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GeoLinks Formally Approved by USAC to Begin CAF Build Out

The Universal Service Administrative Company has officially cleared GeoLinks to begin CAF II build outs in California and Nevada

CAMARILLO, Calif.–(BUSINESS WIRE)–On Wednesday, June 5th, 2019 the Universal Service Administrative Company (USAC) formally approved GeoLinks to start receiving funding for the Company’s Connect America Fund Phase II (CAF II) buildout in California and Nevada. Announced by the Federal Communications Commission (FCC) in August of 2018 as the largest CAF II winner in the state of California, and 5th largest winner in the nation overall, with GeoLinks’ deployment plans and Letters of Credit officially approved, the innovative telecom will officially begin broadband deployment this summer.

Awarded a total of $87.8M in the auction, GeoLinks will provide more than 11,000 rural locations across California and Nevada with Internet at 100 megabits per second. The Company is also confident that this new infrastructure will simultaneously reduce the cost of bringing high speed broadband access to anchor institutions, such as Schools, Libraries, Hospitals, and Community Colleges, throughout both states.

“We are thrilled to have officially cleared both the FCC and USAC’s approval process for CAF II,” stated GeoLinks’ Co-Founder and CEO Skyler Ditchfield. “While the announcement back in August was undoubtedly exciting, we are now officially in the position to begin deployment throughout both states.”

With the GeoLinks’ team fully prepared to break ground, the Company is now looking forward to participating in the FCC’s LIFT America Act, which will support another $40B worth of broadband infrastructure deployment in aims of closing the digital divide.

For media inquiries and interview requests, please contact Lexie Smith at [email protected]

FCC Comments – Microwave Flexible Use Service Licenses

Before the

Federal Communications Commission

Washington, DC  20554

 

In the Matter of

Preparation For Incentive Auction of Upper

Microwave Flexible Use Service Licenses In                            AU Docket No. 19-59

The 37 GHz, 39 GHz, and 47 GHz Bands

(Auction 103)

 

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) hereby submits these Comments in response to the Commission’s Public Notice released in the above-captioned proceedings.[1]

I. INTRODUCTION AND SUMMARY

GeoLinks is one of the fastest growing Internet and phone providers in America and the fastest growing telecom in California.  As such, and in order to be truly competitive within its service territory, the Company has a vested interest in promoting policies that allow fixed wireless broadband service providers to access spectrum resources suitable to providing high-speed broadband service.  Traditionally, fixed wireless ISPs have operated in the unlicensed bands (i.e. 2.4 and 5 GHz).  While several fixed wireless providers, including GeoLinks, have been successful in utilizing the unlicensed bands, their application is limited.  The availability of PAL licenses in the 37, 39, and 47 GHz bands, in addition to others the Commission is currently crafting rules for, could provide fixed wireless providers opportunities to provide fiber-like high bandwidth services and robust backhaul for 5G services in areas and in ways it was not previously possible.

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses and for seeking comment on ways to structure the upcoming Auction 103 to try to ensure participation from smaller companies.  While the Company believes that these efforts are a step in the right direction, it is concerned that Auction 103, if not structured the right way, will result in all available spectrum resources being consumed by large companies with seemingly endless capital.  As such, GeoLinks offers the following suggestions to help the Commission put would-be auction participants of all sizes on more equal footing in order to encourage additional licensees and innovative use of the 37, 39, and 47 GHz bands.

I. DISCUSSION

A. The Commission Should Make “White Space” Available for Auction

In the Public Notice, the Commission explains that it does not propose to make the “white space” that results in the 39 GHz band if incumbents chose to receive modified licenses, retaining only “partial PEA holdings (i.e., covering less than the full geographic are of a PEA).[2]  GeoLinks does not believe that leaving these “white spaces” unused promotes sound spectrum policy, especially when these white spaces can be used to further the deployment of advanced spectrum-based services.

In the Public Notice the FCC makes several proposals that would enable small businesses (e.g. small service providers) to participate in Auction 103.  However, as small providers have advocated in numerous proceedings, PEA-sized license areas can be too large.  For example, in the 3.5 GHz proceeding, GeoLinks previously advocated for smaller license areas because PEAs can so vastly differ in size as well as in urban vs. rural make up.[3]  The example GeoLinks provided, specifically, was PEA 2 in Southern California, which encompasses eight counties[4] and includes both large populous areas and large swaths of rural areas that are currently deemed “unserved” by high-speed broadband services.  If smaller “white space” license areas were made available within this PEA, for example, it might allow smaller carriers to provide more pinpointed services to specific communities without having to try and compete with the large providers for an entire PEA.

