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GeoLinks Comments on Auction of Priority Access Licenses

GeoLinks FCC Comments - Auction of Priority Access Licenses for the 3550-3650 MHz Band 

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 certain Comments filed on the Public Notice seeking public input on procedures to be used for the auction of Priority Access Licenses (“PALs”) in the 3550-3650 MHz band.[1]

INTRODUCTION AND SUMMARY

GeoLinks commends the Commission on its efforts to open the 3550-3650 MHz band and release this valuable spectrum to the market for advanced services.  However, as proposed in the Public Notice, some of the auction processes may have the unintended consequence of making the majority of the 3550-3650 MHz band (at least in certain markets) only obtainable by large companies with vast amounts of capital.  As such, GeoLinks agrees with commenters that the Commission should reject its Cellular Market Area (“CMA”)-level bidding proposal and urges the Commission to refrain from imposing bidding credit caps on small and rural service providers.

 

DISCUSSION

The Commission Should Refrain from Adopting CMA-Level Bidding

The vast majority of commenters agree with GeoLinks that CMA-level bidding should be rejected for a number of reasons.  First, CMA-level bidding will disadvantage smaller bidders, a concept that the Commission has previously acknowledged.  As DSA points out “the Commission explicitly acknowledged the harms of increasing the size of PAL areas beyond counties, stating that ‘the incremental benefit for 5G mobile use of going from counties to MSAs or PRAs would be far less than the incremental costs incurred by other potential users of the band.’”[2]  Further, as NCTA points out, “the Commission explained that ‘increasing PAL license area size further…could disproportionately favor mobile use cases and hinder investment in innovative fixed networks and localized deployments.’”[3]  This is because CMA-level bidding may have the unintended consequence of driving up PAL prices for rural counties that fall within CMAs that encompass more metropolitan counties.  As CCA explains, CMA-level bidding “risks distorting prices for less-densely populated counties subject to CMA bidding, and in so doing, could reduce auction participation and undermine investment and deployment by the very companies in the best position to improve wireless service in America.”[4]  This risk is clearly illustrated by RWA, which provides several examples in its comments to illustrate how “numerous rural counties…would be tied to pricier metropolitan package bid areas for which large and nationwide carriers would be competing, and therefore effectively unavailable to small and rural bidders.”[5]

Moreover, as WISPA and DSA explain, “CMA-level bidding will make it more challenging for companies that may desire to acquire PALs in rural counties that would be less desirable for large carriers looking to establish a larger geographic footprint of licenses,” which could “foreclose, or at least greatly diminish, the ability of competitive and smaller ISPs and other local entities to win PALs in the 172 CMAs.”[6]  Further, as Southern Linc explains, the CMA-level bidding proposal “undoubtedly provides a significant advantage to bidders with larger war chests than have an incentive to bid for larger areas in order to achieve economies of scale.”[7]  The result will be an auction that takes the band “further from its ‘Citizens’ roots,” as API notes.

Second, the Commission’s CMA-level bidding proposal is overly complex.  While AT&T praises the Commission for offering bidders “the flexibility to bid utilizing two different market area structures,” the creation of two distinct auction processes and two distinct types of bidders may lead to confusion or a lack of participation in the auction.  As Verizon explains, “the proposal for [CMA]-level bidding is not package bidding” and would add “unnecessary complexity to an already-complex auction.”[8]  While the Commission sites as a benefit to CMA-level bidding the ability to obtain “an aggregation of counties, rather than having to bid for the counties separately,”[9] it fails to explain how this benefit (which will only really be a benefit for a few auction participants) will help further the goals of the Auction.  As NCTA points out, auction complexity caused by the Commission’s CMA-level bidding proposal will have “unintended inefficiencies – including inhibiting price and demand discovery – without providing the correspondence benefit of reducing the overall number of potential biddable items.[10]

Third, CMA-level bidding is simply not needed for bidders to obtain PALs across an aggregation of counties.  As WISPA explains, “PALs in multi-county areas can be assembled through county-level bids that afford bidders greater flexibility to design bids in a way that does not include undesirable counties in the CMA-level bid.”[11]  And as DSA explains, “large bidders have access to sophisticated auction resources to track auction progress and generate bids that they upload each round into the Commission’s bidding system.”[12]  GeoLinks agrees with DSA that “the Commission’s CMA-level bidding proposal is a solution in search of a problem,” because “the Commission itself provides no justification for the proposal in the Public Notice.”[13]  As OTI explains, the proposal yields “no substantial benefits in reducing burdens for the Commission or even for the largest mobile carriers that set out to acquire PALs in every county in a CMA.[14]  The fact is that CMA-level bidding is just not needed and could cause more harm than good.

For these reasons the Commission should refrain from adopting its CMA-level bidding proposal.

The Commission Should Not Establish Bidding Credit Caps

GeoLinks maintains its position that if the Commission truly wants to release “flexible-use mid-band spectrum to the market” in order to further “deployment of fifth-generation wireless, the Internet of Things, and other advanced spectrum-based services,” it must allow the playing field to remain level throughout the entire auction process and eliminate the bidding credit caps it proposes in the Public Notice.[15]  Specifically, GeoLinks urges the Commission to refrain from imposing bidding caps on could-be auction winners that may otherwise not be able to match the bidding power of large companies.

RWA asserts that caps are necessary because “in prior auctions, deep-pocketed applicants that nevertheless qualified as small businesses were able to freeze out the small and rural providers that actually serve the areas.”[16]  However, this argument does not actually explain why caps are needed or why they are the appropriate solution.  It seems that instead of encouraging the Commission to adopt caps to ensure there is no gaming of the bidding credits in Auction 105, RWA should be asking the Commission to take steps necessary to ensure that small and rural providers are the ones receiving those credits.  GeoLinks would agree with such an ask and urges the Commission to adopt safeguards to ensure that bidding credits only go to small and rural service providers that fall within the Commission’s intended definition.  This will ensure that RWA’s concerns are addressed without hamstringing small and rural carriers in the Auction 105 process.

For these reasons, GeoLinks urges the Commission to refrain from imposing caps of the amount of bidding credit a small business or rural service provider may receive.  If the Commission does determine that bidding credit caps must be implemented, at a minimum, GeoLinks urges the Commission to increase them significantly.

CONCLUSION

For the foregoing reasons, GeoLinks urges the Commission to reject its CMA-level bidding proposal and refrain from imposing bidding credit caps on small and rural service providers.

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 12, 2019

 

[1] Public Notice, Auction of Priority Access Licenses for the 3550-3650 MHz Band; Comment Sought on Competitive Bidding Procedures for Auction 105; Bidding in Auction 105 Scheduled to Begin June 25, 2020, AU Docket 19-244, FCC 19-96 (rel. Sept. 27, 2019) (“Public Notice”).
[2] Comments of the Dynamic Spectrum Alliance, AU Docket No. 19-244 (filed Oct. 28, 2019) (“DSA Comments”) at 4, citing Report and Order, GN Docket No. 17-258 (Rel. Oct. 24, 2018) at para. 27.
[3] Comments of NCTA – The Internet & Television Association, AU Docket No. 19-244 (filed Oct. 28, 2019) (“NCTA Comments”) at 4, citing Promoting Investment in the 3550-3700 MHz Band, Report and Order, 33 FCC Rcd. 10,598 (2018) at paras. 20 and 39.
[4] Comments of the Competitive Carriers Association, AU Docket No. 19-244 (filed Oct. 28, 2019) (“CCA Comments”) at 4.
[5] Comments of the Rural Wireless Association, Inc., AU Docket No. 19-244 (filed Oct. 28, 2019) (“RWA Comments”) at 3-4; see also at 4-9.
[6] Comments of the Wireless Internet Service Providers Association, AU Docket No. 19-244 (filed Oct. 28, 2019) (“WISPA Comments”) at 4 and DSA Comments at 5.
[7] Comments of Southern Communications Services, Inc. dba Southern Linc, AU Docket No. 19-244 (filed Oct. 28, 2019) at 4.
[8] Comments of Verizon Communications, Inc., AU Docket No. 19-244 (filed Oct. 28, 2019) at 2-3.
[9] Public Notice at para 29.
[10] NCTA Comments at 3-4
[11] WISPA Comment at 3.
[12] DSA Comments at 11.
[13] Id. at 10
[14] Comments of the Open Technology Institute at New America, AU Docket No. 19-244 (filed Oct. 28, 2019) at 8.
[15] Public Notice at para. 1.
[16] RWA Comments at 3.

GeoLinks Comments on the Rural Digital Opportunity Fund

Rural Digital Opportunity Fund - GeoLinks 

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 submitted on the Notice of Proposed Rulemaking (“NPRM”) issued August 2, 2019 in the aforementioned proceedings.[1]

INTRODUCTION

GeoLinks commends the Commission on its efforts to deploy high speed broadband to the remaining unserved areas of the country.  As a Connect America Fund Phase II (“CAF”) auction award winner, GeoLinks recognizes how the proposed Rural Digital Opportunity Fund (“RDOF”) Auction rules will impact small to medium sized service providers.  GeoLinks supports the creation of the RDOF and largely supports all of the Commission’s proposals with respect to its implementation thereof.  However, GeoLinks provides input on some of the Commission’s proposals that could result in diminished participation in the RDOF auction or inefficient use of Universal Service Fund (“USF”) support.

DISCUSSION

A. The RDOF Auction Must Remain Technology Neutral

The RDOF Auction process, as proposed in the NPRM, is built off of the Commission’s success in the CAF auction that concluded last year.  As such, the NPRM proposes a number of processes designed to obtain similar successful results to more areas with a larger and more robust fund.  While this effort should be applauded throughout the telecommunication industry, unfortunately some commenters have decided to use the NPRM as an opportunity to attempt to sway the Commission away from running the RDOF auction in a technology neutral manner.

