also a place to post your jobs and find qualified candidates. So many of us spend so much of our time on Facebook that it’s a natural place to let people know that you’re hiring. – Ken GoodwinPacific Preferred Insurance Brokers

2. TechFair

Participating in the TechFair organized by the city of Los Angeles is great. It had big local companies in attendance, which attracted many job seekers and in turn led to more great resumes for us!  – Anna NguyenovaTubeScience

3. Referrals

Turn to your company’s best employees and ask them for referrals. That really can be the best way to get a full or accurate read on a person. Resumes these days can often be inflated and rarely ever paint a clear picture of a candidate’s full potential — or lack thereof. – Skyler DitchfieldGeoLinks

4. Local Meetups

Using Meetup (now owned by WeWork) is a great way to network and meet fellow specialists who can themselves help or refer someone to you right in your neighborhood. A few people create their own and drive relevant prospects to it! – Zaid AmmariPPC Masterminds

5. Indeed And Linkedin

I have two resources that I regularly use. One is Indeed, and the other is Linkedin, which I use for finding full stack developers and other talent for our company. Mainly, I will advertise on Indeed and then do follow-up research on Linkedin to see more information about each applicant. It is not easy to find full stack developers that are available and local, but this seems to work pretty well. – Ron LLC

6. Your Community
I find participating in your community really helps. Specifically, speaking at my alma mater (USC) has been a great way to attract extremely promising candidates — from MBAs to people fresh out of college. –  Brett CrosbyPeerStreet
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Six Professional Organizations In Los Angeles You Should Know About

Six Professional Organizations In Los Angeles You Should Know About


Professional organizations can greatly benefit any business professional. It’s an opportunity to get together with like-minded people in your industry and talk about the things that matter to you in the work. It can be great for networking as well as garnering new information that you can then put to use. A business owner may even feel inspired to come up with new ideas to implement.

We asked members of the Forbes Los Angeles Business Council what professional organization they would recommend to help strengthen the business side of things. The suggestions below are just a subset of what is available, so it is encouraged to do research and seek out additional opportunities for networking and professional development.

Members of Forbes Los Angeles Business Council share their favorite professional organizations.PHOTOS COURTESY OF THE INDIVIDUAL MEMBERS.

1. Digital LA 

Digital LA is a group for entrepreneurs, technology executives and startup founders across verticals to connect. Kevin Winston, the creator of Digital LA, creates weekly events across LA on topics ranging from blockchain to health care technology to food influencers. Kevin puts on Silicon Beachfest, which is an annual/bi-annual multi-day conference for LA’s best to connect and attracts people from around the world. – Robert BrillBrill Media Company

  2. Local Chamber Of Commerce

The local Chamber of Commerce hosts frequent networking events and often publically recognizes the great work done within their communities, ultimately making the companies or individuals more visible to the community and beyond. – Skyler DitchfieldGeoLinks

3. Young Presidents’ Organization

Young Presidents’ Organization (YPO) is one of the better organizations to be associated with. It is the leaders and titans of industry, and they have an incredibly rigorous selection process, making it a great place to network and lean on other thought leaders. – Lucas PolsSpark xyz

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Spectrum as Infrastructure – Connecting Rural and Underserved Areas

Spectrum as Infrastructure – Connecting Rural and Underserved Areas

Panel discussion at the 8th Annual SHLB Conference.

Panel Description: More than 15 million Americans in rural and tribal areas still lack access to 25/3 broadband, and a disproportionate number of rural schools and libraries lack high-capacity broadband connections. Wireless services may provide cost-effective solutions to address this rural broadband gap. Fixed wireless access can provide broadband at high capacity (100/10 Mbps or better), or over long distances to remote locations, at a fraction of the cost of trenching fiber. This panel will describe three pending FCC rulemakings that could open access to a large new supply of both unlicensed and lightly-licensed shared spectrum.

