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Comments to Consider Modifications to the California Advanced Services Fund

BEFORE THE
CALIFORNIA PUBLIC UTILITIES COMMISSION

Order Instituting Rulemaking to Consider
Modifications to the California Advanced Services Fund.
Rulemaking No. 12-10-012 (Filed October 25, 2012)

 

OPENING COMMENTS OF CALIFORNIA INTERNET, L.P. (U-7326-C) DBA

GEOLINKS ON PROPOSED DECISION OF COMMISSIONER GUZMAN ACEVES

IMPLEMENTING THE CALIFORNIA ADVANCED SERVICES FUND

INFRASTRUCTURE ACCOUNT REVISED RULES

November 29, 2018 

Pursuant to Rule 14.3 of the Commission’s Rules of Practice and Procedure, California Internet, L.P. (U-7326-C) dba GeoLinks (“GeoLinks” or the “Company”) respectfully submits these comments on the on the Proposed Decision of Commissioner Guzman Aceves, entitled “Decision Implementing the California Advanced Services Fund Infrastructure Account Revised Rules” (“Phase II PD”), released on November 9, 2018.

GeoLinks limits these comments to one section of the Phase II PD regarding the Ministerial Review process (Section 2.3). In the Phase II PD, while the Commission acknowledges GeoLinks’ concerns regarding the lack of technology neutrality present in the proposed ministerial review process with respect to the maximum price per household for fiber projects vs. fixed wireless projects, the Commission fails to actually make the process technology neutral. Specifically, while the Phase II PD does lower the maximum amount per household eligible for ministerial review for fiber projects (from $8,000 to $6,000 per household), the number is still inextricably several thousand dollars more than the threshold for fixed wireless projects ($1,500 per household).

The Phase II PD fails to provide any rationale for the thresholds proposed or even attempt to explain why the proposed fiber threshold is $4,500 per household higher than the proposed fixed wireless threshold. GeoLinks assumes these numbers are based on averages taken from previously-approved CASF projects, but this is not clear. For example, while the CASF Annual Report for 2016 explains that the average of 15 CASF fiber projects is $9,442, inclusive of middle mile costs, the Phase II PD does not address this average in any way, explain how the new $6000 may or may not be related to it. The Phase II PD is completely silent as to how the proposed thresholds were conceived, what they may or may not be based on, or why they can’t be the same for both technology types.

Moreover, while the Phase II PD does note that the ministerial thresholds do not preclude fixed wireless projects from being awarded grants that fall outside the ministerial cost criteria, it makes very clear that these projects (even if still significantly less per household than proposed fiber projects that may offer the same speed to the same areas) must go through the Commission’s Resolution process (which is presumably longer and requires a Commission decision). GeoLinks asserts that 1) creating separate thresholds for separate technologies that offer the same service, 2) requiring one technology to endure a procedural process that another would not for what might otherwise be an identical proposed project, 3) and failing to provide any explanation for why the cost threshold or the path to approval is different for one technology over another are examples of bad public policy. In all, the Commission’s retention of differing thresholds for fiber projects vs. fixed wireless projects in direct opposition to the Commission’s goal of administering the CASF program on a “technology neutral” basis and should be rejected.

GeoLinks urges the Commission to create one ministerial threshold for all technology type. Specifically, GeoLinks suggests $4000 to create some balance between the currently inequity of $6000 (fiber) vs. $1500 (fixed wireless).

Respectfully submitted,

/s/ Melissa Slawson
Melissa Slawson
General Counsel, V.P. of Government Affairs and Education
California Internet, L.P. dba GeoLinks
251 Camarillo Ranch Rd
Camarillo, CA 93012

November 29, 2018

[1] California Advanced Services Fund: A Program to Bridge the Digital Divide in California, Annual Report January 2016 – December 2016 (issued April 2017) at page 43, FN 51.
[1] Interim Opinion Implementing California Advanced Services Fund, Decision 07-12-054 (rel. December 20, 2007), at 8: “The CASF shall be administered on a technology neutral basis by the Commission.”  See also Id. At 28: “CASF funding proposals will be reviewed based upon how well they meet the criteria for selection as set forth below, and, where applicable, compared with any competing claims to match the deployment offer under superior terms. Such criteria should be evaluated on a competitively neutral basis.” (Emphasis added).
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Wireless Smart Farming to Keep Frost Away From Citrus

Wireless Smart Farming to Keep Frost Away From Citrus

UCSB SmartFarm sensor approximately 5 feet off the ground surrounded by citrus will help UC researchers know when to turn on windfans to protect plants from frost.

By Susan Rambo.

Computer science researchers from the University of California, Santa Barbara, are using the internet of things to prove that smart farming can be a farm implement as basic as the tractor and plough.

The husband and wife team of Chandra Krintz and Rich Wolski, both UCSB computer science professors, think data analytics can help tackle some of the tough challenges of modern agriculture. They want to apply the predictive mathematical leaps used in modern internet commerce to predict what people will buy, to agriculture. The pair created the UCSB SmartFarm program in response to what they see as the main issues of agriculture.

Krintz and Wolski cite U.S. Department of Agriculture and United Nations Food and Agriculture Organization studies that say some scary stuff: increasingly more food is needed to feed the growing global population, and yet farm labor is in short supply or too expensive. Eighty percent of the fresh water and 30% of global energy is used to produce food, half of which we waste in spoilage. Farming also has some particularly tough foes: Pests and disease attack farms’ output and farm land is subsiding (sinking) — especially in California — because of groundwater overdraft. On top of all that, agriculture makes 22% of greenhouse gases.