For example, NRECA boldly asserts that “the FCC should not grant applications in which the applicant is proposing to utilize new, unproven technologies or proposing data rates beyond generally accepted standards for the technology.”[2]  NRECA goes on to say that “winning bids should only go to proven technologies that have been extensively deployed and field-proven to deliver quality services meeting all EDOF requirements.”[3]  Notably, NRECA fails to state specifically what technologies it refers to, what these perceived “generally accepted standards” are, or what “extensively deployed” or “field-proven” mean.  These statements are made simply to plant a seed of doubt into trusting any technology that is seen as an alternative to traditional fiber technology.  Similarly, the North Dakota Joint Commenters (“NDJC”) assert that RDOF should only support “future-proof fiber.”[4]  Moreover, Windstream urges the Commission to limit support to small providers “with limited existing infrastructure.”[5]

These commenters, and others, seek to limit RDOF opportunities for diverse technology types and turn the Commission’s favor to “traditional” technology types with “traditional” deployment processes.  What these commenters fail to address, however, is that these “traditional” efforts have not been successful to ensure broadband deployment to unserved parts of the US, which is why the RDOF is being proposed in the first place.  GeoLinks urges the Commission to retain the technology neutral approach it sets forth in the NPRM and rely on its proposed financial and technological requirements to vet which service providers and which technologies are eligible for RDOF support.

B. The Commission Should Not Implement Subscribership Milestones as a Basis for RDOF Funding

GeoLinks asserts that the Commission should refrain from making funding contingent upon RDOF recipients attaining set subscribership milestones.  From a statutory perspective, RDOF funds should only be used for broadband deployment. GeoLinks agrees with WISPA that Section 254 of the Communications Act limits the use of RDOF support for “the provision, maintenance, and upgrading of facilities and services for which the support is intended.”[6]  Specifically, WISPA asserts that “the [USF] was established to subsidize availability of telecommunications services in high-cost areas,” not adoption.[7]  Therefore, based on the language of Section 254, a subscription requirement should not be a requirement for RDOF funding.

From a policy perspective, several Commenters agree that imposing subscribership milestones will not serve the goals of the program.[8]  As an initial matter, lack of subscribership in an area is not necessarily attributable to the efforts, or lack thereof, of a service provider.  As CenturyLink explains, providers “have every incentive to sell their service to customers in program areas where they have deployed the network facilities required to provide the requisite broadband service in high-cost areas.”[9]  However, as the California Emerging Technology Fund astutely notes, “borrowing a line from the movie ‘Field of Dreams,’ just because you build it, does not mean that subscribers will come.”[10]  Similarly, WTA uses the adage “you can lead a horse to water, but you can’t make it drink” to show that “no matter what a [service provider] may do to deploy, operate and advertise their broadband services,” they may not have control over broadband adoption in RDOF areas.[11]  As GeoLinks points out in its opening comments, low take rates may occur due to a number of factors including consumers in RDOF areas not understanding the benefits of highspeed broadband connections or potential competition either from new entrants after deployment or from existing service providers offering slow speed options (i.e. sub 25/3 Mbps, which customers may opt to keep though faster speeds will be available).  Any of these factors can affect take rate.

In addition, imposition of a minimum subscribership requirement will only serve to discourage participation in the RDOF auction.  As WISPA explains, “if the Commission requires RDOF recipients to meet subscribership benchmarks, participation in the auction may be significantly depressed.”[12]  Similarly, NCTA notes that such a requirement “would add a level of uncertainty into the funding mechanism, including how much support would be needed to spur adoption in an area, and could potentially deter bidders.”[13]

For these reasons, GeoLinks urges the Commission not to adopt a mandatory subscription rate as part of the RDOF auction process.  Instead, the Commission can encourage broadband providers to take steps to secure higher subscription rates by implementing its proposed requirements that recipients deploy networks capable of supporting a 70% subscription rate and advertise the availability of their services in RDOF areas.

C.  In Order to Encourage More Rapid Deployment and Efficient Use of RDOF Funds, the Commission Should Not Impose the Letter of Credit Requirement

Several Commenters share GeoLinks’ concerns regarding the letter of credit (“LOC”) requirement proposed in the NPRM.  As GeoLinks noted in its opening comments, LOCs can carry significant burdens for service providers – especially small and medium sized service providers.  GeoLinks asserts that the proposed LOC structure will do nothing to promote the Commission’s goal of encouraging rapid deployment of broadband networks.  Instead, the Commission should consider alternative options to protect disbursed funds.

In the NPRM, the Commission considers options that will encourage faster build out from RDOF recipients.[14]  GeoLinks asserts that one way to encourage faster buildout is to refrain from requiring RDOF recipients to obtain LOCs.  As GeoLinks explains in its opening comments, one of the burdens that LOCs impose on service providers is the potential to hinder the ability to secure additional types of funding to procure equipment and other network essentials early in the buildout process.  This view is shared by Windstream, which explains that LOCs affect “a provider’s ability to finance its deployment obligations” by making the provider “a less attractive borrower, because the lender knows that the provider has a substantial (albeit contingent) outstanding financial obligation.”[15]  Without the ability to finance equipment upfront, service providers may have no choice but to stretch out their buildout timeline – making purchases on a rolling basis as funding comes in.  This does nothing to encourage (or allow) providers to speed up deployment efforts.

In addition, as GeoLinks and other explain, LOCs are expensive.  The costs associated with obtaining and maintaining an LOC often run service providers 3-5% of the total value of the LOC (if not more).  As CenturyLink illustrates, for example, these costs can be astronomical over the life of the LOC requirement.[16]  While the Commission has previously acknowledged that LOC’s carry costs, the assumption appears to be that service providers will simply bake those costs into their bids – in other words, that USF funds should be used for those costs.[17]  The flaw in this assumption, however, is that any USF funds used for bank fees, etc. are no longer available for actually deploying broadband.

As the Joint Commenters explain, “it is the Commission’s responsibility to ensure that limited universal service funding is being used in [an] efficient and cost-effective manner.[18]  Moreover, as Incompas notes, “as the Commission recognizes in the NPRM, letters of credit can be costly, and bidders must take that into account in their auction participation.  That is money that would be better invested in the network itself.”[19]  Similarly, in advocating for the use of a performance bond over an LOC (discussed more below), WISPA suggests that a less fee-intensive option “could re-direct tens of millions of dollars from letters of credit fees to deployment.”[20]  Being able to use all obtained USF funds for USF deployment purposes rather than for bank fees, etc. will mean the ability for service providers to utilize USF funding more rapidly upon receiving it (vs. holding on to it to ensure all bank-related fees are paid before utilizing it for equipment, deployment, adding additional personnel, etc.).

For these reasons, the Commission should consider alternatives to the LOC in order to reach its goal to encourage faster buildout of broadband networks in RDOF areas.  There are a number of alternatives proposed by commenters.  GeoLinks supports several of them.  As an initial matter, GeoLinks supports the proposal by Incompas that “the Commission should allow small providers to demonstrate capability through means other than letters of credit,” such as “participation in other build projects, such as E-Rate of another federal or state grant project.”[21]  GeoLinks supports the idea that participation in another project could serve as assurance to the Commission that RDOF funds will be utilized in an effective manner.  Specifically, GeoLinks suggests that the Commission refrain from requiring LOCs from CAF recipients that are meeting their performance milestones.

However, if the Commission believes some mechanism must be used for all RDOF recipients regardless of past performance, GeoLinks supports the use of a performance bond in lieu of an LOC.  As WISPA explains in its opening comments, “if rules are appropriately crafted, performance bonds can accomplish the same objectives as letters of credit, with the added benefit of giving RDOF recipients flexibility to rely on a less expensive or otherwise better financial instrument.”[22]  Specifically, WISPA cites The Surety & Fidelity Association of America and the National Association of Surety Bond Producers which explain that a performance bond “is the result of the surety’s review of the financial strengths and capabilities of the carrier in determining whether to provide the bond.”[23]  This group explains that a performance bond “serves as a ‘deep pocket’ in the event the carrier fails” while an LOC “simply does not provide the same financial guarantee to the government.”[24]  For these reasons, and those set forth in its opening comments, GeoLinks urges the Commission to adopt a performance bond requirement over an LOC requirement.

In addition to a performance bond requirement, GeoLinks would also support alternative options for RDOF recipients (that recipients could chose between depending on their specific financial needs/ realities).  One such option would be for a service provider to place a set amount into escrow, as suggested by Windstream.[25]  This would serve as an upfront payment similar to spectrum license auctions.  As Windstream explains, “the provider would be permitted to take the funds out of escrow as soon as it certifies that it has met its first deployment milestone” and “should the provider withdraw before funding is disbursed or if it should fail to meet its first milestone on year after the deadline…the provider [would] be referred to the Enforcement Bureau.”[26]  GeoLinks agrees that “this requirement would ensure that providers have ‘skin in the game’ before they place their bids, not after.”[27]  Another option would be the reduced LOC option that GeoLinks proposed in its opening comments.  Specifically, GeoLinks suggested that the Commission reduce the LOC amount required for each year based on whether certain performance metrics have been met by an RDOF recipient.  This concept is also supported by WISPA, which proposed that as an alternative to the performance bond requirement, the value of a letter of credit should “be reduced by the same percentage as the service milestone that the RDOC recipient has satisfied.”[28]

GeoLinks supports elimination of the LOC requirement for all RDOF recipients as proposed in the NPRM.  Specifically, GeoLinks urges the Commission to either eliminate the requirement for service providers that have previously been awarded CAF funding or, if some mechanism must be used, to adopt a performance bond requirement with the option to obtain a reduced LOC, depending on the preference of the service provider.  GeoLinks believes that these alternatives will help the Commission protect its financial interests while meeting its goals of encouraging rapid deployment of RDOF services and ensuring USF funds are used in the most efficient manner possible.

CONCLUSION

GeoLinks commends the Commission on its efforts to deploy high speed broadband to the remaining unserved areas of the country.  While GeoLinks largely supports all of the Commission’s proposals regarding the RDOF, the Company urges the Commission to encourage faster buildout and avoid discouraging participation in the RDOF auction by ensuring RDOF remains technology neutral, refraining from imposing a subscribership threshold upon which funding is contingent, and considering alternatives to the LOC requirement.