Attachment A hereto is a screenshot of PEA 2 taken from the California Interactive Broadband Map.[5]  The shaded areas represent areas that are considered unserved (no broadband access).[6]  While most of these areas fall within Connect America Fund Phase II grant areas, this map illustrates that large PEAs can contain both metropolitan areas as well as unserved areas. If “white spaces” in the 39 GHz band exist in PEAs that could be used to help provide much needed services to unserved rural areas, it stands to reason that the Commission should make those areas available to companies that wish to use them.  Conversely, if a remaining “white space” were to fall within a more populated area, allowing smaller companies the chance to utilize that spectrum would only serve to promote competition against companies who may opt for PEA-sized licenses.

GeoLinks fails to see the logic in creating auction procedures to encourage small companies to participate but refrain from creating possible license areas that these small companies could utilize – especially when they are available.  Moreover, not making these smaller license areas available will lead to these areas remaining unused, which will most likely disproportionately affect rural areas.  As such, GeoLinks strongly urges the Commission to reconsider its position to exclude “white space” areas from Auction 103.

B. The Commission Should Eliminate the Proposed Bidding Credit Caps

GeoLinks has previously expressed that incentive auctions tend to only benefit large companies with large amounts of capital to spend.  For this reason, GeoLinks commends the Commission on its decision to implement bidding credits for small businesses and primarily rural service providers.  However, while the bidding credits set forth in the Public Notice will help level the playing field for all bidders in the Auction 103, the Company believes that if the Commission truly wants to “promote small business and rural service provider participation in auctions and in the provision of spectrum-based services,” it must allow the playing field to remain level throughout the entire auction process.  Specifically, GeoLinks urges the Commission to eliminate the bidding credit caps it proposes in the Public Notice.[7]

GeoLinks recognizes that most companies eligible for the bidding credits do not have access to the kind of capital needed to even come close to reaching the bidding credit caps set forth in the Public Notice.  However, this does not mean it’s impossible. To truly create an auction process that promotes the deployment of advanced spectrum-based services, the Commission must account for the financial differences between larger companies and smaller, competitive companies or those focused on serving rural areas.  For example, if a small competitive broadband provider or rural service provider were to successfully raise enough capitol prior to the auction, it is possible that that company could compete head-to-head with a larger provider for the same block of spectrum within a specific license area.  In this circumstance, the smaller/ rural service provider should not be hamstrung by a limit on bidding credits, which could mean the difference between obtaining needed spectrum or not.  To promote innovation, these smaller companies must be given an opportunity to obtain spectrum licenses. Therefore, GeoLinks urges the Commission to refrain from imposing bidding caps on could-be auction winners and make the Auction 103 bidding credits applicable to all bids made by an eligible company, no matter how large.

II. CONCLUSION

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses and to encourage small businesses to participate in Auction 103.  However, in order to truly promote expanded participation in the Auction, GeoLinks recommends that the Commission reconsider making “white spaces” in the 39 GHz band available for auction and remove the bidding credit caps that will only serve to hamstring smaller providers from bidding against large providers.

/

/

/

/

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

May 15, 2019

 

Attachment A

FCC Comments - Microwave Flexible Use Service Licenses

[1] Incentive Auction of Upper Microwave Flexible Use Service Licenses in the Upper 37 GHz, 39 GHz, and 47 GHz Bands for Next-Generation Wireless Services; Comment Sought on Competitive Bidding Procedures for Auction 103, Public Notice, AU Docket No. 19-59, FCC 19-35 (rel. April 15, 2019) (“Public Notice”).
[2] Public Notice at para. 5.
[3] See Reply Comments of California Internet, L.P. dba GeoLinks, GN Docket No. 17-258 (filed January 29, 2018).
[4] PEA 2 encompasses Kern, Los Angeles, Orange, Riverside, San Bernardino, San Luis Obispo, Santa Barbara, and Ventura Counties.
[5] See http://www.broadbandmap.ca.gov/ (screenshot taken May 10, 2019).
[6] Based on California’s definition – areas that are not served by speeds of at least 6 Mbps down/ 1 Mbps up.
[7] See Public Notice at paras. 11-17.

GeoLinks’ CEO Skyler Ditchfield Appointed to the FCC’s Broadband Deployment Advisory Committee

The Federal Communications Commission announces Skyler Ditchfield as a member of the newly re-chartered Broadband Deployment Advisory Committee

CAMARILLO, Calif.–(BUSINESS WIRE)–On May 16, 2019, Chairman Ajit Pai of the Federal Communications Commission (FCC) announced his appointment of Skyler Ditchfield, Co-Founder and CEO of GeoLinks, to serve as an official member of the newly re-chartered Broadband Deployment Advisory Committee (BDAC). Of the 39 listed appointees, Skyler Ditchfield serves as the only Southern California representative.

