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ClearFiber™ – Enterprise-Grade Internet Delivered in 7-10 Days

What to Expect in a ClearFiber™ Fixed Wireless Installation

Not sure what to expect from a fixed wireless installation?

Let’s start with an overview of fixed wireless technology. Simply put, fixed wireless provides high-speed direct Internet access using radio waves to create a point-to-point link from a wireless network tower antenna to a dish with a radio on a building roof. Because there are no underground connections involved, fixed wireless technology is deployable in a fraction of the time and cost of a standard terrestrial fiber connection.

It takes 30-60 days to install fiber and that’s only if your business location is already lit (i.e. connected to fiber). If you need to fiber to be deployed to your building, construction can delay your installation to 90-120 days and sometimes longer.

When you sign up for our award-winning ClearFiberTM fixed wireless Internet, you can get high-speed Internet service with speeds up to 10 Gigabits per second (Gbps) in as few as 24 hours, but typically five to 10 days.

How can we install ClearFiber fixed wireless so quickly? We’ve broken down our installation process into five easy steps, so you know what to expect before you sign on the dotted line.

 

Step 1: Qualify Service Availability

Your service request is sent through a serviceability qualification process wherein GeoLinks’ staff verify that ClearFiber fixed wireless service is available in your area.

 

Step 2: Order & Contract

Once serviceability has been confirmed, an official order request is sent to GeoLinks’ Quotes Team to prepare contracts for e-signature.

Once contracts are signed and returned to GeoLinks, an in-house project coordinator is assigned to your account and will follow-up with the following documents:

  • Roof Access Form
  • On-site Contact
  • Site Readiness Questions

 

Step 3: Pre-Installation

Once all documents are completed and submitted, your order is moved to our engineering department, where the circuit is designed to fit your business needs, based on the specs laid out in your contract.

Then, your order goes to the fulfillment department, which makes sure that we have the equipment (e.g. radios and dishes) required for the installation. The fulfillment department also pre-configures or programs the radios for your installation.

Next, our dispatch department will reach out to your on-site contact with the soonest available date time of arrival for installation.

We’ll work to meet your scheduling needs, but installation date from order confirmation is typically between five to 10 business days. We usually schedule multiple installations in the same campus on the same day. Separate locations typically are scheduled and rolled out one at a time.

 

Step 4: Installation

On the day of the installation, GeoLinks’ project coordinator will call 30 minutes in advance of our team arriving. When our in-house technicians arrive, they will meet with your point of contact and confirm that we have access to the server room and roof and secure approvals to proceed.

GeoLinks’ technicians then transport the weatherproof fixed wireless radio dish – usually two- or three-feet in diameter –to the top of your building and secure it to the roof.  To do this, we use a non-penetrating, flat mount with rubber matting between the mount and the roof to protect the roof. The mount is weighed down by bricks to keep it stable. Weatherproof CAT-5 cabling is strung from the radio dish to the handoff inside the building. We’re typically able to drop cables through the ventilation system, so that we don’t need to drill.

We take care to position the mast and dish low so that it is not noticed by passersby on the sidewalk at ground level.

The installation typically takes two to four hours. Once installed, our technicians take pictures of the radio and share them with you, so that you’re aware of the radio location without having to climb to the roof. We then conduct a speed test with you live in-person to verify the installation was successful.

Before GeoLinks’ technicians leave, we obtain a signature indicating your approval that the deployment is in working order.

 

Step 5: Post-Installation Follow Up

Following the installation, our project coordinator will send you IP information with confirmation of the successful installation. Our customer service representative will contact you to verify there are no issues and our billing department will then invoice for the installation and first month of service.

 

Contacting Support

From here on out, if you ever have a need to contact customer support, simply submit a trouble ticket at the form available at our Support page and we’ll get back to you in four hours or less.

If you have an immediate need, and support can’t wait, call us at 1.888.225.1571 to speak with a GeoLinks’ representative.

 

Ready to Get Connected Fast?

Contact a GeoLinks ClearFiber solutions specialist

 

Get to Know GeoLinks Business Sales Consultant, Jacques Lee

1. Let’s start with something simple, what’s your role at GeoLinks?

I am a business sales consultant. I generate and close new business. I also educate clients on the solutions we provide.

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

My favorite part is the camaraderie and the inviting, welcoming vibe we have here. The environment makes me want to come to work every day. Everybody has fun, it feels like home. Feels like I’ve known these people forever.

3. What was the most interesting job you had before working at GeoLinks? 

I worked for MTV in their production department as a production assistant and eventually a production coordinator. I’d scout locations, contact talent, set up for production. It was a pretty fun, exciting, sometimes wild job.

4. What makes GeoLinks’ ClearFiber™ network different from other fixed wireless networks?

Simply put, we’re the best. It’s our customer service. We’re always available to help you. It’s also a dynamic network. We’re constantly evolving and engineering innovative solutions for businesses.

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

Hanging out with my kids. I help my youngest son with his sports. I’m a pretty family oriented person so I keep it close to home.

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

I would say most of them don’t know that I’m an avid snowboarder.

7. What does an average day as a GeoLinks Sales Consultant look like?

We’re always prospecting for new business. I’m following up with potential clients, learning about their business so that I can figure out how I can customize the best solutions for them. At the same time, I’m calling on new opportunities and building new relationships, building our client network.