Featured Speakers in Highlights: Melissa Slawson (GeoLinks) Andrew Clegg (Google), Moderator: Michael Calabrese (New America OTI)

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8 Companies Redefining Highly Technical Industries

8 Companies Redefining Highly Technical Industries

There are a number of companies disrupting the current state of highly technical industries. From logistics software to machinery, the list of innovation can go on-and-on. This can be attributed to the “meet demand” at all cost global business model we are currently in the throws of.

High-Technology Industry

Image Pixabay

The current tech boom can in many ways be attributed to the perpetually changing needs of retailers, manufacturers, and the consumers they aim to please. This is especially true in highly technical industries where innovative competition is fierce.

Let’s take a closer look at the companies redefining highly technical industries in innovatively unique ways.

1] A. Prentice Ray

Prentice Ray & Associates (APRA) is a company set on disrupting high-tech industry needs in the government sector. They have a variety of consulting services that support government agencies, such as the Department of Defense, Department of State, and the U.S. Air Force.

They provide services, like acquisition support, IT and app development technology solutions, cyber security, project management, staff augmentation, and more. By implementing APRA, agencies and enterprises can enhance existing processes.

2] Edge Logistics

Edge Logistics is a logistics and transportation company helmed in Chicago, Illinois. The company provides freight broker services with high-tech proprietary support to help industries maximize efficiency, which increases their logistics bottom line.

By serving up customized logistics solutions that meet company needs, the company has had exponential growth. Features include, efficiency evaluations, operation audits, distribution program development, and more.

3] Machinery Network

Machinery Network provides a massive inventory of used machinery for CNC, plastic, metalworking, fabrication, and more. This fills a huge industrial gap, especially since the cost of new machinery equipment can be too high for new manufacturers.

The manufacturing industry is always in need of companies providing solutions to enhance efficiency and productivity. According to the National Association of Manufacturers, every dollar spent in manufacturing adds $1.89 to the economy.


Machinery Network adds value to highly technical industries via auction, appraisal, financing, warranties, and technical support. They are members of Machinery Deals National Association (MDNA) and the Association of Machinery and Equipment Appraisers (AMEA).

4] Clean Energy Solutions

Clean Energy Solutions is serves up solar energy solutions for enterprises, governments, nonprofits, businesses, and even homeowners. They are revolutionizing the solar industry, one of the most highly technical industries of today.

Noted as one of the fastest growing companies in the solar industry, they have over 35,000 installs with partners funding almost a billion dollars in solar projects. One of the hallmarks of Clean Energy Solutions is that they make solar attainable to everyone.

5] goTRG

goTRG is a leader in multi-channel sales and supply chain business solutions and SaaS for retailers and manufacturers. There innovative technology helps retailers and manufacturers overcome pain points associated with reverse logistics, returns management, multi-channel sales, and more.

By implementing software, cleverly dubbed as R1 Cloud, they can help retailers and manufacturers make disposition decisions farther upstream for an efficient and more profitable reverse logistics system.

6] GeoLinks

GeoLinks is another company providing value to highly technical industries through fixed wireless Internet. This is achieved using their ClearFiber™ Network, SD-WAN, DigitalVoice, and a full-suite infrastructure.

With 24/7 technical support and fast installation, this innovative company is providing telecommunication on a scalable level. The GeoLinks solution is available for businesses, global enterprises, and institutions.

7] Your Doctors Online

Your Doctors Online is a health-tech company solving a major issue in highly technical industries, providing quality healthcare and access to medical advice, prescriptions, second opinions, and sick notes 24/7 anywhere in the world.

Your Doctors Online

The core of the company began with second opinions for those needing a fresh perspective on a diagnosis or treatment plan.

However, their free online doctor chat has made waves in the health-tech industry. Now people and companies can access doctors via an app in minutes.

8] HQSoftware

HQSoftware delivers customized software solutions in the highly technical space of IoT, VR, and AR. Their innovative solutions include, data analysis, UX/UI design, web and mobile app development and integration, IoT development, software integration, and more.