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

October 21, 2019

 

[1] Rural Digital Opportunity Fund, Notice of Proposed Rulemaking, WC Docket No. 19-126, FCC 19-77 (rel. Aug. 2, 2019) (“NPRM”).
[2] Comments of National Rural Electric Cooperative Association, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) (“NRECA Comments”) at 8.
[3] Id.
[4] Comments of the North Dakota Joint Commenters, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) at 2.
[5] Comments of Windstream Services, LLC, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) (“Windstream Comments”) at 20.
[6] Comments of the Wireless Internet Service Providers Association, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) (“WISPA Comments”) at 21-22, citing 47 U.S.C. §254(d).
[7] Id. at 21 (emphasis added).
[8] Notably these commenters represent varying company sizes, interests, and technology types.
[9] Comments of CenturyLink, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) (“CenturyLink Comments”) at 18.
[10] Comments of California Emerging Technology Fund, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) at 14.
[11] Comments of WTA-Advocates for Rural Broadband, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) at 21.
[12] WISPA Comments at 8.
[13] Comments of NCTA – The Internet & Television Association, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) at 8.
[14] See NPRM at 28 seeking comment on whether the Commission should require support participants to build out to 50% of the requisite number of locations in a state by the end of year three.
[15] Windstream Comments at 18.
[16] See CenturyLink Comments at 13.  The chart CenturyLink includes in its comments assumes a 2.5% LOC fee.  These numbers will be higher, relatively, for smaller companies who likely have secured LOCs at a higher rate.
[17] Connect America Fund, et al., Report and Order and Further Notice of Proposed Rulemaking, WC Docket Nos. 10-90, 14-58 and 14-259, 31 FCC Rcd 5949 (2016) (“CAF Phase II Auction Order”) at para. 139 – “While we understand that the requirement will impose costs on participants, we expect that all entities will factor the cost of letters of credit into their bids.”
[18] Comments of the Pennsylvania Public Utility Commission (Pa. PUC), the Pennsylvania Office of Consumer Advocate and the Pennsylvania Office of Small Business Advocates (“Joint Commenters”), WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) at 5.
[19] Comments of Incompas, WC Docket Nos. 19-126 & 10-90 (filed Sept. 19, 2019) (“Incompas Comments”) at 13.
[20] WISPA Comments at 36.
[21] Incompas Comments at 13.
[22] WISPA Comments at 35.
[23] Id. at 36
[24] Id.
[25] Windstream Comments at 19.
[26] Id.
[27] Id. at 20.
[28] WISPA Comments at 40.

How to Create an IT Disaster Plan to Prepare for California Wildfires

How To Create Your IT Disaster Plan to Prepare for California Wildfires - GeoLinks.com

How to Prepare Your IT for Wildfires in California

Wildfires in California are a serious concern for any business. They present both a danger to the people working at your organization and to your operations as a whole. Many businesses create plans for the former concern, which is, of course, the most important. However, the latter, continuing operations during and after a wildfire, can be overlooked, especially concerning IT. Below are some tips on creating an IT disaster plan for California wildfires.

1) Analyze Your Vulnerabilities

Consider how your information technology would be affected by a natural disaster. For example, do you have server hardware on-site in your main office? Do you rely on Internet connectivity to work? If you have IT resources outside of your headquarters, where are they located?

Understanding your vulnerabilities is essential to creating an IT disaster management plan. By thinking through what would happen if your physical location(s) were shut down, you can prepare your business for lasting operations during and after a wildfire.

Keep in mind that IT disaster planning doesn’t just revolve around safeguarding computers and data. More important are the essential personnel who help keep your IT infrastructure running. Hopefully, you already have a plan in place to ensure the safety of your staff. If you don’t, that should be your number one priority.

Once you have planned for your team’s safety, consider how they will resume work during and after the disaster. Will they need to connect remotely? If so, how will you enable them to do so?

2) Set Priorities

In the event of a disaster, there are scenarios that may prohibit your company from immediately resuming full operations. To determine what business elements are most important to get up and running again quickly, set and communicate priorities beforehand.

For example, perhaps the top priority is to get everyone connected to your network and each other again. Or it may be to ensure your proprietary data is both secured and accessible.

Understanding these priorities will help you to create your IT disaster prevention and disaster recovery plan. It will also help your team members to maintain clarity in the event that things don’t go exactly as planned. They can make decisions on the fly more easily when they have pre-determined goals.

3) Plan Redundancy

One of the most important elements of any IT disaster management plan is redundancy. IT resources can become unavailable in the event of a disaster. This can include hardware hosted at your place of business, overall network infrastructure, off-site resources, and more.

For example, if your business currently uses a terrestrial-based Internet connection, you may find yourself disconnected in the event an earthquake or wildfire damages nearby network infrastructure. Unfortunately, repairing damage can take a long time depending on the extent of the destruction. A great solution to avoid this vulnerability is to have two Internet circuits, a fiber optic connection (terrestrial) and a fixed wireless circuit (air), that issues automatic failover via a SD-WAN device in the event one experiences an outage. Having duel Internet circuits also ensures a business’s hosted VoIP connections remain active during a wildfire.

All in all, establishing IT redundancy ensures business continuity in the case of a wildfire or other natural disaster.

4) Plan for Data Continuity

No matter what business you are in, data is important. Perhaps your business is quite literally based on collecting and analyzing data. Perhaps you use customer information to make critical marketing decisions. Regardless of how you use the data, having access to critical business information is vital.

If you let it be a vulnerability, you may find your bottom line significantly impacted when a wildfire hits California.

Thus, cloud-based data back-ups are an absolute must for any business. If your business isn’t currently leveraging the cloud, it is time to get started. Additionally, you should have at least one back up drive located off-site. Issuing nightly backups of your key data is also strongly encouraged.

5) Evaluate Your Insurance

For many businesses, IT resources represent a significant investment. You need the proper insurance coverage to ensure that you can reestablish your operations promptly without risking your cash flow. This is especially true for California businesses given the state’s frequency of catastrophic events including wildfires and earthquakes.

Policies such as business interruption, loss of use, and extended coverage are worth significant considerations for any CA-based business. Insurance should be a component of every business’s IT disaster plan.

Getting Ready for the Next Wildfire

Whether you are ready or not, you may be affected by a wildfire in the very near future. It is best to have a plan in place so you’re prepared to handle the situation. Having a strong IT disaster management plan can make all the difference in the world.

Finding the right resources, such as GeoLinks’ GeoLit Bundle, will help you ensure your business continues operations even after a disaster.

GeoLinks Reply Comments on Establishing the Digital Opportunity Data Collection

Before the

Federal Communications Commission

Washington, DC  20554

GeoLinks Reply Comments Establishing the Digital Opportunity Data Collection

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 received on the Report and Order and Second Further Notice of Proposed Rulemaking issued August 6, 2019 in the aforementioned proceedings.

INTRODUCTION AND SUMMARY

GeoLinks commends the Commission on its efforts to modernize its broadband data collection processes.  While the 2nd FNPRM proposes several improvements to how the Commission currently collects broadband data some proposals fail to take into account the fundamental differences that exist between technology types and the resources available to small and mid-sized service providers.  GeoLinks presents these reply comments to provide guidance to the Commission regarding data collection methods that are best suited for collecting fixed wireless broadband availability data.

DISCUSSION

  • The Commission Should Adopt the Safe Harbor Provisions Proposed by WISPA While Allowing Service Providers Flexibility When Submitting Availability Data.

GeoLinks supports the safe harbor approach proposed by the Wireless Internet Service Providers Association (“WISPA”).   WISPA’s proposal recommends “a two-pronged process to be used by fixed wireless providers to create propagation maps that better illustrate deployment coverage for various fixed wireless spectrum bands.”  GeoLinks believes that WISPA’s proposed solution strikes the right balance between the Commission’s interest in securing granular broadband availability data and the realities of fixed wireless service.  Especially for smaller providers that may not have in-house broadband mapping expertise or designated mapping resources, this safe harbor process will allow for easily calculable service area boundaries.

As GeoLinks explained in its opening comments, a variety of factors including the location of transmission towers, specific equipment used, available spectrum bands, and line-of-sight from a tower come into play when measuring broadband availability.  This concept is also echoed by Alaska Communications, which explains that “coverage and broadband performance can vary widely” due to factors beyond a service provider’s control.  This includes changing weather, foliage growth, new construction, etc.  Moreover, as the Commission itself explains, determining the area that a broadband provider services “is highly idiosyncratic and determined by multiple factors.”  These factors make the creation of fixed wireless service polygons difficult.  In addition, as Connected Nation explains, “many providers, particularly small cable and fixed wireless companies, do not have the internal GIS expertise to software to create granular and accurate coverage polygons without assistance, regardless of how well the technical standards for polygon creation are defined.”

Alaska Communications asserts that “in order to provide a reliable and uniform standard for reporting fixed wireless coverage…the Commission should adopt the fixed wireless safe harbor proposal submitted by [WISPA].”  GeoLinks agrees.  In the case of small fixed wireless providers, it stands to reason that while creation of a polygon from scratch may be difficult, the location of a company’s equipment and what frequency that equipment is using to provide service is known.  Using WISPA’s safe harbors, fixed wireless service providers could utilize the equipment data they have readily available paired with reasonable estimations of coverage parameters based on the spectrum band utilized to create a polygon that is a reasonable representation of its service territory.  This would allow the Commission to obtain more granular fixed wireless availability data without creating a data submission process that disproportionately affects one technology type/ company size over others. Therefore, GeoLinks strongly urges the Commission to adopt WISPA’s safe harbor parameters as a reporting option for fixed wireless service providers.

In addition to the safe harbor provisions, which GeoLinks believes will be broadly used by fixed wireless service providers, the Company also recognizes the value of allowing for reporting flexibility.  As GeoLinks explained in its opening comments, there may be some instances where additional coverage area outside of the safe harbor parameters is realized. In order to ensure the most accurate data possible, GeoLinks urges the Commission to allow fixed wireless service providers the option to submit polygons that depict this expanded coverage.  In doing so, GeoLinks urges the Commission to allow flexibility in how providers develop these polygons. As Verizon explains, providers should “be permitted to rely on their own services, network designs, and internal data to produce accurate and reliable polygon maps of service coverage.” GeoLinks agrees and provides as an example the suggestion made by ACA that the Commission “permit providers to file polygons in different file formats, including KMZ format which can be readily produced from Google Earth at lower cost that other formats.”

Based on the foregoing, GeoLinks asserts that the Commission should allow fixed wireless providers to submit polygons that follow the safe harbor standards proposed by WISPA or polygons depicting alternative coverage data utilizing flexible methods that track how the provider measures its service territories internally.