According to the FCC’s official release, “In its second term, the BDAC will continue its work to craft recommendations for the Commission on ways to accelerate the deployment of high-speed Internet access, or ‘broadband,’ by reducing and/or removing regulatory barriers to infrastructure investment and strengthening existing broadband networks in communities across the country.” The release continues by outlining the BDAC as an opportunity for interested stakeholders to exchange ideas and develop recommendations to the Commission on broadband deployment, to enhance the Commission’s ability to deploy broadband to all Americans.

Previously appointed to the Streamlining Federal Siting Working Group in 2017, and the Disaster Response and Recovery Working Group in 2018 (both BDAC sub groups), Ditchfield’s elevated appointment will enable him to provide strategic recommendations and influence action to close the digital divide on a national scale.

“I have been continually impressed by Chairman Pai, his administration, and all the work that they have done thus far,” stated Ditchfield. “They’ve truly worked hard to level the playing field for all sized ISPs. They’ve put forward significant new dollars towards broadband investment and are staying true to their promise of closing the digital divide. With GeoLinks’ founding mission being to close the digital divide, we have a multitude of case studies that have proven capable of closing the gap in California. Being that all of these projects demonstrate proven and transferrable methods, I am very excited to get to work with both the BDAC and my two designated working groups to cultivate the most realistic and feasible path forward nationally.”

The renewed BDAC will hold its first meeting on Thursday, June 13, 2019, in the Commission Meeting Room at FCC Headquarters, located in Washington, DC. The meeting is open to the public. The FCC will accommodate as many attendees as possible; however, admittance will be limited to seating availability. The Commission will also provide audio and/or video coverage of the meeting over the Internet from the FCC’s web page at www.fcc.gov/live.

The FCC’s official Public Notice can be accessed online via the following link: https://www.fcc.gov/document/fcc-announces-re-chartered-bdac-membership-and-first-meeting

For media inquiries or interview requests, please contact Lexie Smith, VP of Business Development, 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.

Contacts

Media Inquiries:
GeoLinks
Lexie Smith, VP of Business Development
[email protected]

Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz

Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz - GeoLinks

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) hereby submits these Reply Comments in response to comments filed on the Notice of Proposed Rulemaking (“NPRM”) released in the above-captioned proceedings.[1]

 

  1. INTRODUCTION AND SUMMARY

GeoLinks is one of the fastest growing Internet and phone providers in America and the fastest growing telecom in California.  In an effort to be a truly competitive service provider throughout its service territory, the Company has a vested interest in ensuring that the FCC’s policies allow fixed wireless broadband service providers access vital spectrum resources.  GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses.  It is undeniable that additional spectrum is necessary to meet “America’s appetite for wireless broadband connections.”[2]  However, GeoLinks urges the Commission not to assume that more unlicensed spectrum is sufficient in and of itself to meet the ever-growing demand for these connections.  Moreover, GeoLinks urges the Commission not to limit how fixed wireless service providers may use these new unlicensed resources, and to create rules that allow for Point-to-Multipoint (“P2MP”) use within the 6 GHz band.

  1. DISCUSSION 

  1. Unlicensed Spectrum is Not a One-Size-Fits-All Solution

Traditionally, fixed wireless ISPs have operated in the unlicensed bands (i.e. 2.4 and 5 GHz).  The lack of access to licensed spectrum has forced fixed wireless providers to get very creative about how they provision highspeed and high capacity broadband services (including multi-gigabit speeds).  While several fixed wireless providers, including GeoLinks, have been very successful in utilizing the unlicensed bands, the application of these bands is limited.  As several commenters note, increased use of the unlicensed bands has created congestion.[3]  As Broadcom points out, “demand for unlicensed services, especially Wi-Fi, continues to grow, and the existing unlicensed spectrum in the 2.4 GHz and 5 GHz bands has become congested.”[4]  In addition, as WISPA’s comments show, the issue of congestion in the unlicensed bands has also been recognized by all current FCC Commissioners.[5]

While GeoLinks sees merit in Broadcom’s assertion that making the 6 GHz band available for unlicensed use “will be a critical step in addressing the looming unlicensed spectrum crunch,”[6] ultimately, GeoLinks believes that relying solely on more unlicensed spectrum availability (without additional opportunities for licensed spectrum) is, at best, a short-term solution.  As Commissioner Rosenworcel notes in her NPRM statement, “by the end of the decade, we will see as many as 50 billion new devices connecting to our networks through the internet of things.”[7]  GeoLinks cautions that as innovation and new devices seek room in the unlicensed bands, the wireless broadband providers that offer competitive connectivity to these new devices will continue to get squeezed.  Inevitably with so many wireless devices and wireless service providers clamoring for the same spectrum, the result will be the same – congestion in the bands and limited opportunities for competition and innovation.