The only way smart farming can make a dent on those issues is to attack specific problems. For Krintz and Wolski’s first test projects, they talked to the farmer — in this case, farm researchers — first before designing a system. Although almost every ag tech pitch begins with a summary of those issues, the UCSB computer scientists’ approach is to come up with scientifically vetted data about the usefulness of cloud and data analytics in farming.

The design parameters of behind UCSB SmartFarm’s Farm Cloud System is to make a system a farmer could love: it should be easy to use and work reliably, cheaply and privately — farmers don’t want their data accessible. The system needs to provide useful data to help increase yield, automate farm operations or save money (or all three), and the data must be available real time. The whole thing has to work without IT staff.

The self-managing system needs to work like an appliance, like your refrigerator, write Krintz and Wolski in a presentation about the project.

Krintz and Wolski are testing the system on nut trees at Fresno State and on citrus at the University of California’s Lindcove Research and Extension Center (LREC) near Visalia, Calif. The UCSB SmartFarm program has support from Google, Huawei, IBM Research, Microsoft Research, the National Science Foundation, National Institutes of Health and the California Energy Commission.

RCR Wireless News visited the LREC — a literal test bed for citrus and smart farming — and got the full tour of the UCSB’s Farm Cloud System.

Lindcove’s research mandate

The public is probably not aware that agricultural research centers, such as LREC (Lindcove), do the hard science that protects our food. In the case of Lindcove, hard science is the study of mostly citrus trees, and it means the grueling work of studying each tree.

Dr. Beth Grafton-Cardwell, research entomologist, an integrated pest management (IPM) specialist and Lindcove’s director remembers sorting fruit by hand.

“When I first started in 1990, if we harvested in January, we would stand in the field in our long underwear and they would pick fruit into a bin and we would have ring sizers that told us what size the fruit was. We would count the fruit and size the fruit and write it on a clip board on a piece of paper,” she said. “Now this machine can do this better.”

Standing near a huge packing line machine that dwarfed her, Grafton-Cardwell explained how the cameras and the extra sensors enable the machine to size and weigh the fruit, examine the outside of the fruit using three types of cameras and estimate the sugar levels inside. One piece of fruit goes through the machine at a time, for scientific purposes, which differs from how a normal packing house operates.

“If I am a researcher, each of my trees is a replication and a different situation, so I want to know everything there is to know about the fruit on that tree,” said Grafton-Cardwell. The cameras take about 30 photographs of each piece of fruit, rotating the fruit as they go. Every parameter from each piece of fruit is put into a spreadsheet: “We know the size, the shape, if it has scarring, the precise color,” said Grafton-Cardwell.

The growers paid for Lindcove’s packing line. “We can simulate anything you want to do on a commercial pack line,” said Grafton-Cardwell. Most packing houses have these machines but don’t use them the way researchers do. They use them for sorting fruit, not for collecting the precise data the researchers need.

“You have to train the machine to the colors and the blemishes. It can get overwhelming,” said Kurt Schmidt, Lindcove’s principal superintendent of agriculture. “We can slow everything down and gather an infinite amount of data.”

“The data sets are ginormous,” Grafton-Cardwell pointed out. Data and an interpretation of the data is the really the product that Lindcove produces.

Originally started in 1959 by University of California Riverside and San Joaquin Valley citrus growers, Lindcove helps growers try out treatments and crop varieties without experimenting on their own crops, which protects their orchards — and livelihood. “Researchers from around the state can come here and do experiments,” said Grafton-Cardwell. Lindcove focuses on creating new varietals and demonstrating gardens of hundreds of citrus — a demo garden that is repeated in several other locations, such as the desert, for comparison. The center is working on 30 research projects right now.

“Citrus grows quite easily statewide….there are 300,000 acres [planted] statewide. It’s all fresh market, [California growers] don’t do juice. If the growers produce for juice, they lose money,” said Grafton-Cardwell. Florida and Brazil are the juice producers.

“Their climate produces a better juice fruit,” said Schmidt.

Lindcove is one of nine research centers in the University of California’s Agriculture and Natural Resources (ANR) department. With soil and climate typical for the commercial citrus growing in the Central Valley of California, the Lindcove’s 175 idyllic acres may be tucked remotely against the Sierra foothills on the road to Sequoia National Park, but it’s on the forefront of fighting some pretty scary citrus pests.

The Huanglongbing (HLB) bacterium has the citrus industry in California in an increasing panic. This bacterium, spread by the Asian citrus psyllids, a small bug imported from Asia, has already made its way up through Mexico and is now in Southern California and spreading northward.

Huanglongbing, also known as citrus greening disease, is killing trees at alarming rates and there is no cure yet. “It has devastated Florida. Huanglongbing has knocked their acreage down by 50 percent,” said Grafton-Cardwell. “We are trying to get some proactive research going to prepare for the arrival of the disease in the commercial citrus. Right now it is just in residential backyards, but it is going to get to the commercial citrus in the near future,” said Grafton-Cardwell.

In California, it is particularly hard to control because of the prevalence of backyard citrus trees.

“Right now it is just in Southern California. We are up to about 650 trees in Southern California that tested positive,” said Grafton-Cardwell. All of those infected trees were in residential yards. Therein lies the problem: An estimated 60% of homeowners have a citrus tree in their yard. “That’s like 15 million citrus trees. How do you manage a disease when you’ve got 30 million commercial trees and 15 million residential trees? It is very difficult,” she said. “Homeowners don’t understand plant disease, they don’t understand how to manage the pest, they don’t understand the risk.”

Unrelated to HLB, but nonetheless an insurance policy for all citrus growers, is Lindcove’s Citrus Clonal Protection Program (CCPP) out of UCR. Lindcove preserves and archives original budwood of citrus varieties as part of CCPP. Large screenhouses — greenhouses with screens instead of glass — hold clean budwood, which nurseries, growers and even citrus enthusiasts can use to propagate citrus plants. The citrus buds are grafted to rootstock and grown into trees in the screenhouses, where they are protected from insects.