  • The Commission Should Establish Polygon Reporting by Speed Tier

In the 2nd FNPRM, the Commission asks what additional steps the Commission “can take to improve the quality of fixed broadband coverage polygons while minimizing the associated reporting burdens.”  GeoLinks agrees with commenters that propose that polygons be required for Commission-specified speed tiers.  As Alaska Communications explains, to help mitigate the burden associated with “developing separate polygons for every possible combination of download and upload speed, platform technology, and target customer,” the Commission should “establish bandwidth tiers (each covering a reasonable range of bandwidths) that may be represented by a single polygon.”  While GeoLinks may market specific speed tier offerings in some areas, the reality of fixed wireless technology is that almost any upload and download combination is possible with the appropriate engineering.  And GeoLinks’ customers subscribe to a wide variety of speed combinations despite the standard “tiers” offered.

Reporting by standardized speed tiers would allow service providers to easily report relevant data pertaining to its availability without running the risk of potentially having to create numerous polygons for the same area to reflect customer subscription variation.  For these reasons, GeoLinks urges the Commission to create standardized reporting bandwidth tiers.

  • The Commission Should Not Require Fixed Broadband Providers to Report Latency Levels

Several commenters agree with GeoLinks that the Commission should not impose latency testing on broadband service providers.  Unlike CAF recipients, average service providers are not prepared at this time to roll out latency testing and don’t have the benefit of high-cost funding to supplement the costs.  Therefore, requiring this now would impose significant burdens on broadband providers to develop and deploy testing measures unique to their networks.

Depending on the applicable protocol and engineering of a network, a service provider can provide high speed broadband to its customers and a high-quality user experience even with what may be considered higher latency.  Therefore, so long as a customer is obtaining the speeds they expect, latency is unimportant. Moreover, as NCTA explains, “in the past, the Commission has recognized that it is reasonable to presume that a provider that is meeting the applicable speed threshold is also meeting any applicable latency standards.”

The imposition of requiring latency reporting hardly seems worth it given the minor value (if any) that would result from it.  In fact, even some advocates of latency reporting admit there is no immediate need for this information.  As Verizon succinctly explains, obtaining latency data to go along with coverage polygons “will impose significant burdens on providers and will provide little useful information beyond what already is available.”

GeoLinks urges the Commission not to impose latency reporting on broadband service providers at this time.  Instead, GeoLinks suggests that the Commission review latency testing data submitted under CAF and monitor consumer complaints for any latency-related issues.  If latency becomes an issue that affects customers or if CAF providers chronically report higher latency than the maximum threshold allowed under CAF, then the Commission can revisit the concept of latency reporting for all broadband providers.

  • The Appropriate Timeframe for Filing Corrected Broadband Availability Data is with a Service Provider’s Next Reporting Opportunity

GeoLinks urges the Commission not to implement correction timeframes that impose additional burden on service providers.  As explained by numerous commenters, smaller providers generally don’t have in-house broadband mapping teams that can easily revise availability polygons on a rolling basis.  Instead, GeoLinks agrees with the Joint Commenters and Alaska Communications that service providers should be required to submit corrections in conjunction with their next scheduled semi-annual polygon update.

  • The Commission Should Not Impose Enforcement Measures for Unintentional Filing Errors

Some commenters urge the Commission to impose enforcement measures on service providers for any mistakes made during the reporting process, ever if inadvertent.  The City of New York, for example, asserts that the Commission should “penalize providers for reporting errors, whether intentional or not.”  Similarly Free Press “strongly urge[s] the Commission to adopt penalties for submitting inaccurate data, which should be particularly severe for ‘chronic filers of bad data.’”  However, GeoLinks cautions against imposing strict penalties on service providers who make unintentional errors.

As an initial matter, the collection procedures the Commission proposes are largely new.  There will inevitably be growing pains as service providers develop internal best practices for collecting, compiling, mapping, and submitting availability data.  Therefore, at a minimum, the Commission must allow reasonable time for service providers to shore up processes before considering enforcement actions – and should allow additional time (or offer additional resources) to smaller providers.  Secondly, and most importantly, the risk of enforcement action for any mistakes, even if unintentional, will only serve to encourage service providers to underreport service availability to avoid the potential of having something challenged.  This does nothing to move forward the Commission’s goals of creating an accurate snapshot of broadband availability.

Instead, the Commission should focus its efforts on improving data submissions and helping service providers perfect collection practices.  As NCTA notes “when errors are identified, the Commission should focus on correcting data so that its future maps are as accurate as possible, not punishing providers for good-faith mistakes.”

  • The Commission Should Create an Evidence-Based Challenge Process

GeoLinks asserts that any service availability disputes must include not only a certification but also proof that the service provider declined to provide service.  This concept was also proposed by NCTA, which asserts that the Commission should create an “evidence-based challenge process that places substantive evidentiary requirements on the party submitting the challenge.” Similarly, Verizon explains that certification by itself “does not go far enough to ensure that the Commission and providers are not bogged down…from meritless public challenges” and suggests that the Commission “consider other ways to ensure that its process to make its maps more informed does not become consumer by bad data or open the door to unnecessary or cumbersome procedures.”  For these reasons, GeoLinks urges the Commission to require that disputes not only include a certification but also include proof that the service provider declined to provide service.  This should be true for individual disputes and bulk disputes alike.

  • Crowdsourced Data Should be Used for Informational Purposes Only

In the 2nd FNPRM, the Commission seeks comment on how to best use crowdsourced data “to improve the quality of the service-availability dataset going forward.”  While crowdsourcing data can be used to assess customer experience trends, GeoLinks agrees with commenters that assert that not all crowdsourced data is reliable or relevant.  As Alexicon asserts that “the effectiveness of crowd sourcing is only as good as the crowd, so the Commission must adopt rules that ensure the process takes into account only legitimate concerns, provides for a simple process for addressing any undisputed discrepancies, and allows reporting carriers to make any necessary corrections without fear of immediate reprisal.”

In GeoLinks’ experience, factors outside of the service provider’s control can affect crowdsourced broadband speed data (for example).  Such factors include customer equipment, the reliability of the speed data test platform, etc. When present, these factors can yield results that are not reflective of a service provider’s network performance and, if relied on at face value by USAC, could paint an inaccurate picture of a service provider’s network availability footprint, skewing the Commission’s mapping efforts.  As WTA explains, “the overriding problem with crowdsourcing is that it seeks to test the entire Internet experience of the customer, which is impacted by multiple factors…not just the network of the providers.”  Moreover, as NCTA asserts, “online speed tests that do not control for factors outside the control of the provider should not be used for the purpose of assessing the validity of a provider’s reported deployment.”  In light of these potential limitations of crowdsourced data, GeoLinks encourages the Commission to heed the suggestion posed by WTA and use crowdsourced data for informational purposes only and consider crowdsourcing “a complement to, and [not] a substitute for, robust and meaningful evidentiary challenge processes.”

CONCLUSION

GeoLinks commends the Commission on its efforts to modernize its broadband data collection processes.  In order to ensure that the process takes into account the fundamental differences that exist between technology types and resources available to small and mid-sized service providers, GeoLinks urges the Commission to adopt the recommendations set forth herein.

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks

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

 

October 7, 2019

 

GeoLinks Opening Comments on Establishing the Digital Opportunity Data Collection

Before the

Federal Communications Commission

Washington, DC  20554

Establishing the Digital Opportunity Data Collection - GeoLinks

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these Comments in response the Report and Order and Second Further Notice of Proposed Rulemaking issued August 6, 2019 in the aforementioned proceedings.

INTRODUCTION AND SUMMARY

GeoLinks is one of the fastest growing Internet and phone providers in America and the #1 fastest growing fixed wireless service provider in California.  While the Company originally  focused on business and enterprise customers, in 2016 GeoLinks turned its focus to expand its customer base to include unserved and underserved areas throughout California and beyond.

GeoLinks is an advocate for improved broadband availability mapping and commends the Commission on its efforts to modernize its broadband data collection processes.  While the 2nd FNPRM proposes some improvements to how the Commission currently collects broadband data other proposals fail to take into account the fundamental differences that exist between technology types and resources available to small and mid-sized service providers.  GeoLinks presents these comments to provide guidance to the Commission regarding data collection methods that are best suited for collecting fixed wireless broadband availability data.

DISCUSSION

  • The Commission Should Adopt the Safe Harbor Provisions Proposed by WISPA

Fixed Wireless technology is unique.  Because it utilizes direct, line-of-sight connections (from specific point to specific point), some characteristics are similar to wireline technology. Similarly, because it is wireless and does not carry the connection requirements of wireline technology (i.e. physical wires), it also shares many characteristics to mobile wireless.  However, it is neither wireline nor mobile wireless and, therefore, requires broadband reporting processes specifically tailored to account for these differences.

As proposed, the data collection processes set forth in the 2nd FNPRM do not work for fixed wireless providers.  A variety of factors including the location of transmission towers, specific equipment used, available spectrum bands, and line-of-sight from a tower, are all factors that must be considered when engineering a fixed wireless network.  Logically, these factors also come into play when measuring broadband availability and therefore make the creation of a reporting polygon extremely challenging (at least in the form proposed by the 2nd FNPRM). Therefore, the Commission must look to adopt a solution that allows it to obtain the granular data it seeks while accounting for the technological differences of fixed wireless services.

GeoLinks supports the reporting approach previously advocated by the Wireless Internet Service Providers Association (“WISPA”).  As WISPA explained, “in order to fulfill the overall objectives for accurate data for all areas of the country, especially rural areas, modernization must take into account the inherent differences in deployment and technology between wired broadband services and fixed wireless broadband services, as well as recognize and reduce the significant financial burdens on small providers.”  As such, WISPA’s proposal recommended “a two-pronged process to be used by fixed wireless providers to create propagation maps that better illustrate deployment coverage for various fixed wireless spectrum bands.”  GeoLinks believes that this proposed solution strikes the right balance between the Commission’s interest in securing granular broadband availability data and the realities of fixed wireless service and strongly urges the Commission to adopt WISPA’s safe harbor parameters.

One addition to WISPA’s proposal that GeoLinks would suggest is the option for fixed wireless service providers to provide expanded coverage information if service availability areas extend further than the proposed safe harbor parameters.  While GeoLinks believes that the safe harbor parameters proposed by WISPA are generally good measures of the broadband service parameters that will be realized, the Company also believes that in some instances, additional coverage area may be possible.  To ensure the most accurate reporting possible, GeoLinks urges the Commission to adopt the safe harbors in WISPA’s proposal with the option for service providers to provide a more expanded polygon if they so choose.  GeoLinks understands that any polygon areas that fall outside of the safe harbor areas would be subject to additional scrutiny by the Commission.