Featured in CIO Review and Clutch, HQSoftware boasts a notable client list, including the United Nations, HTC, BBC, and SEGA to name a few. There deep tech knowledge has positioned them as a leader in the software industry.

Wrapping Up . . .

There are a number of companies redefining highly technical industries. The above companies are serving up cutting-edge solutions for enterprise, governments, businesses, and organizations, all worth exploring. From logistics to healthcare, the tech solutions of the future are certainly disrupting the tech status quo.

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Comments on The Eligibility For and Prioritization of Broadband




Order Instituting Rulemaking to Consider  Modifications to the California Advanced Services Fund.

Rulemaking No. 12-10-012  (Filed October 25, 2012)





September 21, 2018


California Internet, L.P. (U-7326-C) dba GeoLinks (“GeoLinks” or the “Company”) respectfully submits these opening comments on the Administrative Law Judge’s Ruling Requesting Comments on the Eligibility for and Prioritization of Broadband Infrastructure Funds from the California Advanced Services Fund released on September 5, 2018 (“Ruling”).

Headquartered in Camarillo, CA, GeoLinks is nationally recognized for its innovative Internet and Hosted Voice solutions.  The Company’s proprietary ClearFiber™ product utilizes a combination of terrestrial fiber optic backhaul, carrier-grade full-duplex fixed wireless equipment, and Federal Communications Commission (“FCC”) licensed spectrum to deliver ultra-reliable high-speed broadband Internet access via radio waves.[1]

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 addition, the Company was recently named an awardee in the Connect America Fund Phase II (“CAF II”) auction for several areas in California where, absent subsidy funding, “broadband expansion and ongoing service would not be economically feasible.”[2]  The Company hopes to leverage its expertise in connecting unserved areas of the state to apply for California Advanced Services Fund (“CASF”) funding in the coming year.

  2. The Commission Should Incentivize the Use of Existing Communication Facilities in Making Determinations Regarding 100% Project Funding but Should not Require It if Such Use is Not Practicable

The Ruling seeks comment on how the Commission should weigh the existence of communications facilities when determining whether a project is eligible for 100% funding.  GeoLinks supports the notion that, where possible, existing communication facilities should be utilized for CASF projects.  The CASF should not fund duplicative facilities if use of existing facilities is possible and cost-effective.  This is especially true where existing communication facilities in a proposed project area are owned or already utilized by the CASF applicant.  However, GeoLinks urges the Commission not to mistake the existence of communication facilities with the availability or usability of communication facilities.

The “existence of communication facilities” should be narrowly defined to only include facilities that are accessible to a CASF applicant.  As an initial matter, while competitive broadband providers may have information regarding existing fiber backhaul interconnection points or existing unbundled network elements (“UNEs”), they do not necessarily have access to information regarding where all existing communication facilities exist within or near a proposed project area.  For example, providers may not know where there is existing conduit or wireless communication towers.  In addition, even if a tower is present, it may not always be clear who owns it.  In these instances, if a CASF applicant is not aware that facilities are available, it should not be precluded from seeking 100% CASF funding for an area.

Second, even where existing communications facilities are known, they may not be available.  Areas without highspeed broadband access generally do not have an abundance of options for middle mile and backhaul interconnection.  In GeoLinks experience, areas such as those that are eligible for CASF funding may only have legacy ILEC facilities.  GeoLinks has experienced several instances where UNE connections have been unavailable due to oversold circuits or the delays associated with negotiating interconnection agreements.  In these instances, while communication facilities technically exist, they are not feasible options and should not preclude a competitive broadband carrier from being eligible for 100% CASF funding if the project would otherwise meet the criteria for additional funding and serve the public interest.

Third, even if known and available, utilizing existing facilities may not be the most cost-effective solution for a project.  Fixed wireless providers use existing facilities wherever practicable including towers, roof tops, water towers, etc.).  However, in instances where there are no existing facilities with line-of-sight, a fixed wireless provider may not be able to utilize existing communications facilities (or any facilities, for that matter).  In these cases, in order to create a direct line of sight (and to avoid unnecessary “tower hops” that can add cost and deployment delay), a fixed wireless provider may need to build its own towers.  These new towers are capable of extending high-speed broadband networks to areas that fiber providers either can’t or are unwilling to due to cost.  In these situations, while existing facilities may be technically available, it may not make sense to utilize them.