As GeoLinks has expressed before, the availability of unlicensed bands is not a one-size-fits-all solution to the ever-growing demand for spectrum.  In order to craft a more complete, long-term solution, GeoLinks urges the FCC to expand the availability of unlicensed bands in conjunction with efforts to create more opportunities for licensed spectrum for competitive broadband providers.  This dual approach will ensure less congestion in the unlicensed bands for those carriers supplying the connectivity that drive further innovation.

  1. The Commission Should Ensure the New Rules Regarding the Use of the 6 GHz Band Allow for P2MP Use

With respect to new rules to govern unlicensed use of the 6 GHz band, GeoLinks agrees with various commenters that urge the Commission to create new rules that allow for and promote P2MP operations.  For example, the Dynamic Spectrum Alliance (“DSA”) and Starry urge the Commission to allow higher gain antennas and P2MP operations.[8]  Similarly, WISPA makes a number of suggestions that would allow for P2MP operations such as refraining from limiting the types of services that can be offered in the U-NII-5 and U-NII-7 bands.[9]

As GeoLinks has previously explained, P2MP technology creates opportunities to connect multiple users in a more cost-effective manner (even if miles apart), making it ideal for serving multiple customers in one area at a lower cost.  As Starry notes, “point-to-multipoint deployments are essential to fixed wireless providers.”[10]  Moreover, DCA explains that these technologies (as well as point-to-point) “will help improve connectivity and competition in all markets, including but not limited to underserved areas and rural communities.”[11]  For these reasons, GeoLinks urges the Commission to develop rules that allow for P2MP use in the 6 GHz Band.

  1. CONCLUSION

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses.  However, as the Commission strives to create policies and rules for unlicensed spectrum use in the 6 GHz Band, GeoLinks urges the Commission not to assume that more unlicensed spectrum is sufficient in and of itself to meet the ever-growing demand for these connections and to promote competition by creating rules that allow for P2MP use.

 

Respectfully submitted,

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

March 18, 2019

[1] Unlicensed Use of the 6 GHz Band; Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz, Notice of Proposed Rulemaking, ET Docket No. 18-295 and GN Docket No. 17-183, FCC 18-147 (rel. Oct. 24, 2018) (“NPRM”).  The NPRM was published in the Federal Register on December 17, 2018.  See 83 Fed. Reg. 64506 (Dec. 17, 2018).
[2] NPRM at para. 4.
[3] See Comments of Broadcom Inc., ET Docket No. 18-295 (filed February 15, 2019) (“Broadcom Comments”) at 1, Comments of the Wireless Internet Service Providers Association, ET Docket No. 18-295 (filed February 15, 2019) (“WISPA Comments”) at 5, Comments of Dynamic Spectrum Alliance, ET Docket No. 18-295 (filed February 15, 2019) (“DSA Comments”) at 1.
[4] Broadcom Comments at 1.
[5] See WISPA Comments at 6-7 citing NPRM statements of Chairman Pai and Commissioners Carr, O’Rielly, and Rosenworcel.
[6] Broadcom Comments at 1
[7] NPRM statement of Commissioner Rosenworcel at 1.
[8] DSA Comments at 3, Comments of Starry, Inc., ET Docket No. 18-295 (filed February 15, 2019) (“Starry Comments”) at 2.
[9] See WISPA Comments at 10.
[10] Id.
[11] DSA Comments at 15.

The future has arrived; it’s Smart, and we’re not ready for it. Here’s why.

Smart City Technology- Lexie Smith - GeoLinks

Read the original article on Medium.com

From Washington D.C., to the coast of California, “Smart City” is, and was, perhaps 2018’s most prominent buzzword, aside from “5G”, circulating nearly all tech, economic, and broadband related conferences and forums. While the exact definition of what really is a “Smart City” varies by person and party, the concept itself is based on the integration of Information and Communication Technologies (ICT) and the Internet of things or (IoT), to optimize city-wide operations, services, and ultimately connect to citizens.

While some of the general public still think of this concept as far off, the reality is that “Smart Cities” have already began materializing across the country. Thus, this glorified digital future is here, and guess what America, we’re not ready.

Why Not?

Well, it’s simple really. Cities and its citizens can have all the ICT or IoT devices they want, but in order to make a city smart, these systems and gadgets have to physically work. That’s where connectivity comes into play. To fuel a Smart City, you need to have broadband Internet access with enough bandwidth to support electronic data collection and transfers. According to the Federal Communications Commission’s (FCC) 2018 Broadband Deployment Report, upwards of 24 million Americans still lack access to high speed broadband. Furthermore, the report states that approximately 14 million rural Americans and 1.2 million Americans living on Tribal lands still lack mobile LTE broadband at speeds of 10 Mbps/3 Mbps. Finally, only 88% of American schools were reported to meet the FCC’s short-term connectivity goal of 100 Mbps per 1,000 users, and only 22% of school districts met its long-term connectivity goal of 1 Gbps per 1,000 users.

