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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

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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.
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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).
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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 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.

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Use of Spectrum Bands Above 24 GHz For Mobile Radio Services

Before the

Federal Communications Commission

Washington, DC 20554

In the Matter of Use of Spectrum Bands Above 24 GHz For Mobile Radio Services

Establishing a More Flexible Framework to Facilitate Satellite Operations in the 27.5-28.35 GHz and 37.5-40 GHz Bands

Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services

Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz for Government Operations

GN Docket No. 14-177

IB Docket No. 15-256

WT Docket No. 10-112

IB Docket No. 97-95

 

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 the Spectrum Frontiers Second Further Notice of Proposed Rulemaking (“Frontiers Second FNPRM”).1

I. INTRODUCTION AND SUMMARY

GeoLinks serves the largest coverage area of any single fixed wireless Internet service provider in California. The Company’s fixed wireless technology platform depends on access to spectrum resources sufficient to support enterprise-level broadband connections. As such, GeoLinks has advocated before this Commission on a number of spectrum matters over the last year. While the proceedings may differ, there are a few over-arching policy considerations that GeoLinks has repeatedly asserted are necessary to ensure robust competition within the broadband marketplace. These include ensuring spectrum resources are available on a competitive basis and ensuring policies do not favor one technology over others. GeoLinks urges the Commission to apply these same considerations to ensure that there is competitive access to the millimeter wave (“mmW”) bands and associated equipment ecosystem.

II. DISCUSSION

A. The Commission Should Retain Pre-Auction Review and Limitations on Spectrum Holdings

GeoLinks strongly agrees with Starry, Inc. (“Starry”) that the Commission must reaffirm competition policies that prevent over-aggregation of critical spectrum resources.2 In the Frontiers Second FNPRM, the Commission proposes to eliminate the pre-auction limit of 1250 Megahertz for the 28 GHz, 37 GHz and 39 GHz bands.3 Limiting spectrum ownership is necessary to carry out the Commission’s mandate of “promoting economic opportunity and competition and ensuring new and innovative technologies are readily accessible to the American people by avoiding excessive concentration of licenses by disseminating licenses among a wide variety of applicants.”4 As Starry explains, spectrum holdings limitations have played an important role in the FCC’s competition policy for decades.5

GeoLinks agrees with Starry that establishing individual bidders’ limits in advance of an auction promotes transparency and provides all bidders with information necessary to facilitate rational bidding. 6 To the contrary, analyzing spectrum holdings after an auction will require winning bidders that exceed the threshold to divest excess spectrum after-the-fact. From a policy perspective, this creates a system where auction winners who have knowingly purchased more spectrum than they are allowed to have, get the opportunity to pick and choose the best spectrum and discard the rest. This creates the need for the FCC to reevaluate what spectrum will be left over after negotiating individual relinquishments and potentially create the need for an additional spectrum auction to license whatever remains in the band. The result is a system in which large incumbents with large amounts of capital are able to secure any spectrum they want with no need to account for what they already have.

Chairman Pai has stated that the Commission “ha[s] no business picking winners and losers in the marketplace.”7 However, creating a policy that allows large carriers to disregard spectrum limits would do just that. As Untied States Cellular Corporation explains, history has shown that unless large carriers are subject to reasonable spectrum acquisition restraints both pre and post-auction, they are likely to pursue mmW spectrum acquisition relentlessly, which will shut out smaller carriers who might otherwise bid on available spectrum.8 For these reasons, GeoLinks urges the Commission to retain pre-auction review and limitations on spectrum holdings.

B. The Commission Must Ensure a Robust Market for Equipment in the 24 GHz Band

In addition to ensuring that new and innovative technologies are capable of accessing spectrum resources, GeoLinks agrees with Starry that the Commission must also ensure “that all licensees in new spectrum bands have access to equipment ecosystems through effective operability requirements.”9 GeoLinks has previously advocated for spectrum policies that allow smaller service providers the ability to leverage market factors to drive down the cost of equipment. Unlike large incumbent carriers, smaller service providers lack the market power to ensure affordable equipment is available for all spectrum bands. As Starry explains, without operability requirements, these large carriers will be incentivized to inhibit competitive access to network equipment and devices. 10 This may result in underdevelopment of the band, a problem that the Commission has been dealing with in the 700 MHz band for years.11 For these reasons, GeoLinks urges the Commission establish operability requirements in the 24 GHz band.