The screens on these structures are “rated for thrips” — so fine that thrips or psyllids can’t get through it. Recently when one of the screens had a breach, the CCPP program restarted all the trees in the screenhouse to make sure they were free of insects and disease. This is serious business.

First, the network

Lindcove has a new network capability now. “We are really excited,” said Dr. Grafton-Cardwell. “It has taken us ten years to get to the point where we have a network that can support all this, because we are out in the boonies.”

Lindcove now uses the fiber network from CENIC — the non-profit network operator for the California universities, colleges, schools and libraries — and fixed wireless company GeoLinks for last-mile wireless.

“We were getting our internet from a local provider here in Visalia with limited bandwidth for a lot of money,” said Schmidt. “So now we’ve got this big connection that has the potential to have a large bandwidth. We’re in pretty good shape.”

“ANR pushed really hard in the last couple years to develop the funding to do this for all the research and extension centers, all nine of them, because we were all created back in the 1950s, and most of us in the boonies, and none of us had decent network capability. For scientists in this day and age to do research, it is totally revolutionary,” said Grafton-Cardwell. “When I first came in 1990, we weren’t able to do any of this stuff. Computing was really primitive and now it is going to improve what we do.”

Smart farm at Lindcove

“I didn’t even know what the internet of things was before Rich Wolski explained it,” said Grafton-Cardwell, but now she can’t wait to get it.

The goal of the UCSB’s smart farm test at Lindcove is to improve the decision making for frost protection for citrus growers, which should help reduce costs and carbon footprint.

Schmidt pointed out the culprit: the big wind machines on citrus farms. These wind machines are needed because the typical inversion layer of warmer air holds cold air to the ground, which damages fruit. The wind machines circulate the air when frost is imminent. It costs a lot to run the wind machines, which run on propane. That’s not even counting the cost of having to run around to the fields in a truck, taking temperature readings at all hours to make a decision when to turn on the wind machines.

Krintz and Wolski’s team of students have installed low-cost, sturdy weather stations that can withstand the elements and accurately sense temperature and humidity at 5 feet and 30 feet from the ground. The stations are installed to be able to monitor 3 feet from the boundaries of where the wind machines cover. The poles also have surveillance cameras with infrared capability to allow more temperature measurement, beyond regular thermometers. A network station in the field moves the data to the office on-site. Drones could be used “on the fly” to monitor at different levels.

Measuring and estimating the evaporation and transpiration under the tree canopy and sending that data to the office means that someone like Kurt Schmidt won’t have to manually take the temperature every hour at all hours, to determine when to turn on the fans. Also, tapping into Schmidt’s knowledge of when the fans need to be turned on will help inform the system; Krintz and Wolski can write software to automate the fans operations. Having more detailed information in real time means saving fuel if one windfan on one end of a microclimate doesn’t need to be turned on, even though others may need to run.

This frost experiment is only the beginning.

“We have a laboratory here that has equipment in it that again, we could be connecting,” said Grafton-Cardwell. “One of the things I proposed to Chandra [Krintz] and Rich [Wolski], is we have all these data in separate units. The pack line generates data, we are collecting data from the field. That is going into files. The data aren’t connected in any shape or form.”

Grafton-Cardwell’s ultimate goal is to have a researcher go into a portal and view all the data associated with their research.

This article originally appeared in the RCR Wireless News, July 17, 2018, and is re-posted with permission in the UC IT Blog.

Photo of Susan RamboSusan Rambo covers 5G for RCR Wireless News.

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GeoLinks CEO Joins FCC Broadband Committee

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

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

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

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

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

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Fixed Wireless Case Study by GeoLinks – The Coffee Bean & Tea Leaf

Fixed Wireless Case Study by GeoLinks – The Coffee Bean & Tea Leaf

The Coffee Bean & Tea Leaf was slated to open a series new stores in Southern California in 2016 and needed more than 30 Wi-Fi circuits to support both their public Wi-Fi and POS systems in 20 days time. The company initially contracted to provide a terrestrial connection was projecting massive delays and restrictions of available bandwidth. In order to meet their quickly approaching deadlines, Coffee Bean looked to contract an outside local provider to administer a temporary solution.

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Advantages and Disadvantages of Broadband Technologies for Rural America – Infographic

Advantages and Disadvantages of Broadband Technologies for Rural America

Infographic by GeoLinks

 

BroadbandTechnologiesforRuralAmerica_GeoLinks

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

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

POST WRITTEN BY Skyler Ditchfield

CEO of GeoLinks, the Fastest Growing WISP in America named 2018 “Most Disruptive Technology” for its ClearFiber™ Network.

Shutterstock

If you were to google “how to close the digital divide,” you would not come up empty-handed. As a quick precursor, for those of you who may be unfamiliar, the digital divide refers to the inequalities in finances, education and social status faced by those without computers and access to the internet versus those who do. Because having equal access to digital technology is at the core of the divide, broadband availability, or the lack thereof, has become a highly publicized and debated topic between politicians and telecommunications companies (telcos) alike. Nevertheless, the divide still remains and arguably will continue to remain unless the following five steps are taken.

Step 1: Redirect Federal Funding Distribution

The federal government has allocated and continues to allocate ample funding toward closing the digital divide. Consequently, over the past 20 years, we’ve been able to raise broadband standards considerably, at least in urban and suburban markets. Unfortunately, however, the majority of these funds are awarded to major telcos and incumbent providers, and without a guaranteed long-term revenue case in rural America, they have minimal incentive to invest in new infrastructure or to improve current infrastructure. While this may make sense for their personal bottom lines, it does not benefit the American public. So, if large telcos can’t or won’t service rural America, who will?