On December 4th, the New York Times released an article titled, “Digital Divide Is Wider Than We Think, Study Says” that refuted the FCC’s published report. Based on a study conducted by Microsoft, the article summarizes that researchers concluded “162.8 million people do not use the internet at broadband speeds… In Ferry County, for example, Microsoft estimates that only 2 percent of people use broadband service, versus the 100 percent the federal government says have access to the service.”

So, regardless of which multi-million statistic we conclude is more legitimate, while many metro areas may have the bandwidth needed to at least partially move forward into the next digital revolution, there are still millions of Americans who would, as it stands, be left behind. This reality, coined the digital divide, is the ultimate Smart City roadblock.

Why being hyper fiber-minded is our fatal flaw:

States and communities across the country advocate that pervasive fiber network expansion is the solution to closing the divide. And yes, fiber networks can be great. The reality is, however, that building out fiber infrastructure to every location in America is time-consuming, tedious, and prohibitively expensive. Therefore, deploying fiber does not make economic sense in many rural and urban areas of the country. The Google Fiber project serves as a prime example of this.

To summarize, Google officially launched its Google Fiber project in 2010 with more than 1,100 cities applying to be the “First Fiber City.” By 2011, Google announced it selected Kansas City, Kansas as its target pilot. Fast-forward to 2014, and Google missed its projected city-wide connection deadline in Kansas claiming delays. By 2016, Google publicly commented that all-fiber build outs are proving infeasible due to costs and varying restrictive topologies, consequently filing with the FCC to begin testing wireless broadband internet in 24 cities. Within a few months, they officially acquired a wireless broadband provider and formally announced fixed wireless as part of their Google Fiber network moving forward.

All in all, this case study demonstrates first-hand that to actually close the U.S. digital divide our country must adapt a technology-agnostic mind-set and implement a hybrid-network approach that utilizes whatever technology or technologies makes the most sense for a particular region. Technologies like Fixed Wireless, TV Whitespace, 4G, and Fixed 5G, all have their place, alongside Fiber, in closing the divide. Unfortunately, until those in positions of influence are able to open their minds to these alternative methods, America will remain unconnected.

Who are people in positions of influence?

Luckily, our current FCC administration seems at least semi-understanding that fiber isn’t a “one-size fits all solution”; demonstrated in the recent distribution of funding to WISPs in the CAF II Auction. However, many state and local governments remain less progressive. At a recent California Emerging Technology Fund (CETF) meeting in Sacramento, for example, a large majority of key broadband stakeholders and municipalities advocated that the California Department of Transportation’s (CALTRANS) future infrastructure plans should be wholly fiber-based to support the future of Smart Cities and Autonomous Cars. Whether it be from a lack of education, poor past experiences, or simply riding the buzzword bandwagon, until government organizations can push past common misconceptions that fiber is the only answer, community businesses and residents will be left in the divide.

So, what’s the “Smart” thing to do now?

For those cities in America already connected with reliable multi-gig Internet, go ahead, smart things up! Just keep in mind, to remain a Smart City, even fiber-rich metros will eventually need to extend current network infrastructure to new end points such as light poles, unconnected buildings, and future city expansions.

Ultimately, if we want to collectively prepare for this new revolution, we need to first focus on closing the digital divide. First comes broadband, then comes innovation, then comes the utopian idea of not only Smart Cities, but a smart country.

Smart City - Lexie Smith - GeoLinks

Related Suggested Articles:

Five Crucial Steps Needed To Close The U.S. Digital Divide

Grow Food, Grow Jobs: How Broadband Can Boost Farming in California’s Central Valley

Digital Divide Is Wider Than We Think, Study Says

How Community Anchor Institutions Can Help Close the Digital Divide

Rural service is key to bridging the digital divide

Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band

Before the

Federal Communications Commission

Washington, DC  20554

Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band - GeoLinks

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these reply comments in response to comments filed on the Notice of Proposed Rulemaking (“NPRM”) released in the aforementioned docket.[1]

  1. INTRODUCTION

GeoLinks is the fastest growing Internet and phone provider in America and the fastest growing telecom in California.  In addition, GeoLinks was recently awarded Connect America Fund Phase II Auction funding to serve 3883 Census Blocks in California and Nevada.  The Company has a vested interest in ensuring that the FCC’s policies allow competitive broadband providers to access vital spectrum resources and believes that the 3.7-4.2 GHz band provides opportunity for such access, subject to certain rules and requirements.