For the reasons stated above, GeoLinks urges the Commission not to require utilization of any existing communication facilities that may exist in a proposed project area in order to obtain 100% funding.  While GeoLinks supports a requirement to use existing facilities, generally, GeoLinks recommends that in instances where existing facilities are unknown, unavailable or impractical the Commission require that the CASF applicant provide an explanation describing 1) what steps were taken to determine if existing facilities are available, 2) the extent to which any available facilities will be utilized in the proposed project, and 3) if available facilities will not be utilized, an explanation of why the costs to build additional facilities is in the public interest.  GeoLinks believes that this approach will encourage use of existing facilities, where available, but will not hinder competitive carriers from seeking 100% CASF funding for the benefit of a proposed project area or promote over subsidizing CASF projects where it would be more cost-effective to construct new facilities.

In addition to the above, the Ruling asks whether the use of unconnected public safety infrastructure should be a factor in determining whether additional funding is available.  GeoLinks is not opposed to efforts to promote the use of this infrastructure, where available, in CASF projects.  However, if this type of infrastructure is going to be a factor in determining whether additional funding is available, GeoLinks believes that information regarding where this infrastructure is should be made available to all potential CASF applicants.  Moreover, the Commission must take steps to ensure that this infrastructure is accessible by CASF applicants.  Otherwise, this infrastructure should be considered simply “existing communication facilities” and any applicant that already owns this infrastructure should be required to utilize it as part of a proposed CASF project, to the extent possible.

  1. “Significant Contribution” Should be Determined on a Project-Specific Basis

GeoLinks believes that whether a proposed CASF project makes a “significant contribution” to achieving the program goal depends on the specifics of the proposed project.  Using the example set forth in the Ruling, while serving a minimum number of households may be indicative of a “significant contribution” in some CASF-eligible areas, in others, where there may be few households (because, for example, the area is remote or primarily agricultural), GeoLinks believes that a “significant contribution” can still be made in other ways (e.g. by ensuring broadband availability to key anchor institutions in the area, as well as the households within a propose project area).

As the Commission recently stated, the goal of the CASF program is to “support broadband adoption programs in communities with low broadband access.”[3]  This goal applies to all communities throughout California that lack sufficient broadband access.  GeoLinks urges the Commission not to set minimums to measure “significant contribution” that disincentivize would-be CASF applicants from applying for CASF funds in smaller communities.  Instead, GeoLinks suggests that the Commission develop a set of factors that can be weighed to determine if a project would make a “significant contribution.”  In addition to how many households may be served by a project, these factors could include, for example, whether services will be made available to anchor institutions, what speeds will be offered, what the proposed service offerings are, etc. Therefore, GeoLinks urges the Commission to determine whether a project makes a “significant contribution” to achieving the program goal on a project-by-project basis.

  1. Additional Funding Should be Available for Projects that Would Serve Low-Income Communities on a Technology Neutral Basis

In the Ruling, the Commission asks whether additional funding should be provided for applications that service low-income areas.  As an initial matter, GeoLinks supports methods to incentivize CASF projects to low-income communities and does not oppose additional funding for projects that would serve these communities, as set forth in the Ministerial Review table in the Ruling.[4]  However, as discussed in further detail below, GeoLinks urges the Commission not to prioritize one technology type over others by, for example, granting ministerial review to a proposed fiber project to a low-income area but not to a fixed wireless project for a similar area even if the fixed wireless project may offer the same service offerings at a per-household cost of 5x less.  GeoLinks urges the Commission to take a technology neutral approach for all aspects of the CASF program including incentives for serving low-income communities.