First, if you have an option to buy from a small local provider, do so — you will consequently be supporting your local economy. However, the problem with totally relying on the little guys is that they are, in fact, the little guys, and often don’t have access to or the power to access the spectrum of state-of-the-art equipment or fiber assets that enable other providers to offer competitive, cost-effective and high-bandwidth solutions.

Another option is the middle road between mom-and-pop and the incumbent providers — the mid-sized internet service provider. As it currently stands, mid-sized ISPs do not have the financial resources of big telcos to build out low-cost products with long return on investment, thus making them less competitive for consumers. However, if granted adequate funding to build out infrastructure, these mid-sized telcos have the opportunity to give the mega-ISPs true competition, ultimately keeping the market honest, fair and favored toward the public’s best interest.

Step 2: Open The Airwaves, Fairly 

As it currently stands, today’s major cellular companies hold the vast majority of wireless spectrum allotted by the FCC to resolve the digital divide. These services, while important, do not currently deliver the entire bandwidth necessary to meet the needs of all unconnected Americans. However, the United States still has ample wireless spectrum available. If the FCC and Capitol Hill can appropriate these assets to companies that truly support the public’s best interest, and said companies utilize and deploy intelligently, the utopian idea of one day delivering one-gigabit speeds to every home in America is possible. 

Step 3: Implement A True Accountability Structure

On February 12, 2018, the White House released the Legislative Outline for Rebuilding Infrastructure in America. The outline, which acknowledges the horrific state of the nation’s current infrastructure, demonstrates the new administration’s framework, meant to build a better future for all Americans. To its credit, there is a handful of positive action items presented in the outline. From empowering individual state decision-making, to establishing true accountability structures, to expediting and streamlining overall permitting and federal agency processes, at its core, the outline perceivably serves in the general best interest of the American public.

However, it can also be argued that there are inherent and massive flaws in the outline that will ultimately prevent these goals from reaching fruition. For example, past the inadequate division of funding, there is not a clear timeline of when all legislation changes must take effect. Therefore, even though once these changes are enacted there is a 24-month timeline, there isn’t a clear delineation of an official launch date. To paint an extreme example, this outline could have us all sitting here in five or 10 years still spewing on initiatives that could be and could make a better future. Thus, the administration needs to follow up its outline with immediate deadlines in order to formalize proposed accountability structures.

Step 4: Expedite The Use Of Federal Lands

As touched upon above, the idea of expediting processes has been proposed. However, even if we could ensure grant winners would build out as planned, the fact remains that 28% of the U.S. is federally owned, and many of these sites are in areas we need to get through or use for broadcast areas. It’s imperative we support operators’ build times by expediting permitting the use of federal lands sooner than later, and preferably now.

Step 5: Adopt A Technology-Agnostic Hybrid Approach 

While states and communities across the country continue to request fiber optic networks, the reality is that building out fiber infrastructure to every location in America is both cost- and time-prohibitive. Therefore, fiber is not the complete solution if we’re aiming to close the divide in a timely manner. The solution, rather, lies in adapting and building out technology-agnostic hybrid networks. From fiber, to fixed wireless, to 4G and 5G LTE, all of these technologies have their time and place in closing the divide. While there are pros and cons to each method, when used together, they have the ability to create a complete solution that can deliver gigabit and multi-gigabit bandwidth to both urban and ultra-rural communities.

So, If We Know How, Why Is There Still A Divide?

The answer is simple: lack of action. We know the course; now we need to implement. Therefore, to all of those reading this who feel inspired or compelled to truly take part in closing the divide, reach out to your local and state municipalities, and demand action.

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Wireless smart farming to keep frost away from citrus

Wireless smart farming to keep frost away from citrus

Computer scientists from UCSB team up with citrus researchers to make a smart farm system that reports temperatures and may eventually automate the use of wind machines that keep frost off citrus crops.

Computer science researchers from the University of California Santa Barbara are using the internet of things to prove that smart farming can be a farm implement as basic as the tractor and plough.

The husband and wife team of Chandra Krintz and Rich Wolski, both UCSB computer science professors, think data analytics can help tackle some of the tough challenges of modern agriculture. They want to apply the predictive mathematical leaps used in modern internet commerce to predict what people will buy, to agriculture. The pair created the UCSB SmartFarm program in response to what they see as the main issues of agriculture.

Krintz and Wolski cite U.S. Department of Agriculture and United Nations Food and Agriculture Organization studies that say some scary stuff: increasingly more food is needed to feed the growing global population, and yet farm labor is in short supply or too expensive. Eighty percent of the fresh water and 30% of global energy is used to produce food, half of which we waste in spoilage. Farming also has some particularly tough foes: Pests and disease attack farms’ output and farm land is subsiding (sinking) — especially in California — because of groundwater overdraft. On top of all that, agriculture makes 22% of greenhouse gases.

The only way smart farming can make a dent on those issues is to attack specific problems. For Krintz and Wolski’s first test projects, they talked to the farmer — in this case, farm researchers — first before designing a system. Although almost every ag tech pitch begins with a summary of those issues, the UCSB computer scientists’ approach is to come up with scientifically vetted data about the usefulness of cloud and data analytics in farming.

The design parameters of behind UCSB SmartFarm’s Farm Cloud System is to make a system a farmer could love: it should be easy to use and work reliably, cheaply and privately — farmers don’t want their data accessible. The system needs to provide useful data to help increase yield, automate farm operations or save money (or all three), and the data must be available real time. The whole thing has to work without IT staff.

The self-managing system needs to work like an appliance, like your refrigerator, write Krintz and Wolski in a presentation about the project.