  1. DISCUSSION

  2. GeoLinks Supports the BAC’s Proposed Solution to Allow Spectrum Access for Fixed Wireless Providers in the 3.7-4.2 GHz Band

Millions of Americans lack what is considered, by today’s standards, highspeed broadband access – especially in rural areas.  As GeoLinks has previously advocated, sparsely populated rural areas are not well suited for traditional, wired broadband service given the cost to build and deliver a cable/ fiber-based network, often resulting in these areas being left on the wrong side of the digital divide.  However, fixed wireless broadband technology can provide highspeed broadband to consumers in these areas for a fraction of the cost of traditional, wired networks. In addition, fixed wireless providers can (and do in some areas) offer competitive choice to consumers in urban and suburban areas.

Like other fixed wireless providers, GeoLinks’ technology platform depends on access to spectrum resources sufficient to support enterprise-level broadband connections. While spectrum resources do exist that have allowed fixed wireless providers to successfully deploy internet services in some areas, these resources have primarily been available on an unlicensed basis only.  Unlicensed bands are not a one-size-fits-all option as they are often subject to congestion and interference that can degrade wireless signals.

In order for fixed wireless broadband providers to truly compete with traditional, wired service providers, additional spectrum resources are needed. GeoLinks believes the 3.7-4.2 GHz band offers an opportunity for the Commission to allocate spectrum resources in a way that will promote competition and help bridge the digital divide while protecting current users of the band.

The BAC has set forth a “win-win-win solution that: (1) protects incumbent FCC operators from harmful interference; (2) clears a portion of the band for exclusive flexible use licensing; and (3) enables fixed P2MP broadband providers to deploy badly needed high-throughput broadband to unserved and underserved customers.”[2]  GeoLinks believes that this proposed solution strikes the right balance with respect to spectrum sharing, frequency coordination, buildout requirements, and Point-to-Multipoint (“P2MP”) deployment.  As such, GeoLinks supports the opening comments submitted by the BAC in response to the NPRM.

  1. The Commission Should Reject Any Arguments that Fixed Wireless Providers Already Have Access to All the Spectrum Resources They Need

GeoLinks urges the Commission to reject any argument that the spectrum resources that fixed wireless providers have now are “good enough.”  This status-quo mentality is exemplified in comments that appear to suggest that fixed wireless providers have all the spectrum they need or will get it eventually, so there is no need to look to the 3.7-4.2 GHz band for more.  Specifically, the C-Band Alliance explains that “any legitimate requirement for more spectrum for P2MP networks can be met using bands that are either currently available or are being considered for such operations.”[3]

GeoLinks strongly disagrees that fixed wireless providers have enough spectrum already.  As explained above, currently fixed wireless providers primarily have access to only unlicensed spectrum.  In situations where only unlicensed spectrum is available, most connections are limited to point-to-point (“P2P”) connections over short distances to avoid interference with other users.  While fixed wireless providers have had success with these P2P connections, considering them “good enough” fails to account for all of the benefits that the technology couldprovide.  First, even with extensive engineering and coordination, there is no guarantee that interference won’t occur at some point over unlicensed spectrum bands.  This is especially true in densely populated, urban areas where there are numerous users in the unlicensed band.  This interference can make it difficult and costly to engineer a dedicated link to a customer to ensure enterprise-grade broadband service – a service that a fixed wireless provider mustoffer to be competitive in urban markets.  Second, P2P connections require expensive transmission equipment for each link (vs. one for multiple links).  These costs can make it difficult for fixed wireless providers to competitively price broadband services, especially in residential markets where P2P equipment may be cost prohibitive for residential subscribers.

GeoLinks has advocated for the benefits of P2MP services in numerous filings before the Commission.  This technology creates opportunities to connect multiple users in a more cost-effective manner (even if miles apart), making it ideal for serving multiple customers in one area at a lower cost.  Despite the benefits of this technology, however, current spectrum policies hinder fixed wireless providers’ ability to take advantage of it.  For example, P2MP connections are more susceptible to congestion and interference caused from extensive use of the unlicensed bands, especially in urban, highly-populated areas. This makes high-quality P2MP connections over unlicensed spectrum nearly impossible in some areas, clearly refuting the concept that fixed wireless providers have all the spectrum they need.

Moreover, while there are a number of active proceedings before the Commission that may provide fixed wireless providers the ability to access additional licensed, light-licensed, or shared spectrum resources, many of those proceedings are also considering whether specific spectrum bands are better used for other uses (e.g. mobile wireless).  In addition, the outcomes of those proceedings are still very much pending before the Commission and the Commission should not foreclose the option of fixed wireless use in the 3.7-4.2 GHz band just because spectrum might be available in another band at some point.

The BAC’s suggested solution for the 3.7-4.2 GHz band addresses the current spectrum limitations experienced by fixed wireless providers by proposing practical options for P2MP use within the band that will not interfere with existing use by FSS Operators.  The Commission should reject any arguments that fixed wireless providers have enough spectrum now (or will eventually) and therefore the Commission should not consider expanded use of the 3.7-4.2 GHz band.  Instead, GeoLinks urges the Commission to look to implement the BAC’s proposal and adopt spectrum policy that promotes innovation and competition.