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?

I would go to the Giza pyramids with my sons. I just want to feel the energy of that region.

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

Mine is a Bible Verse. Matthew 6: 14-15

For if you forgive men their trespasses, your heavenly Father will also forgive you. But if you don’t forgive men their trespasses, neither will your Father forgive your trespasses.

That changed my life.

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

Scalability. The company is growing in the right direction. There are a ton of great opportunities that come with that. As we grow, I want to continue to grow along with the company and continue to be a valuable asset for our customers and for GeoLinks.

GeoLinks Welcomes Technology Veteran Randy Chapman as New Sales Director for Direct, Channel and Wholesale Sales

Networking Expert to Lead Consultative Sales of GeoLinks’ Dedicated Internet, SD-WAN, Hosted Voice, IoT and Cloud Connectivity Services

June 15, 2020 1:30 PM Eastern Daylight Time

CAMARILLO, Calif.–As GeoLinks continues its strong growth trend, the company is pleased to welcome telecommunications industry veteran Randy Chapman as its Director of Sales. With nearly 15 years of experience in the technology sales sector, Chapman will oversee day-to-day and long-term sales strategy for all of the company’s business sales channels, including direct, channel and wholesale.

“In the midst of our rapid growth, this was really the prefect time to bring Randy onto our team,” said GeoLinks Chief Strategy Officer Phillip Deneef. “The experience and knowledge he brings to the table will allow us to execute on our short-term goals to accelerate sales to businesses, while continuing to plan for what we expect to be an extended period of expansion.”

Chapman brings an extensive background in channel sales. His successful tenure as an agent saw him engineer voice, network security, cloud enablement and infrastructure solutions for a broad client base. He also has nearly ten years of experience as a Director of Sales for technology companies in Southern California.

“I’m ecstatic to be joining such a mission-driven team that is on an impressive trajectory of development and progress,” said Chapman. “My experience has taught me to continue pushing during periods of growth while preparing me to consistently evaluate strategy to optimize results.”

Chapman will manage the organization’s sales team, as well as the continued development of partner relationships in the wholesale and master agent channels. To reach him directly, please email [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.

Not All Connections Are Created Equal

With the sudden surge in remote work and distance learning, internet connectivity has been put to the test. As we predicted, shared circuits in residential areas have been stretched beyond their limits with web surfing and video streaming competing for bandwidth with videoconferencing and large data uploads.

These slowdowns are not unexpected. Most residential internet circuits were not designed to accommodate the increased levels of activity they’re experiencing, which rivals that of enterprise-grade broadband circuits typically used by businesses.

Additionally, the vast majority of residential internet customers share a connection with their neighbors so bandwidth must be divvied up amongst all the households that are connected to it. While these connections fit the needs of residential customers under most normal circumstances, conditions are far removed from normal at the moment.

Subscribers to GeoLinks’ ClearFiber network have not experienced any slowdown, whatsoever. Our Fixed Wireless service provides every customer with a dedicated connection, eliminating the need to share and guaranteeing high speeds that are unaffected by the activity of any neighboring circuits.

Clearly, not all internet connections are created equal. GeoLinks’ Fixed Wireless guarantees speeds and provides residential and business customers with additional advantages, such as fast installation (5-7 days) and 99.999 percent uptime.

To learn more about how you can benefit from Fixed Wireless internet, contact us at (888) 225-1571 or  visit our Youtube channel to watch a three-minute video primer.

Keeping You Connected: Beacons of Growth and Recovery

As we continue to navigate our way through the Coronavirus pandemic, we would like to take a moment to connect with you, our customers and partners. While the situation continues to evolve, as does our way of life along with it, one thing remains unchanged — our commitment to keeping you connected.

In March, GeoLinks joined the Federal Communications Commission’s pledge to Keep Americans Connected and we are steadfast in our commitment to do so. This formal pledge is our vow to ensure that our customers remain connected to vital information infrastructure during these uncertain times.

Over the last several weeks, we have worked closely with our partners and clients to honor this commitment. When possible, we have granted temporary speed bumps to residential clients who are working remotely due to the “safer at home” guidelines. We have differed billing for clients experiencing difficulties paying their bill due to the loss of business and steady income. We have been diligent in ensuring that no clients’ service is suspended due to an inability to pay their bill because of economic difficulties caused by the pandemic.

“As a telecommunications company, we have been in the fortunate position of continuing our growth trend during a time when many industries have been hit extremely hard by the economic toll of the pandemic,” said GeoLinks CEO Skyler Ditchfield. “Our customers are the heart of our company and are driving our success. In kind, we are committed to fueling their continued success and their return to economic vitality in a very real way by keeping them connected to the networks that keep their businesses running.”

While many businesses have been forced to make difficult decisions such as closing for indeterminate timeframes, we have continued to see a high demand for connectivity over the last several weeks. “Our country has weathered many challenges over its history, and what has inevitably led us through each one has been the resilience and ingenuity of our entrepreneurial and business communities,” said Ditchfield. “We have seen signs of recovery over these last few weeks as our network has continued to grow, connecting new customers on a daily basis.”

As we move forward, please remember that we’re here to help. Whether you need help with a disruption to your business caused by the pandemic or you’re looking to connect a new business, we’re your partners in connectivity and nothing is going to change that.

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