Krintz and Wolski are testing the system on nut trees at Fresno State and on citrus at the University of California’s Lindcove Research and Extension Center (LREC) near Visalia, Calif. The UCSB SmartFarm program has support from Google, Huawei, IBM Research, Microsoft Research, the National Science Foundation, National Institutes of Health and the California Energy Commission.

RCR Wireless News visited the LREC — a literal test bed for citrus and smart farming — and got the full tour of the UCSB’s Farm Cloud System.

Lindcove’s research mandate

The public is probably not aware that agricultural research centers, such as LREC (Lindcove), do the hard science that protects our food. In the case of Lindcove, hard science is the study of mostly citrus trees, and it means the grueling work of studying each tree.

Dr. Beth Grafton-Cardwell, research entomologist, an integrated pest management (IPM) specialist and Lindcove’s director remembers sorting fruit by hand.

“When I first started in 1990, if we harvested in January, we would stand in the field in our long underwear and they would pick fruit into a bin and we would have ring sizers that told us what size the fruit was. We would count the fruit and size the fruit and write it on a clip board on a piece of paper,” she said. “Now this machine can do this better.”

Standing near a huge packing line machine that dwarfed her, Grafton-Cardwell explained how the cameras and the extra sensors enable the machine to size and weigh the fruit, examine the outside of the fruit using three types of cameras and estimate the juice level inside. One tree goes through the machine at a time, for scientific purposes, which differs from how a normal packing house operates.

“If I am a researcher, each of my trees is a replication and a different situation, so I want to know everything there is to know about the fruit on that tree,” said Grafton-Cardwell. The cameras take about 30 photographs of each piece of fruit, rotating the fruit as they go. Every parameter from each piece of fruit is put into a spreadsheet: “We know the size, the shape, if it has scarring, the precise color,” said Grafton-Cardwell.

The growers paid for Lindcove’s packing line. “We can simulate anything you want to do on a commercial pack line,” said Grafton-Cardwell. All packing houses have these machines but don’t use them the way researchers do. They don’t need the precision of numbers that researchers need.

“You have to train the machine to the colors and the blemishes. It can get overwhelming,” said Kurt Schmidt, Lindcove’s principal superintendent of agriculture. “We can slow everything down and gather an infinite amount of data.”

“The data sets are ginormous,” Grafton-Cardwell pointed out. Data and an interpretation of the data is the really the product that Lindcove produces.

Dr. Beth Grafton-Cardwell, Lindcove’s director, shows off the packing line machinery at UC ANR’s Lindcove Research and Extension Center, near Visalia, California. The huge measures, weighs citrus, among other datasets. (Image: RCR Wireless News)

Originally started in 1959 by University of California Riverside and San Joaquin Valley citrus growers, Lindcove helps growers try out treatments and crop varieties without experimenting on their own crops, which protects their orchards — and livelihood. “Researchers from around the state can come here and do experiments,” said Grafton-Cardwell. Lindcove focuses on creating new varietals and demonstrating gardens of hundreds of citrus — a demo garden that is repeated in several other locations, such as the desert, for comparison. The center is working on 30 research projects right now.

“Citrus grows quite easily statewide….there are 300,000 acres [planted]statewide. It’s all fresh market, [California growers] don’t do juice. If the growers produce for juice, they lose money,” said Grafton-Cardwell. Florida and Brazil are the juice producers.

“Their climate doesn’t produce a good-tasting fruit, so they stick with juice,” said Schmidt.

Lindcove is one of nine research centers in the University of California’s Agriculture and Natural Resources (ANR) department. With soil and climate typical for the commercial citrus growing in the Central Valley of California, the Lindcove’s 175 idyllic acres may be tucked remotely against the Sierra foothills on the road to Sequoia National Park, but it’s on the forefront of fighting some pretty scary citrus pests.

The Huanglongbing (HLB) bacterium has the citrus industry in California in an increasing panic. This bacterium, spread by the Asian citrus psyllids, a small bug imported from Asia, is making its way up through Mexico into California starting with Southern California.

Huanglongbing, also known as citrus greening disease, is killing trees at alarming rates and there is no cure yet. “It has devastated Florida. Huanglongbing has knocked their acreage down by 50 percent,” said Grafton-Cardwell. “We are trying to get some proactive research going to prepare for the arrival of the disease in the commercial citrus. Right now it is just in residential backyards, but it is going to get to the commercial citrus in the near future,” said Grafton-Cardwell.

In California, it is particularly hard to control because of the prevalence of backyard citrus trees.

“Right now it is just in Southern California. We are up to about 650 trees in Southern California that tested positive,” said Grafton-Cardwell. All of those infected trees were in residential yards. Therein lies the problem: An estimated 60% of homeowners have a citrus tree in their yard. “That’s like 15 million citrus trees. How do you manage a disease when you’ve got 30 million commercial trees and 15 million residential trees? It is very difficult,” she said. “Homeowners don’t understand plant disease, they don’t understand how to manage the pest, they don’t understand the risk.”

Dr. Beth Grafton-Cardwell, research entomologist, an integrated pest management (IPM) specialist and Lindcove’s director, examines the screen on a screenhouse. The screen is rated to keep out bugs as small as thrips, to protect clonal varieties of citrus. (Image: RCR Wireless News, Susan Rambo)

A screenhouse at Lindcove, UC ANR’s research and extension center near Visalia, Calif., contains citrus clones for nurseries and growers to use. The program maintains clean clones of citrus varieties. (Image: RCR Wireless News, Susan Rambo)

Unrelated to HLB, but nonetheless an insurance policy for all citrus growers, is Lindcove’s Citrus Clonal Protection Program (CCPP) out of UCR. Lindcove preserves and archives original bud wood of citrus varieties as part of CCPP. Large screenhouses — greenhouses with screens instead of glass — hold clean bud wood, which nurseries, growers and even citrus enthusiasts can use to propagate citrus plants. The citrus buds are grafted to root stock and grown into trees in the screenhouses, where they are protected from insects.