  1. The Commission Should Adopt Robust Build-Out Requirements for the Band

As GeoLinks has advocated before, the Company believes that spectrum rights should be subject to robust build-out and “use it or lose it” requirements.  In its opening comments, the BAC supports the NPRM’s 12-month build-out period and proposes other build out requirements including limitations on channel reservation periods, minimum build-out standards for P2MP licensees, and limitations on P2MP spectrum use until build out is complete.[4]  GeoLinks supports these suggested build-out requirements and urges the Commission to adopt them.

  • CONCLUSION

GeoLinks supports the BAC’s opening comments submitted on the NPRM and urges the Commission to adopt its win-win-win proposal for the 3.7-4.2 GHz band.

 

Respectfully submitted,

GEOLINKS, LLC

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 27, 2018

[1]Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Order and Notice of Proposed Rulemaking, GN Docket No. 18-122, FCC 18-91 (rel. July 13, 2018) (“NPRM”).
[2]Comments of the Broadband Access Coalition, GN Docket 18-122 (filed October 29, 2018) (“BAC Comments”) at 3.
[3]Comments of the C-Band Alliance, GN Docket 18-122 (filed October 29, 2018) at 45.
[4]SeeBAC Comments at 25.

Procedures to Identify and Resolve Location Discrepancies in Eligible Census Blocks Within Winning Bid Areas

Before the

Federal Communications Commission

Washington, DC  20554

 

Procedures to Identify and Resolve Location ) WC Docket No. 10-90 Discrepancies in Eligible Census Blocks ) Within Winning Bid Areas

 

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

 

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these reply comments in response to comments filed on the Public Notice released by the Wireline Competition Bureau (“Bureau”) regarding procedures to identify and resolve location discrepancies in eligible census blocks within Connect America Fund Phase II (“CAF II”) winning bid areas on September 10, 2018.[1]

 

  1. INTRODUCTION

Several commenters in the aforementioned proceeding share GeoLinks’ view that the Bureau should create a straightforward process for resolving location discrepancies that may exist in Phase II auction support areas.  GeoLinks believes that such a process is necessary to ensure that CAF II recipients and relevant stakeholders are able to gather and report accurate location-specific data.  As such, GeoLinks makes the following recommendations.

 

  1. DISCUSSION
  2. Prospective Developments

In the Public Notice, the Commission asks whether “actual locations should include prospective developments that have a reasonable certainty of coming into existence within the support term.”[2]  GeoLinks agrees with commenters that ask the Commission not to require CAF II recipients to include prospective developments into the definition of “actual location.”

In both California and Nevada, the states for which GeoLinks has been awarded CAF II funding, there have been many instances where housing developments have been planned, or even started, but then downsized, abandoned, or put on indefinite hold.  While many of these developments do eventually get built, as WISPA notes, there is no guarantee that information regarding new developments will stay constant past the one-year period of determining “locations” or that those plans won’t be modified to increase or decrease the number of housing units, small businesses, etc.[3]  As USTelecom explains, “Providers cannot be omnipresent in local real estate planning over the next year and auditing whether a provider could have, or should have, known about a prospective development would be extremely subjective.”[4] Moreover, other commenters advocate for the Bureau to “permit support recipients to rely on any reasonably current data source” and to avoid “imposing evidentiary burdens beyond those that are strictly necessary.”[5]

For these reasons, GeoLinks urges the Bureau not to requirethat prospective developments be included in the definition of “actual location.”  However, if a CAF II recipient chooses to include prospective developments in its definition of actual locations, GeoLinks agrees with WISPA that it should be allowed to do so if it can provide information to show that specific prospective locations are more likely than not to be constructed and inhabited within the six-year buildout period.[6]

 

  1. Reliability and Validity of Data

In its opening comments, GeoLinks urged the Bureau not to limit broadband providers’ ability to determine what methodology may work best for them to gather information regarding the number of locations within an area so long as the provider can explain that methodology.  This sentiment was echoed by several commenters that offered numerous proposals beyond those methodologies that the Public Notice called “generally accepted.”[7]

US Telecom suggests that providers should be able to rely upon desktop geolocation or automated address geocoding.[8]  WISPA discusses the possibility of aerial imagery (which GeoLinks also suggested in its opening comments) in addition to the possibility of combining the findings from desktop geolocation using web-based maps and imagery with other qualitative criteria such as roof size or other visual evidence.[9] Verizon suggests refining initial analysis with web-based maps or targeted GPS data in the field.[10]  Hughes urges the Bureau to allow recipients to utilize third-party geocoding providers.[11]  Moreover, Commnet, explains that any process to collect required location-specific showings “must account for areas such Tribal Lands where standard street addresses are not available and commercial geocoding data are scant and unreliable.”[12]

GeoLinks believes that the proposal of many different options makes clear that there are many ways for CAF II recipients to verify location data.  So long as a CAF recipient’s selected methodology (or methodologies) can be explained, it should not be precluded from using any reasonable method.  Therefore, GeoLinks continues to urge the Bureau not to limit available methodologies to verify location data.