C. The Commission Should Allow Sharing in the 37-37.6 GHz Band

In its opening comments, CTIA advocates for reconsideration of the Commission’s decision to allocate the 37-37.6 GHz Band on a coordinated basis.12 Specifically, CTIA urges the Commission to make this band available on a licensed basis claiming that an experimental sharing regime would be premature.13 However, GeoLinks believes that it is premature to suggest that the Commission close this band off to experimental use when mobile carriers themselves are not able to state explicitly how much spectrum them will need to roll out their 5G services.14 Instead, GeoLinks urges the Commission to finalize rules for shared access to the 37-37.6 GHz band to allow new technologies an opportunity to access these spectrum resources.

III. CONCLUSION

In conclusion, GeoLinks urges the Commission to ensure that there is competitive access to the mmW bands and associated equipment ecosystem by creating policies that ensure spectrum resources are available on a competitive basis without favoring one technology over others.

 

Respectfully submitted,

GEOLINKS, LLC

/s/ Skyler Ditchfield, Chief Executive Officer

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

February 22, 2018

 

1. Use of Spectrum Bands Above 24 GHz, et al., Second Report and Order, Second Further Notice of Proposed Rulemaking, Order on Reconsideration, and Memorandum Opinion and Order, 32 FCC Rcd 10988 (2017) (“Frontiers Second FNPRM”).
2 See Comments of Starry, Inc., GN Docket No. 14-177, et al. (filed Jan. 23, 2018) (“Starry Comments”), at 2.
3 Frontiers Second FNPRM at para. 105
4 See Section 309(j) of the Communications Act of 1934, as amended.
5 See Starry Comments at 2.
6 See Starry Comments at 3.
7 See Ajit Pai, Chairman, FCC Remarks on Restoring Internet Freedom (Nov. 28, 2017) (“We have no business picking winners and losers in the marketplace”).
8 See Comments of United States Cellular Corporation, GN Docket No. 14-177, et al. (filed Jan. 23, 2018), at 8.
9 Starry Comments at 5.
10 See Starry Comments at 5.
11 See Id.
12 Comments of CTIA, GN Docket No. 14-177, et al. (filed Jan. 23, 2018), at 10.
13 See Id.
14 See Comments of Verizon, GN Docket No. 14-177, et al. (filed Jan. 23, 2018), at 5, “It is too early to know how much bandwidth operators will need to provide customers with innovative 5G services.”
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Promoting Investment in the 3550-3700 MHz Band

Before the

Federal Communications Commission

Washington, DC  20554

 

In the Matter of

Promoting Investment in the 3550-3700 MHz Band

GN Docket No. 17-258

 

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 and Order Terminating Petitions (“Notice and Order”) issued October 24, 2017.

I. INTRODUCTION AND SUMMARY

As noted in its opening comments, GeoLinks understands that the 3.5 GHz Band is gaining traction as “one of the core mid-range bands for 5G network deployments throughout the world” and acknowledges that any rules the Commission develops for this band will be primarily for 5G mobile wireless use.[1]  However, this band has propagation characteristics that make it optimal for other wireless technologies that can be deployed quickly to start closing the digital divide.

Sparsely populated rural areas are not well suited for traditional, wired broadband service given the cost to build and deliver a cable/ fiber-based network.  However, fixed wireless broadband technology can provide high-speed broadband to consumers in these areas for a fraction of the cost.  For this reason, it is imperative that spectrum resources be allocated in ways that allow fixed wireless ISPs to deploy services to these regions.