The screens on these structures are “rated for thrips” — so fine that thrips or psyllids can’t get through it. Recently when one of the screens split along one seam, the researchers destroyed all the trees in the compromised screenhouse and disinfected it before repairing it. This is serious business.

First, the network

Lindcove has a new network capability now. “We are really excited,” said Dr. Grafton-Cardwell. “It has taken us ten years to get to the point where we have a network that can support all this, because we are out in the boonies.”

Lindcove now uses the fiber network from CENIC —  the non-profit network operator for the California universities, colleges, schools and libraries — and fixed wireless company GeoLinks for last-mile wireless.

“We were getting our internet from a local provider here in Visalia with limited bandwidth for a lot of money,” said Schmidt. “So now we’ve got this big connection that has the potential to have a large bandwidth. We’re in pretty good shape.”

“ANR pushed really hard in the last couple years to develop the funding to do this for all the research and extension centers, all nine of them, because we were all created back in the 1950s, and most of us in the boonies, and none of us had decent network capability. For scientists in this day and age to do research, it is totally revolutionary,” said Grafton-Cardwell. “When I first came in 1990, we weren’t able to do any of this stuff. Computing was really primitive and now it is going to improve what we do.”

Smart farm at Lindcove

“I didn’t even know what the internet of things was before Rich Wolski explained it,” said Grafton-Cardwell, but now she can’t wait to get it.

The goal of the UCSB’s smart farm test at Lindcove is to improve the decision making for frost protection for citrus growers, which should help reduce costs and carbon footprint.

Schmidt pointed out the culprit: the big windmills on citrus farms. These windmills are needed because the typical inversion layer of warmer air holds cold air to the ground, which damages fruit. The windmills circulate the air when frost is imminent. “It costs $30K a season to run these,” said Schmidt. That’s not even counting the cost of having to run around to the fields in a truck, taking temperature readings at all hours to make a decision when to turn on the windy gas guzzlers.

One windfan and its propane tank peeking out from among rows of citrus at UC ANR’s Lindcove July 9th, 2018, near Visalia, California. (Image: RCR Wireless News, Susan Rambo)

Krintz and Wolski’s team of students have installed low-cost, sturdy weather stations that can withstand the elements and accurately sense temperature and humidity at 5 feet and 30 feet from the ground. The stations are installed to be able to monitor 3 feet from the boundaries of where the windfans cover. The poles also have surveillance cameras with infrared capability to allow more temperature measurement, beyond regular thermometers. A network station in the field moves the data to the office on-site. Drones are also used “on the fly” to monitor at different levels.

Measuring and estimating the evaporation and transpiration under the tree canopy and sending that data to the office means that someone like Kurt Schmidt won’t have to manually take the temperature every hour at all hours, to determine when to turn on the fans. Also, tapping into Schmidt’s knowledge of when the fans need to be turned on will help inform the system; Krintz and Wolski can write software to automate the fans operations. Having more detailed information in real time means saving fuel if one windfan on one end of a microclimate doesn’t need to be turned on, even though others may need to run.

This frost experiment is only the beginning.

“We have a laboratory here that has equipment in it that again, we could be connecting,” said Grafton-Cardwell. “One of the things I proposed to Chandra [Krintz] and Rich [Wolski], is we have all these data in separate units. The pack line generates data, …we are collecting data from the field. That is going into files. The data aren’t connected in any shape or form.”

Grafton-Cardwell’s ultimate goal is to have a researcher go into a portal and view all the data associated with their research.

UCSB SmartFarm sensor approximately 5 feet off the ground surrounded by citrus will help UC ANR’s Lindcove researchers know when to turn on windfans to protect plants from frost. (Image: RCR Wireless News)

The pole holding sensors and cameras for UCSB’s SmartFarm program. (Image: RCR Wireless News)

UCSB’s smartfarm pole at UC ANR’s LREC.

Dr. Beth Grafton-Cardwell, research entomologist, an integrated pest management (IPM) specialist and Lindcove’s director (right); Kurt Schmidt, Lindcove’s principal superintendent of agriculture, (left) stand in Lindcove orchard in front of UCSB smartfarm experiment. (Image: RCR Wireless News, Susan Rambo)

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In the Matter of Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band 

Before the

Federal Communications Commission

Washington, DC  20554

 

In the Matter of Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band  |  GN Docket No. 18-122

 

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

 

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these comments in response to the questions set forth in the Public Notice issued on May 1, 2018.[1]

 

  1. INTRODUCTION AND SUMMARY

GeoLinks is proud to service the largest coverage area of any single fixed wireless Internet service provider (“ISP”) in the state the California.  The Company’s fixed wireless technology platform depends on access to spectrum resources sufficient to support enterprise-level broadband connections.  Millions of Americans lack what is, by today’s standards, considered high-speed broadband access – especially in rural areas. 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.

Over the last two years, GeoLinks has made it a Company priority to reach more unserved and underserved areas within California and beyond.  GeoLinks believes that 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.  Specifically, the​ ​3.7–4.2​ ​GHz​ ​band​ ​is​ especially ​well-suited​ ​to​ ​support​ Point-to-Multipoint (“P2MP”)​ ​broadband​ ​access. As such, GeoLinks urges the Commission to affirmatively state the feasibility of commercial wireless applications and its intention to assess how the band can be properly allocated to maximize public benefit in its 3.7-4.2 Report.