  • The Commission Should Require Broadband Service Providers to File Corrected Broadband Availability Data with Their Next Reporting Opportunity

In the 2nd FNPRM, the Commission proposes that USAC “ensure that providers refile updated and corrected data in a timely fashion,” and seeks comment on the “appropriate time period (if any) for fixed providers to respond to a complaint.”  GeoLinks agrees that any data provided by a broadband provider that is inaccurate should be corrected.  In the case of fixed wireless providers, any data that a provider chooses to provide outside of established safe harbors could be subject to correction, if inaccurate.  However, GeoLinks urges the Commission not to implement correction timeframes that impose additional burden on service providers.

The Commission should require that any corrected data be submitted with a service provider’s next filing opportunity, per the requirements of DODC.  Broadband reporting efforts are time and resource intensive. This is especially true for small and mid-sized providers that may not have in-house GIS specialists or data analysts dedicated to broadband mapping.  Requiring service providers to incur the cost of filing frequent corrections may result in service providers underreporting broadband availability to avoid filing corrections. Instead, lumping corrections in with the required reporting at a set interval (as proposed in the 2nd FNPRM) will not require service providers to allocate more resources than they already do for these ongoing filings.  Moreover, this will ensure the most accurate data possible is provided at each filing deadline. For these reasons, GeoLinks urges the Commission to allow service providers to correct any inaccurate data with their next filing.

The 2nd FNPRM also asks whether the Commission should require providers to resubmit all earlier datasets for the affected areas to conform to any corrections.  GeoLinks sees no value in resubmitting old data that may be outdated anyway.  First, broadband data for small and mid-sized carriers may change overtime due to customer attrition, changes in equipment used, network updates, etc.  Therefore, past data sets may be different than newly reported data sets and requiring correction could mean re-submitting incorrect data. In addition, as stated above, broadband data reporting is already a time and resource intensive effort for small and mid-sized service providers.  To require submission of new data and old data when an error is found could double or triple the work required for no actual benefit to the Commission’s mapping efforts. Instead, GeoLinks urges the Commission to just require the most correct data be submitted at each reporting deadline and use that data to populate its broadband availability tools.

  • The Commission Should Require Individuals to Provide Proof that a Service Provider Declined to Provide Service Within the Applicable 10-Business Day Period

In the 2nd FNPRM, the Commission proposes to require “that individuals disputing coverage certify that they have requested service from the provider and that the provider either refused, or failed, to provide service within the applicable 10-business day period.”  While GeoLinks believes that certification is a good start, false certifications would be difficult to determine prior to the Commission/ USAC and the subject service provider expending time and resources to investigate.  Therefore, the Company urges the Commission to go one step further and require that disputes not only include a certification but also include proof that the service provider declined to provide service. This could perhaps be in the form of an email from the service provider to the individual, a cancelled service order, or a transcript from a call to customer service.  This proof requirement will help ensure that the Commission/ USAC and service providers are only investigating legitimate disputes. Moreover, this would also help eliminate the risk of malicious challenges via automated tools or bots.

  • The Commission Should Not Require Fixed Broadband Providers to Report Latency Levels

In the 2nd FNPRM, the Commission seeks comment on “whether fixed broadband providers should include latency levels along with the other parameters in reporting their coverage polygons.”  The simple answer is “no” for a number of reasons.

As an initial matter, latency testing is not something commonly done by service providers because it is costly and doesn’t provide valuable data to the provider.  While latency testing is required under CAF, CAF recipients are only required to test a subset of customers, built the costs of such testing into their CAF auction bids, and are receiving high-cost support, in part, to undertake this testing.  To impose it on every service provider for all data provided would be extremely burdensome. Second, GeoLinks fails to see what value this data would be to the Commission to warrant such burdensome testing requirements. Depending on the applicable protocol and engineering of a network, a service provider can provide high speed broadband to its customers and a high-quality user experience even with what may be considered higher latency.  From this perspective so long as the customer is obtaining the speeds they expected, a specific latency measurement is unnecessary. Lastly, latency is not a measure of broadband “deployment,” which the Commission states is “critical to the Commission’s efforts to bridge the digital divide.” Therefore, and for the foregoing reasons, GeoLinks urges the Commission to not impose the burden of latency testing on providers.

CONCLUSION

GeoLinks commends the Commission on its efforts to modernize its broadband data collection processes.  In order to ensure more granular data that takes into account the fundamental differences that exist between technology types and resources available to small and mid-sized service providers, GeoLinks urges the Commission to adopt the safe harbor proposal set forth by WISPA, only require service providers to file corrected data with its next submission opportunity (and only on a forward-looking basis), require proof of service denial in the dispute process, and refrain from requiring service provider to provide latency data that will not improve the Commission’s understanding of the current status of broadband deployment.

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks

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

 

September 23, 2019

 

GeoLinks’ Comments to the FCC on Rural Digital Opportunity Fund

Before the

Federal Communications Commission

Washington, DC  20554

Rural Digital Opportunity Fund - GeoLinks.com

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

September 20, 2019

 

SUMMARY

California Internet, L.P. dba GeoLinks (“GeoLinks” or the “Company”) is one of the fastest growing Internet and phone providers in America and the #1 fast growing fixed wireless service provider in California.  While the Company had previously focused on business and enterprise customers, in 2016, GeoLinks turned its focus to expand its customer base to include unserved and underserved areas throughout California and beyond.  GeoLinks was recently named an auction winner in the Connect America Fund Phase II (“CAF”) Auction securing funding to connect more than 11,000 unserved locations making it the largest CAF winner in California and the fifth largest overall.

GeoLinks supports the creation of the Rural Digital Opportunity Fund (“RDOF”) and largely supports all of the Commission’s proposals regarding the RDOF.  In particular, the Company agrees that the Commission should make 25 Mbps/ 3 Mbps the minimum standard for high speed broadband service and should prioritize areas at risk for falling further behind the rest of the country.  GeoLinks also supports the Commission’s efforts to speed up broadband deployment and minimize administrative burdens on RDOF recipients.  

However, there are some proposals that pose serious issues and could result in diminished participation in the RDOF auction, resulting in many areas remaining unserved by high speed broadband services.  In particular, the Commission’s proposed Letter of Credit (“LOC”) requirement and proposed subscribership reporting requirement pose significant threats to the success of the RDOF program and should be rejected.  GeoLinks provides these comments to provide input into the proposed RDOF auction processes and requirements.   

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these Comments in response the Notice of Proposed Rulemaking (“NPRM”) issued August 2, 2019 in the aforementioned proceedings.

INTRODUCTION

GeoLinks commends the Commission on its efforts to deploy high speed broadband to the remaining unserved areas of the country.  As a service provider focused on the unserved market, GeoLinks understands the challenges associated with deployment to these areas.  Moreover, as a CAF award winner, GeoLinks understands the intricacies of the reverse auction process and recognizes what works for small to medium sized service providers and what may not.  While GeoLinks supports the creation of the RDOF and largely supports all of the Commission’s proposals regarding the RDOF, there are some proposals that could result in diminished participation in the RDOF auction.  GeoLinks explains these issues below and provides these comments to provide input into the proposed RDOF auction processes and requirements.  

DISCUSSION

  • The Commission Should Make 25/3 Mbps Service the Minimum and Prioritize Areas That Lack Services Above 10/1 Mbps

In the NPRM, the Commission “proposes a 25/3 Mbps service availability threshold as the basis for establishing eligible areas.”  The NPRM also proposes a baseline performance threshold of 25/3 Mbps, eliminating the 10/1 Mbps Minimum performance tier that was in place for the CAF Auction.  GeoLinks supports both of these proposals.  While GeoLinks believes that broadband funding should promote “future proof” network construction, the Company also understands the realities of providing high speed broadband to far reaching areas that require brand new infrastructure in order to serve.  Therefore, it is reasonable that there be an attainable minimum. GeoLinks urges the Commission to make 25/3 Mbps the minimum threshold for broadband speed under the RDOF (for all auction-related purposes).  

While GeoLinks would like to see all areas without at least 25/3 Mbps service available for support immediately, the Company also understands that it may be prudent to prioritize areas with the slowest Internet speeds in order to ensure these areas don’t fall further behind the rest of the country.  In the NPRM, the Commission seeks comment on prioritizing areas that entirely lack 10/1 Mbps or better fixed service and asks how it should do so.  GeoLinks supports the idea of higher reserve prices and/or additional bidding credits for these areas.  In GeoLinks’ experience, sometimes even with a 100% subsidy for the costs of an area, the economics still do not make sense to build infrastructure that the company will incur additional costs to maintain, market, etc.  These areas likely suffer from the same realities. Therefore, higher reserve prices or credits may allow auction participants to craft bids in a way that make economic sense. In addition, GeoLinks would support a separate auction phase as a way to encourage rapid deployment in these areas.

GeoLinks does not believe that the Commission should prioritize areas solely on the basis that they entirely lack 4G LTE mobile wireless broadband service.  As the Commission itself has recognized, mobile and fixed broadband services are not full substitutes for each other in all cases.  For the purposes of RDOF, the Commission should focus on fixed broadband services which can be used to serve consumers, business, and anchor institutions.  While GeoLinks anticipates that there will be significant overlap between areas that lack 10/1 Mbps service and those that lack 4G LTE services, GeoLinks urges the Commission to base any prioritization on where fixed broadband is lacking.  

  • The Commission Can Encourage Faster Build Out by Offering Service Providers the Option to Front-Load RDOF Support

The NPRM asks whether the Commission should “require support recipients to build out more quickly earlier in their support terms by offering voice and broadband service to 50% of the requisite number of locations in a state by the end of the third year of funding authorization.”  GeoLinks supports the idea of faster deployment of highspeed broadband to unserved and underserved areas.  In fact, GeoLinks is hopeful to complete 100% of its CAF auction buildout milestones well before the applicable deadlines.  However, if the Commission does decide to ramp up the build out requirements as proposed, GeoLinks would urge the Commission to also offer RDOF recipients the option to ramp up RDOF funding distributions.  Under this scenario, if a service provider were expected to build out 50% within 3 years, then funding could be front-loaded during those three years to cover all construction and deployment costs associated with a 50% network build.  Then, after those three years, if funding was front-loaded and assuming the RDOF awardee meets its milestones, the Commission could ramp down payments over the remainder of the 10-year period.  