 

  1. Relevant Stakeholder’s Evidence

With respect to the definition of “relevant stakeholders,” GeoLinks strongly agrees with WISPA that this definition should be limited to individuals, state and local authorities, and Tribal governments, in the relevant supported area.[13]   Additionally, GeoLinks strongly agrees that “the evidence submitted by stakeholders should be the same as is required to be submitted by participants.”[14]  Both GeoLinks and WISPA urge the Bureau to require relevant stakeholders to submit a narrative description of the methodology they used to challenge the location information provided by a CAF II recipient and to certify under penalty of perjury that 1) the location data they are providing is accurate, 2) the stakeholder is located (or represent individuals that are located) within the relevant geographic area, and 3) that the stakeholder is not associated in any way with a competitor.[15]  As WISPA explains, “it should not be sufficient for a stakeholder to solely allegedeficiencies in the participant’s methodology.”[16]

 

  • CONCLUSION

Based on the foregoing, GeoLinks urges the Bureau to adopt the recommendations discussed herein, as agreed to by several parties to this proceeding, regarding procedures to identify and resolve location discrepancies in eligible census blocks within CAF II winning bid areas.

 

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 13, 2018

[1]Public Notice, “Wireline Competition Bureau Seeks Comment on Procedures to Identify and Resolve Location Discrepancies in Eligible Census Blocks Within Winning Bid Areas,” WC Docket No. 10-90, DA 18-929 (rel. Sept. 10, 2018) (“Public Notice”).
[2]Public Notice at 5.
[3]See Comments of the Wireless Internet Service Providers Association, WC Docket 10-90 (filed Oct 29, 2018) (“WISPA Comments”) at 3.
[4]Comments of USTelecom, WC Docket 10-90 (filed Oct. 29, 2018) (“USTelecom Comments”) at 3.
[5]Comments of Verizon, WC Docket 10-90 (filed Oct. 29, 2018) (“Verizon Comments”) at 5 and Comments of Hughes Network Systems, WC Docket 10-90 (filed Oct. 29, 2018) (“Hughes Comments”) at 2, respectively.
[6]WISPA Comments at 3.
[7]SeePublic Notice at 11.
[8]USTelecom Comments at 4.
[9]WISPA Comments at 4-5.
[10]Verizon Comments at 3,
[11]Hughes Comments at 3
Comments of Commnet Wireless, Inc., WC Docket 10-90 (filed Oct. 29, 2018) at 2.
[13]SeeWISPA Comments at 6.  See alsoUSTelecom comments at 5.
[14]WISPA Comments at 7.
[15]SeeWISPA Comments at 6.
[16]WISPA Comments at 7 (emphasis added).

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.

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 https://docs.fcc.gov/public/attachments/DA-18-1121A1.docx.

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.

Disaster Response and Recovery Working Group

FCC ANNOUNCES MEMBERSHIP OF THE BROADBAND DEPLOYMENT ADVISORY COMMITTEE’S DISASTER RESPONSE AND RECOVERY WORKING GROUP - GeoLinksFCC ANNOUNCES MEMBERSHIP OF THE BROADBAND DEPLOYMENT ADVISORY COMMITTEE’S DISASTER RESPONSE AND RECOVERY WORKING GROUP

Read Official Notice here: https://docs.fcc.gov/public/attachments/DA-18-1121A1.docx.

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 https://www.fcc.gov/broadband-deployment-advisory-committee.  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

 

MEMBERS OF THE DISASTER RESPONSE AND RECOVERY

WORKING GROUP

 

Chair:

Red Grasso, FirstNet State Point of Contact

North Carolina Department of Information Technology

 

Vice-Chair:

Jonathan Adelstein, President & Chief Executive Officer*

Wireless Infrastructure Association

 

Members:

 

Skyler Ditchfield, Chief Executive Officer

GeoLinks

 

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

CTIA

 

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

Verizon

 

Frank Korinek, Director of Government Affairs

Motorola

 

Wyatt Leehy, Information Technology Manager

Great Plains Communications

 

David Marshack, Telecommunications Regulatory Lead

Loon

 

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

FirstNet

 

Rocky Vaz, Director of Emergency Management

City of Dallas, Texas

 

Joseph Viens, Senior Director of Government Affairs

Charter

 

Debra Wulff, Public Safety Director

Confederated Tribes of the Colville Reservation