 

  1. DISCUSSION
  2. The 3.7-4.2 GHz Band is Well-Suited for Point-To-Multipoint Services

As GeoLinks has previously stated, the Company supports shared, licensed P2MP use of the 3.7-4.2 GHz band.  As an initial matter, P2MP service options are ideal because they allow a wireless service provider to provide high-speed broadband connections to several end-users (i.e. several households throughout a community) from one location, requiring fewer towers and less equipment than point-to-point connections.  If sufficient spectrum is available, providers can use P2MP technology to deliver gigabit and near-gigabit speeds to customers.  In addition, because P2MP services are wireless, use of this technology eliminates the need for costly, time-consuming and disruptive construction that is generally associated with fiber buildouts.  This is especially beneficial in rural and high-cost areas and can provide much-needed competition to incumbent providers in urban and suburban areas.

Despite the benefits of this technology, as the Broadband Access Coalition explains in its Petition, there is no licensed mid-band spectrum allocated for fixed P2MP service than can enable gigabit speeds.[2]  However, for the reasons stated in the Petition, the 3.7-4.2 GHz band is well suited for the provision of gigabit or near-gigabit wireless broadband connectivity via P2MP connections.[3]  With the appropriate rules, the Commission can ensure P2MP use is feasible in the band, which will result in more affordable, high-speed broadband and increased broadband competition.  GeoLinks urges the Commission to address this possibility in its 3.7-4.2 GHz Report.

  1. The Commission Should Consider Additional Unlicensed Spectrum in Bands Other Than the 3.7-4.2 GHz Band

As GeoLinks addressed in previous filings, traditionally, fixed wireless ISPs have operated in unlicensed bands (i.e. 2.4 and 5 GHz).  While this has allowed for successful deployment of internet services in some areas, the availability of unlicensed bands is not a one-size-fits-all option and congestion and interference can occur in areas with numerous providers seeking to use these frequencies.  With respect to the 3.7-4.2 GHz band, as discussed in more detail below, GeoLinks urges the Commission to make spectrum available on a Part 101 or “light licensed” basis, not an unlicensed basis.

GeoLinks believes that if the Commission were to create rules to allow unlicensed use in the 3.7-4.2 GHz band, it would cause the need for additional administrative oversight and monitoring that would both render the band less usable for commercial wireless services and negate the benefits of unlicensed spectrum use.  First, the Commission would need to carve out a specific section or sections of the band for unlicensed use large enough to accommodate high-speed broadband services.[4]  This could possibly require the need to shift existing users to other frequencies within the band.  In addition, it would require ongoing policing of the band to ensure no unauthorized use spilling into adjacent frequencies, which could cause significant interference to other band users.  In all, it could create significant administrative burdens to both the Commission and existing users in the band.  For these reasons, the Company asserts that the 3.7-4.2 GHz band may not be the most appropriate band for unlicensed uses at this time.

 

  1. The Commission Should Consider Implementing Spectrum Sharing Policies in the 3.7-4.2 GHz Band

As addressed in the Petition, the Commission’s current “full-band, full-arc” policy has led to underutilization of the 3.7-4.2 GHz band.[5]  However, this policy can be revised in a way that will maximize the usefulness of the band.  As an initial matter, GeoLinks seconds the Petition’s suggestion that the Commission require current users of the band to report updated location and technical information to the Commission so that it can update its FSS earth station database.  GeoLinks (as well as other wireless broadband providers) can coordinate its use of a frequency around any fixed point that may be necessary (i.e. an FSS earth station).  As a fixed wireless broadband provider, GeoLinks has the flexibility to design its network in any way necessary to maximize spectrum resources and avoid interference.  As such, GeoLinks believes that an important first step for the Commission to take to assess the feasibility of allowing commercial wireless services in the 3.7-4.2 GHz band is to assess where within the band interference could occur.  With this new information, additional band users can avoid transmitting in the immediate vicinity of an FSS provider or in a way that causes interference.

Second, GeoLinks recommends that the Commission allow sharing of the 3.7-4.2 GHz band.[6]  As noted in the Petition, the Commission has had demonstrated success with “light licensing” and spectrum sharing regimes in other bands.[7]  GeoLinks agrees that this type of licensing regime would prove successful for the 3.7-4.2 GHz band, as well.  Specifically, GeoLinks supports Part 101 frequency coordination to avoid interference while allowing additional users to fully utilize the band for broadband services.  In addition, GeoLinks asserts that because the Commission has successfully implemented these regimes before, it can attest to how they have worked in other bands in its 3.7-4.2 Report.

 

  1. The Commission Should Not Limit its Assessment of Feasibility on Whether the Band Can be Used for Mobile Wireless Services

GeoLinks urges the Commission not to base feasibility of the band for commercial wireless uses on whether those uses will immediately include mobile wireless.  As explained in the Petition, the band “is not now, and will not for several years, be suitable for mobile use given the existing deployment of FSS earth stations and FS P2P links.”[8]  Instead, GeoLinks urges the Commission to recognize the feasibility for P2MP fixed wireless commercial uses that could be deployed in the band ASAP to help bring gigabit and near-gigabit speeds to rural, unserved areas of the country.

  1. The Commission Should Consider Strict Buildout and Usage Requirements for New Users of the 3.7-4.2 GHz Band

As GeoLinks has advocated in previous filings, any spectrum license should carry with it the requirement to serve the public interest – including for shared or light licensed spectrum.  Spectrum is, first and foremost, a public resource and should be allocated accordingly.  As part of its assessment regarding the feasibility of allowing commercial wireless use of the 3.7-4.2 GHz band, the Commission must consider what steps will be necessary to ensure successful and efficient use of the band once such uses are allowed.  GeoLinks recommends that the Commission affirmatively state in its 3.7-4.2 GHz Report that any additional use of the band will be subject to strict buildout and service requirements to help promote broadband deployment in rural areas.[9]  These requirements will alleviate the risk of spectrum warehousing and encourage rapid deployment of high-speed broadband by band users.