Chairman Pai has stated that the Commission “ha[s] no business picking winners and losers in the marketplace.”[2]  Therefore, the Commission must be careful to avoid creating spectrum policies that favor some technologies over others.  Currently, mobile wireless carriers have ample spectrum resources available to them.  However, smaller providers struggle to acquire even a fraction of what these large carriers already have.  For these reasons, GeoLinks urges the Commission to develop rules for the 3.5 GHz Band that support 5G deployment without closing off the band to other uses, such as fixed wireless service.

II. DISCUSSION

A. PAL Allocation Should be Done in a Way that Promotes Efficient Spectrum Use in Both Urban and Rural Areas

GeoLinks has consistently urged the Commission to consider the unique characteristics of rural vs. more populated urban areas when determining how those areas should be licensed to ensure the most efficient use of the spectrum.  To achieve this goal, GeoLinks makes the following suggestions with respect to PAL license areas and license terms.

As an initial matter, in reviewing comments filed in this docket and assessing the unique characteristics of the license areas that GeoLinks would seek to apply for, the Company believes that PALs at the county-level may strike a balance between PEAs and census tracts.  As Open Technology Institute at New America and Public Knowledge (“OTI & PK”) explains, many PEAs include both major metropolitan markets and rural areas, that may include hundreds of small towns.[3]  For example, PEA 2 in California has a population of nearly 20,000 while PEA 192 has a population of just over 300,000.[4]  In these situations, it makes little sense to treat all PEAs the same for the purposes of allocating spectrum licenses.

Meanwhile, GeoLinks agrees with commenters that census tracts are too small for general PAL assignments.[5]  In part, this is because wireless network areas are difficult to limit to census tract boundaries in urban areas (where census tracts are smaller than in rural areas).  Many times, depending on specific engineering, a fixed wireless transmitter will have the capability to extend a wireless broadband signal several miles, often covering numerous census tracts, especially in urban areas.  Assignment of PALs at the census tract level in urban areas could lead to carrier interference between PAL license areas and the need for expensive management processes to avoid such interference.  As NCTA points out, by reducing the total license areas from 74,000 census tracts to approximately 3,150 counties, the Commission would significantly simplify license management burdens and border coordination issues.[6]  GeoLinks is inclined to agree that county-sized licenses would also support rural deployment better than PEAs.[7]

Many commenters assert that counties are still too large and that awarding PAL licenses on a county-basis will stifle the ability for smaller carriers to obtain PALs in the 3.5 GHz band and will not promote deployment to rural areas.  GeoLinks believes that if PALs are awarded at the county level, subject to strict buildout requirements (as discussed in further detail below), and if the FCC establishes robust relinquishment, partition and/ or disaggregation rules, large carriers only looking to serve a small portion of a county will either seek out other spectrum resources or engage in secondary market agreements quickly within PAL areas.

While GeoLinks supports the idea of PALs being issued at the county-level, generally, the Company still recognizes that counties may not present a perfect option for all parts of the country and urges the Commission to consider the unique characteristics of rural vs. more populated areas when determining final license areas.  Just as PEAs differ in size and population, so do some counties.  Especially in California, counties can consist of large metropolitan areas and vast stretches of rural areas.  In these counties, GeoLinks supports the adoption of a hybrid approach but agrees with NCTA that “the Commission should carefully evaluate prospective solutions to ensure that they would meet the Commission’s substantive goals.”[8]

In addition to allocation by county (or hybrid approach in rural areas), GeoLinks supports a longer PAL license term.  As explained in its opening comments, the Company believes that longer terms will allow license holders time to better utilize the spectrum.  Specifically, the expectation of extended use of a specific band of spectrum creates certainty that will allow PAL holders to work with equipment manufacturers to develop and produce new equipment at lower costs.  These lower costs will, in turn, allow license holders to invest more resources into their networks to promote higher speeds, additional roll out, etc.  Shorter license periods, however, will have the opposite effect.  As AT&T points out, the current three-year license term (paired with no right of renewal), creates the risk that PAL licensees will face stranded investments.[9]  As T-Mobile notes, a ten-year term “would afford each licensee sufficient time to design and acquire the necessary equipment and devices and to deploy facilities across the license area.”[10]