GeoLinks suggests that the Commission allow RDOF recipients who chose the front-loaded funding option to select how funding is distributed during the first three years.  The Commission could provide some standard options (e.g. 50% over the first three years and then the remaining 50% distributed over the last seven, etc.) for RDOF recipients to chose from (subject to reporting requirements).  Because offering this option would not change the overall RDOF budget, the Commission should be able to accommodate it without any risk to the USF fund. While the front-loading option may mean more payouts over the first few years of the program, this would be made up for over remaining years of reduced payments leaving the overall program budget the same.  

While GeoLinks believes that several RDOF recipients will take advantage of this front-loading option, GeoLinks notes that it must be an option (not a program rule) due to the current LOC requirement that the Commission proposes to require.  As GeoLinks explains in great detail below, the LOC requirement is very burdensome on service providers – especially small and mid-sized providers. They carry heavy fees, make it difficult for service providers to secure additional funding, if needed, and often require high collateral amounts.  If the Commission insists on requiring LOCs for RDOF, front-loading of funds will result in larger LOC amounts for the first years of the program. This structure may not work for some providers as they may be unable to obtain larger LOCs for the first few years of funding or the fees/ restrictions/ collateral requirements may outweigh the benefit of front-loading funding.  GeoLinks is hopeful that the Commission will adopt the option for RDOF recipients to obtain a performance bond for RDOF funding instead of an LOC. Regardless, a front-loading payment option should be at the RDOF recipient’s discretion.  

  • The Commission Should Harmonize RDOF Reporting Requirements with Those Required for CAF Auction Recipients

In the NPRM the Commission seeks comment on how it can align service milestones to minimize administrative burden.  GeoLinks asserts that all RDOF reporting deadlines should align with the applicable reporting deadlines imposed on CAF auction awardees.  This includes for service milestone reporting, location reporting deadlines, etc. GeoLinks believe that this will be the most administratively simple process.  Regarding deadlines for service providers that may be authorized to receive support on different dates, GeoLinks urges the Commission to still use the same reporting deadlines applicable to CAF for all awardees.  

  • The Commission Should Not Implement Subscribership Milestones as a Basis for RDOF Funding

GeoLinks generally supports the service milestones that the Commission proposes in the NPRM as they very closely track the requirements set forth for the CAF auction.  These service milestones have been thoroughly vetted via the comment process and the success of the CAF Auction and are good measures of awardee progress. However, the Commission proposes one new milestone, in particular, that will not serve to track a service provider’s progress in reaching its RDOF buildout requirements and, instead, may discourage providers from bidding on areas at all.  Specifically, the Commission’s proposed subscription requirement.  

In the NPRM, the Commission proposes “to also adopt subscribership milestones for Rural Digital Opportunity Fund support recipients” and suggests that the “proposal could set milestones at 70% (the subscribership level assumed by the CAM) of the yearly deployment benchmarks.”  The NPRM goes on the explain that “under this proposal, we would condition a portion of the recipient’s support on meeting the subscribership milestones.”  While GeoLinks is certainly not opposed to the requirement that an RDOF-funded project be designed to support a high level of subscribership, requiring service providers to ensure a high level of subscribership or risk losing funds for network that has already been built will only serve to discourage participation in the RDOF auction.  

From a statutory perspective, Universal Service Fund (“USF”) funds are only to be used for broadband deployment, not adoption.  Section 254 of the Communications Act of 1934 specifies that high-cost support can only be used “for the provision, maintenance, and upgrading of facilities and services for which the support is intended.”  This language only contemplates deployment of facilities, not adoption efforts.  Therefore, adoption requirements for RDOF would fall outside the scope of the FCC’s statutory authority with respect to Section 254.  

From a policy perspective, broadband “subscription” and “availability” should not be conflated.  While an RDOF-funded network should be able to support robust subscribership in eligible areas, there are more factors than just “where infrastructure is” that dictate whether a consumer chooses to subscribe to the services offered.  In many of the areas that RDOF will cover, consumers have lived with slow or no Internet connections for a long time. Consumers in these areas may not understand the benefits of highspeed broadband connections based on a lack of firsthand knowledge.  In these cases, many of these customers may opt to remain on their slower connections (if available) or may not see the benefit of connecting at all. This is a reality that the State of California has recognized in its ongoing implementation of the California Advanced Services Fund (“CASF”).  In 2017, the California Legislature made changes to the CASF program including the creation of the Broadband Adoption Grant Program to fund digital inclusion projects and broadband access projects that focus on broadband education, digital literacy, providing public broadband access, and community outreach.  The state legislature realized that availability alone is not enough to spur adoption and created additional grant funds to increase subscribership.  

Moreover, in addition to the possibility of a low consumer take rate, it is possible that RDOF recipients will face competition (including existing providers offering slow speeds or satellite providers that may not qualify for RDOF based on latency factors).  This can also affect subscriber numbers. If community members split subscriptions between the RDOF-funded provider and a competitive provider (or among more than one competitive provider), under the proposed subscribership requirement the RDOF-funded provider might be at risk for losing support for the area despite meeting all other requirements.  

GeoLinks believes that other aspects of the RDOF framework address the Commission’s concerns regarding subscribership.  First, networks must be robust enough to support a 70% subscription rate. Second, recipients, as ETCs, will be required to market services throughout their RDOF service territory.  Lastly, because there is a requirement to install within 10 days in order to claim an area as “served” there is certainty that a customer could subscribe if desired. For these reasons, GeoLinks strongly encourages the Commission to focus the efforts of RDOF to increasing and expanding broadband availability and not impose potentially impossible subscribership requirements.  

  • The Commission Should Eliminate the Standalone Voice Service Requirement

In the NPRM, the Commission proposes to require RDOF recipients to offer standalone voice service, as it did under CAF, and seeks comment on this proposal.  While GeoLinks is prepared to offer standalone voice service throughout its CAF award areas, the Company does not believe that this should be a requirement for RDOF funding.  Instead, GeoLinks urges the Commission to simply require that RDOF winners offer a voice service option, which can be available via a service bundle. If there is demand for a standalone voice option, RDOF winners will offer it.  However, if there is not, the Commission should not require an RDOF winner to incur the costs associated with ensuring a standalone voice service is available to all eligible locations within its RDOF service area.    

  • The Commission Should Adopt a Larger Minimum Geographic Area for the RDOF Auction

The NPRM seeks comment on “whether census block groups containing one or more eligible census blocks is an appropriate minimum geographic unit for bidding for the [RDOF]” or whether “a larger minimum geographic unit, like census tracts or counties” would be more manageable.  GeoLinks supports the idea of larger minimum geographic units, specifically census tracts.  GeoLinks believes that larger minimum geographic areas will promote RDOF bids that take into account more network synergies, which may result in lower bids and less draw from the USF.  Bidding by census block group, while successful under CAF, was more complex and made it more difficult for service providers to gauge costs over larger areas. For these reasons, GeoLinks supports a larger minimum geographic area for the RDOF auction.  

  • The Commission Should Not Impose a Letter of Credit Requirement Under RDOF

In the NPRM, the Commission proposes to require a letter of credit (“LOC”) from RDOF long-form applicants as it did in the CAF Auction and seeks comment on “whether the Commission should use alternative measures to protect disbursed funds.”  As a CAF award recipient, GeoLinks has firsthand knowledge of the LOC process, what banks require to obtain one, and the burden that LOCs carry for small to mid-sized service providers.  GeoLinks strongly opposes implementing an LOC process for RDOF and commends the Commission for being willing to consider alternatives.  

As an initial matter, LOCs are very expensive to obtain.  Even at a 3% fee (which GeoLinks believes is on the low end of what service providers are receiving), under CAF, because of the requirement that LOC amounts increase exponentially each year to align with fund disbursements, LOC fees paid to banks account for a sizeable chunk of total CAF funds; funds which could be used for additional broadband deployment.  While the Commission did address its understanding that LOC’s carry costs in the Phase II Auction Order, the assumption that service providers would simply bake those costs into their bids also assumes that USF funds should be used for those costs.  GeoLinks urges the Commission to consider alternative options that carry fewer costs to ensure that more USF funds, in this case RDOF funds, are used for broadband deployment rather than to pay bank fees.

Second, obtaining an LOC may hinder a provider from securing additional types of funding to procure equipment and other network essentials early in the buildout process.  In order to secure a large LOC, a provider may either be required to use a large percentage of their initial CAF funds as collateral against the LOC or may be required to agree to far reaching UCC liens that affect the provider’s ability to borrow additional funds.  In either event, such requirements make it difficult for service providers to engage in rapid deployment of new network infrastructure, even if the costs of an LOC are built into the CAF bid. The result is slower deployment as providers are forced to prioritize bank costs over buildout costs.

   Third, because of the way LOC requirements are currently written, LOC holders under CAF are being charged like a drawn line of credit, subject to EBITDA-to-debt ratios.  This means that as the LOC requirement grows, there is a risk that the LOC amount will outgrow a service provider’s lending ability with the financial institution issuing the LOC.  Under this scenario, even if a service provider is on track to complete its buildout requirements, it could find itself unable to maintain the line of credit needed for the LOC resulting in default.  This is especially true for small and mid-sized service providers.  

Fourth, as the LOC amount grows year over year, even if the service provider is able to secure the necessary LOC, some banks may not be able to take on the risk associated with funding the LOC.  For example, by years 3 and 4 an LOC requirement could reach tens of millions of dollars for some recipients. Under these circumstances, a service provider may need to secure multiple LOCs in order to cover the entire amount required by the Commission.  However, as mentioned above, if the provider does not have the requisite cash reserves, each bank may require a first position UCC lien. This may make it impossible for the carrier to secure more than one LOC. While discounts on the LOC amount are possible depending on buildout rate, as noted above, if initial CAF funds are being diverted to banks for LOC security and UCC liens are being imposed, obtaining additional funding in order to build network may not be possible.