  1. The Commission Should Require CASF Grantees to Offer Affordable Broadband Service Plans as a Condition of Receiving CASF Funding

GeoLinks believes that affordability should absolutely be a factor when addressing broadband access.  It is well understood that the digital divide has two sides – availability and adoption.  Even where broadband service may be available, if it is not affordable then it is still not attainable.

GeoLinks supports requiring CASF grantees to offer affordable broadband service plans.  The FCC has long recognized the importance of affordability when it comes to broadband access.   The FCC’s Urban Rate Survey sets forth reasonable comparability benchmarks for fixed voice and broadband services.  As part of the CAF II Auction process, the FCC requires CAF II recipients to adhere to these comparability benchmarks when pricing broadband services:

For broadband services, a support recipient will be required to certify that the pricing of a service that meets the required performance tier and latency performance requirements is no more than the applicable reasonably comparable rate benchmark, or that it is no more than the non-promotional price charged for a comparable fixed wireline broadband service in the state or U.S. territory where the eligible telecommunication carrier (ETC) receives support.[5]

GeoLinks believes that if the Commission requires an affordable broadband service plan, it should build off of the extensive work the FCC has already done and utilize the rural comparison rates already in place.  Requiring a different standard could disincentivize providers from participating in the CASF program.  On one hand, a laxer pricing standard could run contrary to the FCC’s standards, putting CAF II service providers at odds with the FCC’s directives.  On the other hand, a stricter pricing standard could render an area unattractive to potential applicants where, even with a grant or loan (even at 100% funding), a return-on-investment may not be possible.

GeoLinks urges the Commission to require an affordable service offering from CASF grantees that aligns with requirements already put into place for CAF II recipients.  This will ensure an affordable rate for consumers and create administrative certainty for all broadband providers.  

  1. The Commission Should Ensure That Any New Scoring Criteria Serve the Public Interest and the Goals of the CASF Program

In the Ruling, the Commission proposes a number of new scoring criteria.  GeoLinks provides comments on the proposed scoring criteria, below:

  • A Commitment to Serve All Households in the Proposed Project Area

GeoLinks supports a requirement to serve a minimum threshold of households within a proposed project area.  This is necessary to ensure that the residents of a project area receive the full benefit of the CASF award.  However, GeoLinks cautions against drawing a hard line regarding serving all households in a project area given currently available data.

On the California Broadband map, census projections are based on the 2010 U.S. Census.  While this may be the most accurate information available, it is still close to 10 years old and may, depending on how areas have changed, over or under-estimate the actual number of households in an area.  Even for the CAF II Auction, while the FCC requires that auction recipients offer service to a certain number of locations within an award area, that number is based on the Connect America Cost Model Methodology, which is an estimate and subject to a “true-up” process once awardees begone construction.  For this reason, GeoLinks suggests that the Commission adopt the same minimum availability threshold utilized by the FCC in the CAF II auction (95% of locations within eligible areas) for CASF project areas.[6]

  • 10 Mbps/ 1 Mbps Speed Threshold

As GeoLinks explained in prior comments in this proceeding, the Commission should reject any notion that so long as a CASF applicant offers 10 Mbps/1 Mbps, no additional points should be awarded if higher speeds are offered.[7]  This “good enough.” approach does nothing to future-proof network design to ensure adequate speed and capacity for years to come and runs contrary to the goals of the CASF program.  Just as the FCC’s CAF II auction assigned different bid weights to different speeds tiers offered by auction participants,[8]  the Commission should assign higher weight to CASF applications that offer higher speeds.  In addition, GeoLinks urges the Commission to consider weighting a proposed project higher with respect to additional funding above 60% if a service provider proposes to offer speeds of 100 Mbps/ 20 Mbps to a minimum of 95% of locations within a proposed service area.

  • Latency

GeoLinks advocates that latency of 100 ms should be the absolute minimum acceptable for any CASF-funded broadband project.  The Company has advocated in other forums that the minimum latency should be 50 ms.