Rural Wireless Association (“RWA”) asserts that “lengthening the PAL license term to ten years will result in spectrum lying fallow in rural areas and further deprive small and rural providers of access to protected 3.5 GHz.”[11]  GeoLinks agrees that without the appropriate checks and balances, this could be a risk.  Specifically, GeoLinks agrees with NCTA that longer, renewable terms also require appropriate performance obligations.[12]  GeoLinks asserts that PAL licensees must be subject to strict build out and reporting requirements (as discussed in further detail below).  If a license holder fails to meet these robust buildout requirements, the remaining portion of the PAL area should be subject to relinquishment, partition and/ or disaggregation to allow another service operator the opportunity to utilize the PAL for the remainder of the PAL license term.  When the PAL license term expires, the secondary PAL license holder(s) should get the first right of renewal for the PAL areas held.

B. The Commission Should Ensure Adequate PAL Allocation Among Technology Types to Promote Competition

Section 309(j) of the Communications Act of 1934 directs the Commission to promote “the development and rapid deployment of new technologies, products, and services for the benefit of the public,” while “disseminating licenses among a wide variety of applicants” and “avoiding excessive concentration of licenses.”[13]  As Google explains, with the right rules, PAL spectrum can support both established wireless and new investors with novel business models.[14]  GeoLinks agrees that “opening PAL spectrum to a wider set of potential licensees advances greater overall intensity of use, supports additional economic activity, and avoids the hazards that follow when government auction rules artificially limit access to spectrum that otherwise would support many business models.”[15]

GeoLinks asserts that PALs should be assigned in a way that ensures a mixture of technologies are able to utilize the 3.5 GHz Band.  One way in which the Commission can ensure competition within the 3.5 GHz Band is by keeping its existing spectrum aggregation limit in place.  While AT&T urges the elimination of the 40 MHz spectrum aggregation limit,[16] GeoLinks maintains that allocating more than 40 MHz of spectrum to one PAL holder will essentially close off the band to any other provider that could use that spectrum to provide high-speed broadband service.[17]  Moreover, allocating more than 40 MHz to one PAL holder that is not positioned to utilize the band immediately (e.g. a mobile wireless carrier planning to utilize the band for future 5G services) could mean that the 3.5 GHz Band would not be utilized fully for an indefinite amount of time.  GeoLinks agrees with OTI & PK that package bids be limited to three or at most four of the PALs (30-40 MHz).[18]

C. The Commission Cannot Solely Rely on Secondary Markets to Avoid Spectrum Warehousing or Underutilization of Spectrum in the 3.5 GHz Band

AT&T asserts that “allowing for partitioning and disaggregation will alleviate concerns that licensing on a PEA basis will result in underutilized spectrum.”[19]  However, as Google explains, “history confirms that the Commission’s partitioning and disaggregation rules, while sound, cannot be relied upon to promote access to spectrum for non-traditional or rural licensees. According to Commission records, the large wireless carriers who typically win mobile-ready spectrum in auctions only rarely engage in secondary market transactions with smaller entities, much less entities other than established telecommunications companies.”[20]

GeoLinks agrees with numerous commenters that the FCC cannot rely on the secondary marketplace alone if PALs are granted for larger geographic areas.[21]  However, GeoLinks believes that the secondary marketplace is a viable solution IF PALs are subject to strict build out and reporting requirements and the threat of forced relinquishment, partition and/ or disaggregation for failure to meet those requirements.

In developing policies surrounding allocation of PAL licenses in the 3.5 GHz band, GeoLinks urges the Commission to develop strict buildout and reporting requirements for PAL licensees.  As stated in its opening comments, the Company suggests that the Commission require license holders to provide status updates regarding their deployment/ network improvements within the 3.5 GHz Band by census block and reporting on a quarterly basis for the first year of the initial license period or renewal and annually thereafter.[22]

With respect to buildout metrics, GeoLinks strongly opposes T-Mobile’s proposal that the Commission adopt a performance requirement of coverage to only 40% of the population for licenses in the 3.5 GHz band.[23]   As OTI & PK notes, if build-out requirements are based on population, mobile carriers would satisfy them simply by building out almost solely in the high-density and/ or high-ARPU areas where the economic returns justify putting spectrum to work.[24]   GeoLinks asserts that the Commission must create buildout requirements that ensure the 3.5 GHz band is utilized in all areas of the PAL license areas, regardless of population density.  Failure to implement such requirements will only serve to ensure that large swaths of spectrum go unused; a concept that runs contrary to the Commission’s efforts to close the digital divide.