Lastly, and perhaps most importantly, the LOC requirement disproportionately affects small and mid-sized service providers.  While one of the Commission’s stated goals for creating the RDOF reverse auction process is to encourage “intermodal competition,” the LOC process does not put providers on equal footing.  For example, a small, regional provider that has been offering service to a rural community may be the best solution to get high-speed service, tailored to the unique needs of those consumers, to any adjacent RDOF areas.  However, because this small provider may have fewer cash reserves than larger carriers or have a shorter history of creditworthiness, it will face an additional level of scrutiny in obtaining an LOC. This will inevitably makes securing an LOC very difficult, expensive and time consuming for the provider, which the provider must weigh against its interest in participating in the RDOF auction.  The unfortunate result may be that this provider opts not to participate in RDOF and that the adjacent unserved areas remain unserved.  

GeoLinks implores the Commission not to create policies that will divert USF funds away from their intended purpose, cause service providers to stall deployment, or preclude small and mid-sized providers from participating in the RDOF.  Instead, because the Company does realize the need for the Commission to protect itself, GeoLinks proposes the following alternatives to the LOC process. The Company believes these options strike the right balance between protecting the Commission’s interests and ensuring participation in the RDOF by small and mid-sized service providers. 

  • The Commission Should Implement a Performance Bond Option for RDOF Long-Form Applicants

In the NPRM, the Commission asks if there are viable, less costly alternatives to LOCs that still minimize risk to public.  One such alternative is a performance bond.  A performance bond requirement would provide the same protections for the Commission that an LOC would with far less cost to the USF fund and far less burden on RDOF recipients.  For example, like an LOC, performance bonds can carry stipulations on how the Commission would be able to receive compensation/ draw from the bond and would clearly define what a default would consist of.  However, unlike an LOC, there is less risk to the Commission of a service provider defaulting because it couldn’t obtain an LOC in later years of the program.  

As discussed above, the LOC requirement, as proposed and as required under CAF, is written to cover funding to be received in a coverage year AND funding that has been received to date.  While these amounts may start small, by year 3 or 4, these numbers can be astronomical and carry both heavy fees and heavy collateral or credit requirements. If a small or mid-sized service provider is unable to secure the collateral required to obtain an LOC or cannot overcome the other hurdles, a bank will refuse to renew the LOC and, under the Commission’s rules, will leave the RDOF recipient in default.  Meanwhile a performance bond carries far fewer collateral/ credit requirements while still offering the Commission the same amount of coverage. The reduction in risk of default alone should be enough to convince the Commission that a performance bond is the superior option, let alone the reduction in burden to RDOF recipients and to the USF.   

 By way of example, the California Public Utilities Commission has used performance bonds for its California Advanced Services Fund (“CASF”) broadband infrastructure grants since 2007 “to provide requisite assurance that [an] applicant has the financial resources to complete the broadband project.”  Specifically, the CPUC explained that the purpose of requiring a performance bond would be to “provide adequate financial safeguards, and reasonable certainty that the broadband project can be completed, or that funds can be retrieved from the applicant in event of nonperformance.”  As of April 2019, the CPUC has awarded more than $236 Million in grant funding for infrastructure builds, line-extensions, and in revolving loans.  To the best of GeoLinks’ knowledge, the CPUC has never acted to collect on any performance bond.  GeoLinks believes that the CASF fund can serve as a guide for the RDOF program and that a performance bond requirement will serve to adequately protect the Commission while reducing burden on service providers and on the RDOF fund.  

  • In the Alternative, the Commission Should Implement an Option for a Reduced Letter of Credit 

While GeoLinks has a strong preference for a performance bond option over an LOC requirement, the Company recognizes that there may be some providers that prefer the LOC process or need to obtain such an instrument due to some financial-related reason.  In this case, GeoLinks is not opposed to allowing service providers to obtain LOCs.   However, GeoLinks urges the Commission to reduce the LOC amount required from year to year.  Specifically, GeoLinks suggests that the Commission reduce the LOC amount required for each year based on whether certain performance metrics are met.  For example, if by the end of year 1 an RDOF recipient has reported building out to a certain percentage of eligible locations within its awarded area (perhaps 17%, which equates to approx. 1/6 of the buildout requirement to be reached within 6 years), the LOC amount would remain at a level equal to the funding to be disbursed in the applicable year (vs. that year plus the funding awarded in any previous years).  This would help keep the LOC cost reasonable and predictable.  Then the Commission could ramp down the requirement more each year as RDOF recipients reach higher completion percentages.  

To accomplish this reduced LOC option, the Commission must publish measurement criteria that can be monitored and measured by lending institutions that underwrite LOCs.  This will allow these institutions to track performance to more accurately assess risk. Even without additional reporting obligations to the Commission, these measurement criteria could be used for lending institutions’ internal reports required under an LOC arrangement to provide assurance that construction was being completed as mandated under RDOF.  

  • The Commission Should Require Less Technical Information from CAF Auction Winners in the RDOF Short Form Application Process

In the NPRM, the Commission asks if it should adopt the same two-step application process that the Commission adopted for the CAF Auction.  As a general matter, GeoLinks supports the current two-step process and believes it strikes the right balance to ensure the Commission can properly vet would-be auction participants prior to the auction and obtain all the needed information from auction winners before distributing funds without discouraging service providers from participating due to too much up-front work.  Therefore, GeoLinks urges the Commission to keep the two-step process.  

That said, the NPRM further asks whether the Commission should require “less information at the short-form stage from applicants that qualified to participate in the CAF Phase II auction.”  GeoLinks believes that applicants that the Commission deemed qualified to bid in the CAF auction have already made a strong showing of their technical and financial capabilities.  Therefore, unless there is a serious reason to re-vet these companies, it is reasonable to refrain from requiring them to submit brand new or repetitive info to prove their auction-worthiness.  However, GeoLinks would support a requirement that the pre-vetted applicant attest that nothing material has changed that would render previously submitted financial or technical information void.  Along this vein, GeoLinks believes that any CAF auction winner that defaulted on their winning bids should be subject to additional scrutiny under the RDOF short-form application phase to ensure that additional defaults do not occur.  But they should not be precluded from bidding.

CONCLUSION

GeoLinks commends the Commission on its efforts to deploy high speed broadband to the remaining unserved areas of the country.  While GeoLinks largely supports all of the Commission’s proposals regarding the RDOF, the Company urges the Commission to create policies that will prioritize deployment to areas that currently do not have service over 10/1 Mbps, encourage faster buildout, and avoid discouraging participation in the RDOF auction.  In particular, GeoLinks urges the Commission to reject its proposed LOC and subscribership reporting requirements.     

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

September 20, 2019

 

How SD-WAN Can Benefit Your Multi-Location Business

How SD-WAN Can Benefit Your Multi-Location Business - GeoLinks.com

Software-defined wide area network technology (SD-WAN) is a powerful tool for businesses that rely on the Internet to operate. It is especially beneficial for multi-location businesses. Of course, every company’s needs are a little different. So, is SD-WAN right for your business?

Read on to learn more about its benefits and uses for multi-location businesses.

What Is SD-WAN?

A wide area network (WAN) is a telecommunications network that covers a large geographical area. Unlike a local area network (LAN), a WAN can connect devices and networks to the Internet and cloud-based service providers. Its primary purpose in the business world is to connect an organization’s locations together so that they can work securely and efficiently.

Software-defined wide area networks use software to simplify the delivery of the WAN. It is an answer to the problems of two prior technologies: traditional WANs and multiprotocol label switching (MPLS). WANs spread over large areas tend to suffer from connection quality issues. MPLS addresses this but is expensive and slow to deploy.

SD-WAN offers many technical advantages over traditional WANs without all the logistical drawbacks of MPLS. Unlike a conventional WAN which relies on a hardware network, SD-WAN, such as the service offered by GeoLinks, can be managed virtually.

What Are the Benefits of SD-WAN for a Multi-Location Business?

Multi-location businesses can utilize SD-WAN to connect their headquarters with outside branches. This may be an organization with people working in offices all over the globe or it may be a retailer with a few locations around a city. Unlike MPLS which requires the use of a singular telecom across every location, SD-WAN is carrier agnostic allowing you to customize your bandwidth per location.

A business in Los Angeles with satellite locations in San Bernardino and San Diego, for example, may need to run applications that work efficiently between all three sites. SD-WAN would enable them to do so, simply and cost-effectively. If the team wanted to open another location in Riverside, SD-WAN would make connecting the new office seamless.

These are some of the reasons to choose SD-WAN to connect your business locations:

  • Cost Savings: Relative to other modern WAN options such as MPLS, SD-WAN is less costly to deploy and to maintain.
  • Efficient Routing: More traditional technologies such as MPLS are not routed based on application demand. SD-WAN, conversely, uses optimized path routing to ensure prioritized applications have the best possible performance.
  • Fast Deployment: SD-WAN is software-based and delivered through the cloud. Requiring just an edge device installed on site, setting it up is both fast and cost-effective. This makes it very simple to quickly connect another branch or remote office.
  • More Stable Internet: Businesses that rely on the Internet to operate can benefit from SD-WAN as it can seamlessly combine multiple Internet connections. Capable of jitter buffering, forward error packet correction, dynamic link steering, and issuing automatic failover to a backup connection in the event one connection fails, SD-WAN ensures an organization has true business continuity. For certain businesses, this can make a critical difference.
  • Centralized Monitoring: SD-WAN offers multi-location businesses functionality to monitor the network in real-time from anywhere. So, your headquarters can keep an eye on all network activity and remotely address any issues. This significantly simplifies network maintenance when compared to a hardware-based solution.

Which Multi-Location Businesses Benefit From SD-WAN?

Which Multi-Location Businesses Benefit From SD-WAN? - GeoLinks.com - Rodeo Drive

  • Multi-location car dealerships

  • Banks with multiple branches

  • Hotel and restaurant chains

  • Marketing and Ad Agencies with offices spread nationally

  • Schools, Hospitals, Libraries and other Municipalities

  • Multi-location retailers

Basically, any business with multiples branches or offices can benefit from SD-WAN. It is especially helpful for organizations that run cloud services or wish to house and mitigate all IT operations within a single hub.

Most businesses today rely heavily on the Internet. Having automatic failover to back-up connections safeguards your business from experiencing any perceived outages. Therefore, if lost productivity from a dropped Internet connection would substantially harm your business, SD-WAN may be for you.