  • CEQA-Related Timeframes

GeoLinks supports the proposed requirement that if a project receives a categorical exemption under CEQA, it must be completed in 12 months or less and if a project requires additional CEQA/NEPA review it must be completed within two years of the approval of those reviews.  The CASF program should support rapid deployment of high speed broadband networks.  Longer timeframes would not serve the public interest.

  • Data Caps

GeoLinks supports this Commission’s proposed requirement that data caps, where used, should exceed 190 GBs per month.  The Company does not impose data caps on its customers and does not believe that CASF recipients should, either.  However, if imposed, GeoLinks believes that 190 GBs per month is sufficient for general use.  That said, the Company urges the Commission to require that CASF-awardees offer a plan with a higher data cap.

  • Affordable Plans

As explained above, GeoLinks supports the notion of requiring CASF-recipients to offer affordable plans to customers.  Specifically, GeoLinks urges the Commission to utilize the rural comparison rates already established by the FCC.  

  1. The CASF Program Should be Administered on a Technology Neutral Basis

As an initial matter, GeoLinks asserts that the CASF Program, in all aspects, should be administered on a technology-neutral basis.  Any service provider, regardless of technology type (including satellite), should be permitted to apply for CASF funds so long as it can adhere to all minimum service requirements as suggested herein.  Along this vein, any service provider, regardless of technology type, must also be subject to the same standard of review with respect to the CASF application process.

In the Ruling, the Commission seeks comment on proposed revisions to the Ministerial Review process set forth in the Staff Proposal.  While GeoLinks continues to support a ministerial process and commends the Commission for considering this time and cost saving process, the Commission must ensure that any such process is implemented on a technology neutral basis, which, unfortunately, the proposed revisions still do not accomplish.

Originally, Staff’s proposal suggested a per household threshold of $1,285 for fixed wireless providers and $15,650 for wireline providers to received ministerial review of any proposed project that proposed to serve low-income areas.[9]  In the Ruling, the Commission now proposes $4000-$8000 per household for wireline and $1,500 for fixed wireless to trigger ministerial review.  As noted in GeoLinks’ opening comments on the Staff Proposal, it was not clear where the original numbers came from but GeoLinks surmised that they may have been based on amounts approved for projects in the past.[10]  GeoLinks does not know how the Commission determined the new numbers in the Ruling.  Regardless, GeoLinks maintains that any threshold numbers used as part of any CASF review process must be technology neutral lest they work to favor one technology over others.

As proposed, the new ministerial process for reviewing CASF projects and assigning the amount of funding a project may be eligible for STILL creates a huge disparity between technology types.  First, the Ruling proposes a range for ministerial review of wireline projects that may allow for streamlined review of projects that cost more than 5x what a fixed wireless project may cost for the same area.  For example, if a fixed wireless provider applies to provide high-speed broadband to households in a CASF-eligible area of the state for $1600 per household, that fixed wireless provider should not be precluded from the ministerial process when a fiber-based project, that will likely offer the same speeds, latency, etc., would be eligible for ministerial review – and for a project costing potentially $6400 more PER HOUSEHOLD.   This price discrepancy serves no public benefit and diverts funds that could be used for other areas unnecessarily.  The Commission should instead grant ministerial review for all projects that offer streamlined, high quality, low-cost solutions to CASF-eligible areas, regardless of technology type.

GeoLinks urges the Commission to set one per household cost threshold for ministerial review that accommodates any kind of technology.  This will encourage service providers with the most cost-effective network design to apply for funding.  Moreover, it will streamline the administrative process.  As the Commission appears to believe $4000 would be an appropriate threshold, GeoLinks supports making that the threshold for ministerial review for all technology types.

  1. The Commission Should Not Preclude CAF Providers from Seeking CASF Funds in Non-CAF Areas

As GeoLinks explained in previous comments, in adopting any rules related to the treatment of CAF recipients, GeoLinks urges the Commission to remember that these recipients made commitments to the FCC in exchange for receipt of CAF funds.  As a recent CAF II awardee, GeoLinks stands by this statement as it prepares to complete its CAF II obligations.