As stated in GeoLinks’ opening comments, minimum buildout requirements should be set high enough to ensure that unserved areas (if applicable) within the license area are not left behind.[25]  As such, GeoLinks suggests that the Commission implement buildout requirements based on locations within the PAL license area.

Moreover, the Commission should establish robust relinquishment, partition, and disaggregation processes for situations where buildout requirements are not met.  Similar to the RWA’s suggestion that unused PAL areas should be subject to a “keep-what-you-serve” standard at the time of renewal, GeoLinks suggests that this be taken a step further to ensure anything unserved within a reasonable time (i.e. one year from PAL assignment) can become available for reassignment by the Commission.[26]

GeoLinks believes that these buildout and reporting requirements, pair with a relinquishment, partition, and disaggregation process will ensure that large carriers either refrain from bidding on PAL areas in which they know they cannot or will not meet the build out requirements or ensure that these carriers seek out options for partitioning a portion of the PAL to another carrier expeditiously (before buildout requirements kick in).  However, in advocating for these safeguards, GeoLinks asserts that PAL holders should not be able to set the price or terms for transferring unused spectrum to an interested party.  GeoLinks firmly believes that if a PAL holder is not willing to utilize the 3.5 GHz Band throughout the entire license area or does not meet certain mandatory buildout requirements (such as those suggested above), the holder should not reap a benefit.

D. If the Commission Utilizes an Incentive Auction to Assign PAL Licenses in the 3.5 GHz Band, it Should Create a Process to Ensure All Types of Service Providers Can Participate

GeoLinks has previously advocated that incentive auctions should not be the preferred mechanism for determining how spectrum is licensed in all bands.[27]  This is because incentive auctions tend to only benefit large companies with large amounts of capital to spend and incentivize bidders to purchase spectrum resources as an asset for future use rather than for immediate use.  This process, while not necessarily designed to, picks “winners and losers” by creating a playing field that only a limited number of parties can participate in.  GeoLinks understands that the Commission will likely utilize the auction process to license PALs in the 3.5 GHz band.  In light of this, and to ensure that PAL licenses can be obtained by “both established wireless and new investors with novel business models,”[28] GeoLinks recommends that the Commission establish a set of bidding credits designed to put potential bidders on equal footing.  Some suggestions for bidding credits include the following.

i. Small Service Provider Bidding Credit

Many small and mid-sized service providers lack the large amounts of capital generally necessary to compete in spectrum incentive auctions leaving them behind and unable to compete with larger carriers in the same spectrum bands.  This disadvantages rural areas where many of these small and mid-sized carriers operate (and wish to invest in additional broadband deployment).  In order to put these smaller operators on equal footing with larger operators, GeoLinks suggests a generous bidding credit for carriers with fewer than 10,000 customers.[29]

ii. Rural Broadband Bidding Credit

GeoLinks believes that the 3.5 GHz band is well suited for a multitude of rural broadband services that will help in the Commission’s goal of closing the digital divide.  However, this will only occur if the policies surrounding allocation of the 3.5. GHz band PALs are crafted in a way that encourages such deployment.  This includes giving smaller service providers, that may focus their service offerings on rural areas, opportunities to obtain spectrum sufficient to offer high speed broadband to these areas – smaller providers that likely do not have the capital that the large mobile carriers do in order to afford such spectrum.  GeoLinks suggests that the Commission create a generous bidding credit for service providers that commit to serve rural areas within the PAL license area.  Specifically, GeoLinks suggests that those service providers that bid on rural areas, including areas containing CAF II Auction eligible areas, and commit to serving a certain number of locations within such area be given such a bidding credit.  The Company also suggests that such bidding credits be subject to ongoing reporting regarding rural service deployment over the 3.5 GHz band.