 

  • CONCLUSION

In conclusion, GeoLinks urges the Commission to consider the suggestions set forth in the Petition and recognize the feasibility for commercial wireless services under a shared, light licensed regime in its 3.7-4.4 GHz Report

 

 

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

May 31, 2018

[1] Office of Engineering and Technology, International, and Wireless Telecommunications Bureaus Seek Comment for Report on the Feasibility of Allowing Commercial Wireless Services, Licensed or Unlicensed, to Use or Share Use of the Frequencies Between 3.7-4.2 GHz, Public Notice, GN Docket 18-122, DA 18-446 (re. May 1, 2018).
[2] Broadband Access Coalition, Petition for Rulemaking to Amend and Modernize Parts 25 and 101 of the Commission’s Rules to Authorize and Facilitate the Deployment of Licensed Point-to-Multipoint Fixed Wireless Broadband Service in the 3700-4200 MHz Band, RM-11791 (filed June 21, 2017) (“Petition”) at 4.
[3] “The 3700 – 4200 MHz band satisfies two fundamental requirements for spectrum to provide high-speed fixed wireless broadband access to residential and small business customers and to community anchor institutions. First, the 3700 – 4200 MHz band has excellent propagation characteristics compared to high-band spectrum, offering near-line-of-sight (“nLOS”) capability at low power for last-mile services. Second, the band has 500 megahertz of contiguous spectrum, an amount sufficient to accommodate twenty-five 20 megahertz channels that can be bonded to create larger 40, 80, and 160 megahertz channels. These wide channels facilitate the provision by multiple entities of last-mile fixed wireless broadband connectivity at gigabit or near-gigabit speeds.”  Petition at 4.
[4] GeoLinks believes that a minimum of 120 MHz of clean spectrum (with no interference) is required to provide gigabit or near-gigabit broadband speeds.
[5] Petition at 5.
[6] This position is also shared by other parties.  See e.g. Comments of the Competitive Carriers Association, RM-11791 (filed August 7, 2017) at 2 and Comments of Starry, Inc., RM-11791 (filed August 7, 2017) at 1.
[7] “Part 101 frequency coordination will ensure that the incumbent Fixed-Satellite Service (“FSS”) and terrestrial point-to-point (“P2P”) Fixed Service (“FS”) will not suffer harmful interference from band-sharing with P2MP.” Petition at 1.
[8] Petition at 6.
[9] Specifically, GeoLinks recommends build out to a minimum number of locations.  In the alternative, GeoLinks recommends that the Commission require any new band user to make a showing that they are actually serving customers over the band within a reasonable timeframe.
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What is Fixed Wireless Internet?

An introduction to Fixed Wireless Internet and the Fastest Growing WISP in America

 

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GeoLinks Announces Vectus Acquisition and ClearFiber™ Network Expansion

GeoLinks Announces Vectus Acquisition and ClearFiber™ Network Expansion

California’s fastest growing telecom, GeoLinks, announces acquisition of wireless Internet provider Vectus.

GeoLinks is thrilled to officially announce its acquisition of Southern California fixed wireless broadband provider, Vectus. The acquisition includes an outright procurement of the ISP’s robust fixed wireless network, key staff, and existing customer base ultimately expanding GeoLinks’ existing ClearFiber™ network and coverage map.

Founded by seasoned industry professionals in 2006, Vectus has become known as one of California’s leading providers of Ethernet over fixed wireless Internet services. Presently, the Vectus network offers dense coverage throughout Orange County, Riverside, San Bernardino, and Los Angeles Counties.

“With founding roots in Southern California, GeoLinks has been familiar with Vectus’s robust wireless network for quite some time,” said GeoLinks CEO Skyler Ditchfield. “When the opportunity to officially acquire Vectus came to the table, all parties knew immediately that merging networks would be seamless from an operations standpoint, and prove immensely beneficial to existing and future clientele. With contracts finalized, company migration will commence immediately, enabling GeoLinks to further expand its coverage map while simultaneously increasing our overall network capacity, redundancy, and ability to deliver higher bandwidth.”

President and CTO of Vectus, David Saylor, agreed with Ditchfield that the acquisition was a natural and strategic fit for both entities. “Post-acquisition, I have full confidence that all existing Vectus customers will continue to receive the same exceptional service they’ve become accustomed to. At our cores, GeoLinks and Vectus have synergistic beliefs—always put the customer first. By combining assets, all current and future customers will now have access to an even more resilient and redundant wireless network. Skyler and GeoLinks are highly respected leaders and innovators in the world of telecom, and I speak on behalf of the entire Vectus team when I say that we’re extremely pleased to be combining forces and joining their efforts.”

Both Vectus and GeoLinks’ existing clients will encounter no disruptions of service during the network transition. GeoLinks looks forward to announcing further details on increased network offerings in the upcoming months.

###

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 Hosted Voice solutions. Named the Fastest Growing WISP in America, GeoLinks delivers Enterprise-Grade Internet, Layer 2 Transport, Hosted Voice, 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.

Recognized as a thought-leader in closing the digital divide, GeoLinks proudly sits on an array of national boards, coalitions, and working groups including the Schools, Healthcare & Libraries Broadband (SHLB) Coalition, the Wireless Internet Service Providers Association (WISPA), the Broadband Consortium of the Pacific Coast (BCPC), and the FCC’s Broadband Deployment Advisory Committee’s (BDAC) Streamlining Federal Siting Working Group.In 2018 GeoLinks was awarded the Corporate Partnership Award by the Corporation For Education Network Initiatives In California (CENIC) for serving the research and education community in California.

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