GeoLinks does not believe that CAF providers should be precluded from seeking CASF funding for non-CAF areas, subject of course to the same evaluation criteria and the same score weighting as all CASF applicants (as detailed above).  Allowing these providers to seek CASF funds for areas that, for example, may be adjacent to a CAF area or the CAF provider’s existing service territory may create synergies that could reduce the amount of CASF funding needed to serve the area (vs. a new provider potentially needing to build network from scratch to provide the same service).  Because CAF II providers will already be constructing network in California capable of providing consumers with higher speeds than that required under the current CASF rules,[11] allowing these providers to extend additional network that will be capable of the same to CASF-eligible areas is in the public interest.  In addition, GeoLinks believes that after a CAF area is completed (meaning the provider has completed construction to ensure broadband availability to the requisite number of locations in an area as required by the FCC), CAF providers should not be precluded from applying for CASF funding to complete build out to 100% of the locations within that area.

If a CAF provider fails to meet its commitments (either by only offering broadband service to a portion of the requisite locations within an area or not completing an area at all), there should be some consequence with respect to CASF funding for those CAF areas.  Since CAF areas are precluded from CASF funding and will be until July 2020, unless a CAF provider notifies the Commission that it does not intend to complete its obligations, these areas continue to be “on hold” until CAF providers can complete network buildout.  If a CAF provider decides not to complete an area and waits to inform the Commission of this fact, it is essentially holding the area hostage with respect to broadband funding.  This behavior should not be rewarded.  GeoLinks urges the Commission to adopt a mandatory CASF-application waiting period for these providers, which would ramp up the longer the provider waited to inform the Commission that it would not complete a CAF area.  Failure to impose some consequences for delay on the part of these providers will only serve to incentivize gaming the system to the detriment of California consumers.


Based on the foregoing, GeoLinks urges the Commission to ensure that the CASF Program is administered on a technology neutral basis and in a way that allows applicants to leverage existing communication facilities and other sources of funding without limiting opportunities for competitive carriers to offer cost-effective, high quality, broadband solutions to CASF-eligible areas.


Respectfully submitted,


/s/ Melissa Slawson   

Melissa Slawson

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

California Internet, L.P. dba GeoLinks

251 Camarillo Ranch Rd

Camarillo, CA 93012


September 21, 2018

[1] For more information about fixed-wireless technology and GeoLinks’ Clearfiber™ network, visit
[2] FCC Press Release, Connect America Fund Auction to Expand Broadband to Over 700,000 Rural Homes and Business: Auction Allocates $1.488 Billion to Close the Digital Divide, released August 28, 2018 (“CAF Press Release”), at 1.
[3] Press Release, CPUC Acts to Expand Broadband Adoption Through California Advanced Services Fund, released June 21, 2018.
[4] See Ruling at 6.
[5] See Connect America Fund Phase II Auction Scheduled for July 24, 2018 Notice and Filing Requirements and Other Procedures for Auction 903, AU Docket No. 17-182, released February 1, 2018, at para 13.
[6] See Connect America Fund, et al., Order on Reconsideration, FCC 18-5 (rel. January 31, 2018) (“CAF Recon Order”), at para. 29.
[7] Reply Comments of California Internet, L.P. DBA GeoLinks on Phase II of the February 14, 2018 Amended Scoping Memo and Assigned Commissioner’s Ruling (filed May 1, 2018), at 6.
[8] CAF Recon Order, at para. 4.
[9] Phase II of the February 14, 2018 Amended Scoping Memo and Assigned Commissioner’s Ruling, Appendix C (“Staff Report”), at 14.
[10] Opening Comments of California Internet, L.P. DBA GeoLinks on Phase II of the February 14, 2018 Amended Scoping Memo and Assigned Commissioner’s Ruling (filed April 16, 2018), at 3.
[11] See  As shown on this map, all areas in California for which support was awarded are for services at “baseline” (25/3 Mbps) or higher.  See also, CAF Recon Order, at para. 4.
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