iii. Connect America Fund Phase II Awardee Bidding Credit

In its opening comments, GeoLinks proposed that Connect America Fund Phase II (“CAF II”) awardees (or, depending on timing, CAF II applicants that pass the short form phase of the application process) that rely on spectrum resources be allowed “first crack” at a PAL covering applicable eligible areas.[30]  GeoLinks believes that this “first crack” could be in the form of a bidding credit applicable towards PALs in the 3.5 GHz Band.  As awardees will already be committing to serve 95% of rural locations within eligible CAF II areas, this credit could be paired with the rural bidding credit.

iv. Wholesale Bidding Credit

Another bidding credit GeoLinks suggests is a credit for those PAL holders that are willing to offer access to PAL spectrum on a wholesale basis to other service providers, either in the same areas as the PAL holder offers its services or in areas throughout the PAL license areas where the PAL holder cannot or does not wish to deploy services.

v. PAL Awardee Payment Options

In addition to the bidding credits set forth above, and any others the Commission may determine are in the public interest, GeoLinks suggests that the Commission implement a process by which smaller PAL recipients can pay for their spectrum licenses in installments over the length of the PAL period.  This will allow bidders with less upfront capitol to expend on spectrum (generally small and mid-sized carriers) to acquire and pay as the spectrum is utilized and services are deployed.  GeoLinks suggests that failure of a PAL recipient to make timely payments under such a payment option should result in relinquishment or forced relinquishment, partition and/ or disaggregation.  GeoLinks suggests that applicants who qualify for the “small Service Provider” bidding credit, for example, should qualify for extended payment.

III. CONCLUSION

In conclusion, GeoLinks urges the Commission to adopt rules with respect to spectrum licensing in the 3.5 GHz band that do not close off the band to fixed wireless service providers, ensure efficient use of the band, and promote broadband deployment and competition in both urban and rural areas.

 

Respectfully submitted,

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

January 29, 2018

[1] Notice and Order at para. 2.
[2] See Ajit Pai, Chairman, FCC Remarks on Restoring Internet Freedom (Nov. 28, 2017) (“We have no business picking winners and losers in the marketplace”).
[3] See Comments of Open Technology Institute at New America and Public Knowledge, GN Docket No. 17-258 (filed Dec. 28, 2017), at 23 (“OTI & PK Comments”).
[4] Data based on 2010 Census data, available at https://www.fcc.gov/oet/maps/areas (last visited January 29, 2018).
[5] See generally Comments of AT&T Services, Inc., GN Docket No. 17-258 (filed Dec. 28, 2017) (“AT&T Comments”), Comments of United States Cellular Corporation, GN Docket No. 17-258 (filed Dec. 28, 2017), Comments of Mobile Future, GN Docket No. 17-258 (filed Dec. 28, 2017), Comments of T-Mobile USA, Inc., GN Docket No. 17-258 (filed Dec. 28, 2017) (“T-Mobile Comments”), etc.
[6] Comments of NCTA – the Internet & Television Association, GN Docket No. 17-258 (filed Dec. 28, 2017), at 4 (“NCTA Comments”).
[7] Id. at 5
[8] Id. at 9.
[9] AT&T Comments at 3, citing Comments of Ericsson, GN Docket No. 12-354 (filed July 24, 2017), at 6.
[10] T-Mobile Comments at 4, citing the Notice and Order at para 13.
[11] Comments of the Rural Wireless Association, GN Docket No. 17-258 (filed Dec. 28, 2017) at 7 (“RWA Comments”).
[12] See NCTA Comments at 13.
[13] 47 U.S.C. §309(j)(3).
[14] Comments of Google LLC, GN Docket No. 17-258 (filed Dec. 28, 2017), at 2 (“Google Comments”).
[15] Id. at 3; see also NCTA Comments at 4, “NCTA continues to believe that the Commission should design its licensing rules in this innovation band to enable investment by a wide variety of market participants.”
[16] AT&T Comments at 7.
[17] See Comments of GeoLinks, GN Docket 17-258 (filed Dec. 28, 2017) at 3 (“GeoLinks Comments”).
[18] See OTI & PK Comments at 6.
[19] AT&T Comments at 8
[20] Google Comments at 19.
[21] See e.g. Comments of the General Elective Company, GN Docket No. 17-258 (filed Dec. 28, 2017), at 23 and OTI & PK Comments at 22.
[22] GeoLinks Comments at 4.
[23] T-Mobile Comments at 7.
[24] OTI & PK Comments at 20.
[25] GeoLinks Comments at 5.
[26] See RWA Comments at 10.
[27] Reply Comments of GeoLinks, GN Docket N. 17-183 (filed Nov. 15, 2017), at 3.
[28] Google Comments at 2.
[29] This suggestion goes beyond the bidding credits implemented in 600 MHz Band (Incentive Auction), See Updating Part 1 Competitive Bidding Rules et al., WT Docket No. 14-170 et al., Report and Order, 30 FCC Rcd 7493 (2017).  GeoLinks is open to other metrics for determining what is considered a “small service provider” but believes that the metric should be smaller than what was proposed for the 600 MHz Band or that the bidding credit should increase incrementally the fewer customers a service provider has.
[30] GeoLinks Comments at 7.
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Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz

Before the

Federal Communications Commission

Washington, DC 20554

In the Matter of

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

GN Docket No. 17-183

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

California Internet, L.P. dba GeoLinks, LLC (“GeoLinks” or the “Company”) submits these reply comments in response to certain comments filed on the Notice of Inquiry (“NOI”) issued August 3, 2017 in the aforementioned docket.

Additional flexible access to mid-band spectrum would allow broadband providers to leverage wireless technologies to fill the gaps in the current broadband landscape. Fixed wireless technologies offer new opportunities to connect rural and unserved communities and offer competitive alternatives to incumbent providers in urban settings. GeoLinks submits these reply comments to provide input on potential opportunities for additional flexible access to mid-band spectrum.

DISCUSSION
Rules for the 3.7-4.2 GHz Band Should Be Changed to Promote Point-to-Multipoint Wireless Broadband Service
As explained in its opening comments, GeoLinks urges the Commission to structure a flexible use regime that will allow small and mid-sized wireless broadband providers to utilize mid-band spectrum for point-to-multipoint (“P2MP”) wireless broadband service. As commenters explain, the​ ​3.7–4.2​ ​GHz​ ​band​ ​is​ especially ​well-suited​ ​to​ ​support​ P2MP​ ​broadband​ ​access.[1] However, rule changes are needed to allow for this type of use in the 3.7-4.2 band.

GeoLinks agrees with commenters that the Commission should change its “full-band, full-arc” policy for licensing satellite earth stations.[2] As Microsoft states, the Commission “should initiate a process to update its rules regarding FSS earth stations so that they are protected only to the extent necessary to protect them from receiving harmful interference.”[3] More specifically, GeoLinks supports the BAC’s recommendation that the Commission could “modify its rules to permit FSS operators to retain their current licenses to operate across the entire 3700 – 4200 MHz band, but limit interference protection to the frequencies on which the earth station is actually operating at a given time.”[4] GeoLinks also supports commenters’ recommendation to clean up the FSS database.[5] If the database does reflect FSS earth stations that were never built or no longer exist, as asserted by several commenters, failure to update the information only serves to further limit use of the 3.7-4.2 GHz band.

The 3.7-4.2 GHz band Should Not Be Reserved for Mobile Wireless Use Only
GeoLinks disagrees with commenters that advocate that the 3.7-4.2 GHz band should be solely allocated for mobile wireless broadband use.[6] As an initial matter, GeoLinks fails to see how this type of allocation would help meet the Commission’s goals of expanding broadband deployment to unconnected Americans (especially in rural areas). As GeoLinks explains in its opening comments, P2MP connections offered via fixed wireless broadband service create opportunities to connect multiple users from one transmission point. With the appropriate spectrum allocation, fixed wireless providers can offer up to Gigabit+ P2MP connections of identical quality to fiber connections for a fraction of the cost.[7] This is something that cannot yet be accomplished over mobile broadband connections.