Ultimately, SD-WAN is the best solution for fast-growing California-based businesses looking to establish a cost-effective, scalable, and efficient wide area network.

Interest in learning more about GeoLinks’ SD-WAN offering? Talk to a GeoLinks team member today!

Get to know GeoLinks’ Helpdesk Manager Michael Hurst

Get to know GeoLinks’ Helpdesk Manager, Michael Hurst

1. Let’s start with the basics, what’s your role at GeoLinks?

As Helpdesk Manager, I oversee the Helpdesk, which is responsible for responding to client support tickets, and assisting our FieldOps technicians on installations.

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

The company culture and environment. Everyone here takes great pride in the work that we do. We have created a friendly, family-like environment where we can share ideas with each other with ease. The game room and arcade are a plus as well!

3. What came before GeoLinks; did you always know you wanted to be an engineer? 

Not always! I’ve always had an interest in technology, primarily through playing video games. Prior to this job I was working for a video production company, at first assisting with inventory, later moving to the installation side. It was there where my interest in technology expanded and eventually led me to pursue a career in Networking.

Get to Know Michael Hurst4. What makes GeoLinks’ ClearFiber™ network different from other fixed wireless networks?

We’re always working to expand our already diverse network to cover areas other providers don’t service. In addition, we constantly work to improve our existing network.

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

It’s too hard to pick just one! I think most people in the office know I’m a big sports fan. Go Niners and Giants! Other than that I’m really passionate about playing music, and I’ve been training on Muay Thai kickboxing the last year or so.

Michael Hurst GeoLinks6. What’s something most of your coworkers don’t know about you?

I spent part of my childhood in England, from the ages of 5 to 8, and my entire extended family still live there. I try to make it back as often as I can.

7. What does an average day as GeoLinks Helpdesk Manager look like?

I work closely with our engineering team to ensure our support tickets are handled with care and in a timely manner. I also work closely with our operations managers to ensure our new circuit installations go smoothly.

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

Either hang out on the beach and surf in Maui, or see the sights in New York. I’ve never been.

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

It’s simple, treat others with the same kindness and respect in which you wish to be treated.

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

I look forward to seeing our network continue to diversify and expand, and I look forward to helping our company grow however I can.

Get to know Michael Hurst GeoLinks

Want to join the GeoLinks’ team? Learn more about your current openings on our Careers Page.

GeoLinks Earns Spot on Inc. 5000 List Third Year Running

GeoLinks Earns Its Place on the 2019 Inc. 5000 Fastest Growing Companies in America List for the Third Year in a Row

August 16, 2019 10:00 AM Eastern Daylight Time | Original release published on BusinessWire.com

CAMARILLO, Calif.–(BUSINESS WIRE)–On Wednesday, August 13th, 2019, Inc. Magazine revealed that GeoLinks earned a place on its annual Inc. 5000 list, the most prestigious ranking of the nation’s fastest-growing private companies, for the third year in a row. The list represents a unique look at the most successful companies within the American economy’s most dynamic segment—its independent small businesses. Achieving a three-year growth rate of 256%, GeoLinks represents the one in eight companies that have made this list three times.

“With the incredible team we have in place here at GeoLinks, I have no doubt that we will make next year’s list and beyond,” commented GeoLinks’ Co-Founder and CEO Skyler Ditchfield. “We have the best team there is in telecom, and I am both humbled and proud to lead such a dynamic group of hard-working and innovative individuals. Our mission at GeoLinks is to one day close the digital divide—this makes keeping motivated really easy for each and every one of us. Truly, the best is yet to come!”

Not only have the companies on the 2019 Inc. 5000 (which are listed online at Inc.com, with the top 500 companies featured in the September issue of Inc., available on newsstands August 20) been very competitive within their markets, but the list as a whole shows staggering growth compared with prior lists. The 2019 Inc. 5000 achieved an astounding median growth rate of 157 percent. The Inc. 5000’s aggregate revenue was $237.7 billion in 2018, accounting for 1,216,308 jobs over the past three years.

“The companies on this year’s Inc. 5000 have followed so many different paths to success,” said Inc. editor in chief James Ledbetter. “There’s no single course you can follow or investment you can take that will guarantee this kind of spectacular growth. But what they have in common is persistence and seizing opportunities.”

With the release of this year’s ranking, GeoLinks remains the fastest growing Internet Service Provider (ISP) and Wireless Internet Service Provider (WISP) in the state of California, and the second fastest growing ISP in America.

For media inquiries and interview requests, contact Lexie Smith, VP of Business Development, at [email protected].

About GeoLinks

Headquartered in Southern California, GeoLinks is a leading telecommunications company and competitive local exchange carrier (CLEC) public utility, nationally recognized for its innovative Internet and Digital Voice solutions. Ranked three-years running on Inc. Magazine’s Inc. 5000 Fastest Growing Companies in America, GeoLinks delivers Enterprise-Grade InternetDigital VoiceSD-WAN, Cloud On-ramping, Layer 2 Transport, and both Public and Private Turnkey Network Construction expertly tailored for businesses and Anchor Institutions nationwide.

GeoLinks’ accelerated success is largely due to its flagship product, ClearFiber™, which offers dedicated business-class Internet with unlimited bandwidth, true network redundancy, and guaranteed speeds reaching up to 10 Gbps. Named “Most Disruptive Technology” in the Central Coast Innovation Awards, GeoLinks’ ClearFiber™ network is backed by a carrier-grade Service Level Agreement boasting 99.999% uptime and 24/7 in-house customer support. With an average installation period of 4 to 7 days, GeoLinks is proud to offer the most resilient and scalable fixed wireless network on the market.

More about Inc. and the Inc. 5000

Methodology

The 2019 Inc. 5000 is ranked according to percentage revenue growth when comparing 2015 and 2018. To qualify, companies must have been founded and generating revenue by March 31, 2015. They had to be U.S.-based, privately held, for profit, and independent—not subsidiaries or divisions of other companies—as of December 31, 2018. (Since then, a number of companies on the list have gone public or been acquired.) The minimum revenue required for 2015 is $100,000; the minimum for 2018 is $2 million. As always, Inc. reserves the right to decline applicants for subjective reasons. Companies on the Inc. 500 are featured in Inc.’s September issue. They represent the top tier of the Inc. 5000, which can be found at http://www.inc.com/inc5000.

About Inc. Media

Founded in 1979 and acquired in 2005 by Mansueto Ventures, Inc. is the only major brand dedicated exclusively to owners and managers of growing private companies, with the aim to deliver real solutions for today’s innovative company builders. Inc. took home the National Magazine Award for General Excellence in both 2014 and 2012. The total monthly audience reach for the brand has been growing significantly, from 2,000,000 in 2010 to more than 20,000,000 today. For more information, visit www.inc.com.

The Inc. 5000 is a list of the fastest-growing private companies in the nation. Started in 1982, this prestigious list has become the hallmark of entrepreneurial success. The Inc. 5000 Conference & Awards Ceremony is an annual event that celebrates the remarkable achievements of these companies. The event also offers informative workshops, celebrated keynote speakers, and evening functions.

For more information on Inc. and the Inc. 5000 Conference, visit http://conference.inc.com/.

Get to know GeoLinks’ Director of Network Operations Kevin Malone

Kevin Malone GeoLinks.com

1. Let’s start with the basics, what’s your role at GeoLinks?

My role is Director of Network Operations. I oversee Network Operations (Netops) which consists of the GeoLinks’ Customer Helpdesk, NOC department, as well as Systems/IT.

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

Hard to pick just one. The friendly cultural atmosphere, constantly being challenged, and the fast-paced, never slow environment. Things are never boring.

3. You were one of the first GeoLinks employees to be hired (back when the company was California Internet); how has the company evolved since you first started? 

It has changed quite a bit, from having meetings in a single office room sitting on the floor to where we are now. I remember how big of a deal it was when we first got logo’d shirts and graphics on our only company vehicle.  At that point we were legit!

4. What makes GeoLinks’ different from other Internet Service Providers?

I would have to say the people. From the very start the company was born with a friendly culture of respect. All businesses are about making money but what really matters is how you go about it.  The founders and management of GeoLinks believe above all else that providing the best work environment for the employees fosters success. For this reason I would say it’s why GeoLinks is different than any other company, not just other fixed wireless providers.

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

kevin malone geolinks.com

I have many. From shooting pistols and rifles at the range, to enjoying my Remote Control vehicles (Cars/Trucks/Rock Crawlers, GAS and Electric), to working on my ‘68 Chevy pickup.

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

From age 7 to age 14 I studied Taekwondo. I was a wild child, and it was my parents idea of instilling structure, or at least a way to get rid of my energy. I made it as far as 2nd degree Black belt. My mother at one point had an entire room of trophies from sparring tournaments I competed in throughout California.

7. GeoLinks’ sales team often states that the company “reverse engineers” every circuit. Coming from the technical side of things, can you expand upon what this means exactly?

I think what we mean is we try to look at the details. Many ISP’s simply have a blanket area they say can be served. They’ll tell a customer “yes we can serve you” without doing due diligence. This often causes delays down the road. It’s a matter of considering all the factors before saying yes. When we say yes we can do something, we have put the circuit design through the paces and made sure it’s both possible and that we can support it. It makes us as a company true to our word. When we say “Yes, we can serve you”, we mean it.

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

Funny you ask, I plan on doing this next year! Wherever I go, I would want my friends and family with me as that is the most important thing in life. I would want to go to a place I find beautiful and genuinely enjoy every second I’m there. While we’re there, why not have a big party! That being said, my fiancé and I visited Ireland this year for vacation. Being almost 50% Irish, seeing my roots has always been on my bucket list. We planned the trip ourselves, flew in, and rented a car. We then traveled the island visiting all of its wonders at our own pace. We loved it so much we decided we’re going to get married there next year. We’ve invited all our friends and family and plan to have an awesome day none of us will ever forget.

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

I like to watch the MotorTrend channel on Youtube. It’s a series of car shows, and at the end of each show they display a quote saying “Get Busy Living”.  I interpret this as don’t get stuck in the routines of life, and do what makes you happy!

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

Growing companies, especially fast-growing technical ones, always have unique and difficult challenges. If I’m not being challenged, I don’t feel like I’m growing. From my experience, that will never be an issue working here. From the beginning to now it’s insane how the company has developed; I can’t wait to see where it goes from here.

kevin malone geolinks