Additionally, allocation of this band for mobile wireless providers may not provide an immediate benefit to consumers like allocation for P2MP services would. T-Mobile states in its comments that designation of the 3.7-4.2 GHz band for mobile broadband would “complement wireless carriers’ use of spectrum in adjacent bands.”[8] T-Mobile further states that some of this adjacent band spectrum “may be made available in the future.”[9] Moreover, Verizon explains that this band “can support the high bandwidth carriers required for data-heavy 5G services”[10] – a future technology that is still years from full deployment. While adjacent bands do promote efficiencies, the efficiencies touted by certain commenters are too forward looking to base spectrum policy for this band on at this time. A policy of setting aside rare spectrum resources for prospective purposes when they could be utilized immediately to connect underserved areas promotes inefficiency and runs contrary to the Commission’s goals of closing the digital divide. Instead, GeoLinks urges the Commission to create spectrum sharing policies for this band that will promote the deployment of highspeed P2MP broadband services.

An Auction Mechanism is Not Appropriate for Mid-Band Spectrum
Some commenters advocate that spectrum licenses in the mid-band should be offered via an incentive auction.[11] While auctions are effective for some spectrum bands, GeoLinks maintains its position that an auction mechanism is not appropriate for mid-band spectrum. First, incentive auctions tend to only benefit large companies with large amounts of capital to spend. Small to mid-sized fixed wireless providers have the potential to offer highspeed broadband services that can meet the Commission’s speed and deployment goals for a fraction of the cost of traditional, fiber-based service providers. Therefore, GeoLinks emphasizes that any spectrum licenses granted in the mid-band spectrum should be granted on a basis that will allow these companies to obtain and utilize them. Second, as discussed above, auctions incentivize bidders to purchase spectrum resources as an asset for future use rather than for immediate use.[12] To meet the Commission’s broadband deployment goals, spectrum policies should be developed in a way that promotes connectivity immediately.

GeoLinks urges the Commission to grant spectrum licenses for the mid-band in a way that immediately promotes efficient use and deployment of highspeed broadband services. Specifically, GeoLinks urges the Commission to use a “light licensed” or Part 101-type licensing structure, especially with respect to the 3.7-4.2 GHz band.

CONCLUSION
In conclusion, GeoLinks urges the Commission to develop spectrum policy for the mid-band spectrum that allows for the effective deployment of P2MP wireless broadband technologies.

Respectfully submitted,

GEOLINKS, LLC

/s/ Skyler Ditchfield, Chief Executive Officer

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

[1] See Comments of the Broadband Access Coalition (“BAC”), GN Docket No. 17-183 (filed Oct. 2, 2017) (“BAC Comments”), at 1. See also Comments of Google LLC and Alphabet Access, GN Docket No. 17-183 (filed Oct. 2, 2017) (“Google Comments”), at 2.
[2] See Comments of Microsoft Corporation, GN Docket No. 17-183 (filed Oct. 2, 2017) (“Microsoft Comments”), at 3. See also BAC Comments at 8, and Comments of Verizon, GN Docket No. 17-183 (filed Oct. 2, 2017) (“Verizon Comments”), at 12.
[3] Microsoft Comments at 3.
[4] BAC Comments at 8.
[5] See Google Comments at 4-5 and Microsoft Comments at 3-4.
[6] Comments of T-Mobile USA, Inc., GN Docket No. 17-183 (filed Oct. 2, 2017) (“T-Mobile Comments”), at 7. See Comments of CTIA, GN Docket No. 17-183 (filed Oct. 2, 2017) (“CTIA Comments”) at 6.
[7] Specifically, spectrum allocation of at least 250 MHz in the mid-band would be ideal for these connections.
[8] T-Mobile Comments at 10.
[9] Id.
[10] Verizon Comments at 14.
[11] See CTIA Comments at 5. See, generally, T-Mobile Comments.
[12] See FN 9, supra.

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