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Round Up – Industry Experts share their 2019 Telecom Predictions

From the emergence of fixed wireless and hybrid networks, to the predictive realities of 5G, telecom experts share their 2019 industry forecasts.

Please note that the views and opinions expressed in this article do not represent nor do they imply endorsement of my personal views or my employer’s views and opinions. They are unique and independent to the individual contributors listed as the statement’s source.


From the roll out of new Artificial Intelligence (AI) integrations, to the highly anticipated future of 5G, in 2018 we saw the telecommunications industry generate some pretty innovative trends and thought-provoking headlines. With the new year just around the corner, I thought I’d turn to a variety of diverse industry experts to learn about their 2019 telecom predictions. Here is what they had to say:

There will be a lot of providers deploying 5G, but monetization will prove a challenge

Nathan Rader, Director of NFV Strategy, Canonical

There will be a race to see who can market 5G the quickest and who will have it as standard first. We’re already seeing tests from multiple providers across the world in isolated areas, and the speed and size of rollouts will only increase as providers look to gain the upper hand.

However, this race could be a costly one. Consumer need for 5G isn’t as great as it was for previous generations. 4G can handle most consumer use cases (such as streaming, gaming, browsing etc.) fairly comfortably with reasonable speed.

5G’s main benefit is providing increased capacity, not speed and latency, making it more of a technical development. Being the first 5G standard network will be a marketing coup, but may not come with the consumer kudos and demand it once did.

Further widespread adoption of Fixed Wireless

Phillip Deneef, Chief Strategy Officer, GeoLinks

We’ve seen fixed wireless technology evolve and improve drastically over the last decade, concurrently beginning to debunk “wireless anxiety”. During the Federal Communications Commission’s (FCC) CAF II Auction in 2018, we saw federal acceptance and adoption through the distribution of significant funding to WISPs, such as GeoLinks. This culminates to my prediction that in 2019 I believe we will see a drastic spike in both businesses and community anchors being connected via fixed wireless. While I do think fiber will still remain top of mind for many key stakeholders, I foresee anchors, rural health care facilities as a specific example, better understanding that EoFW is the most cost effective and time efficient way to get these critical care facilities the speeds they need. Taking guidance from both the FCC and overall industry adoption, on a state level I predict that those governing RFP fund distributions will also be more open to fixed wireless solutions. This will directly result in the United States making substantial strides in closing the digital divide.

Competition in Hosted VoIP market will heat up

Marc Enzor, VoIP Consultant & President, Geeks 2 You

Hosted VoIP phone systems are the hottest thing right now in telecom. Even the SMB and Medium size businesses are starting to become aware of what it is, and to gravitate towards it. In years past, we would spend most of our sales pitch educating customers as to what it is, how it works, and why they should use it. In recent months, customers already are aware and ready to purchase immediately. The sales cycle went from multiple meetings to single meetings now. It has become one of the hottest products we sell.

Going into 2019, it’ll only become even more “standard knowledge”, which means the competition in the hosted VoIP market will heat up. I predict several of the biggest names will start to buy the competition out and a true industry leader will emerge. This will have to happen as the top companies now will start to rely on their current growth models and will need to find ways to replace the lost growth as competition gets bigger.

Only edge computing / edge networking and AI will show true growth

Alan J Weissberger, ScD EE, IEEE Communications Society, techblog.comsoc.org

Only two areas in the telecom/networking space deserve the attention they are getting: 1] edge computing/edge networking and 2] Artificial Intelligence (AI).
Edge computing/edge networking is needed to off load the processing that takes place in cloud resident data center computers and also to reduce latency for critical real time control applications (especially for IoT).

AI and deep learning will be embedded into software-defined architectures in telco networks and the cloud to do analytics, predict failures, and move a lot of the human manual processes into automated operations. The long-term goal is to move from automated elements to closed loop automation and finally to autonomous control of networks.  I believe AI will be critically important to progress emerging telecom services and enabling new ones.  Examples include: 5G, Industrial IoT, autonomous vehicles, Augmented Reality/Virtual Reality, etc.  It will be also very useful for more mundane things, like keeping up with WAN and Internet bandwidth demands due to increased video streaming by cord cutters and pay TV customers (like this author) that increasingly stream sporting events (e.g. MLB TV, NBA League Pass, NHL Center Ice, boxing, etc).

All the other new technologies are hyped to the infinity power and headed for a train wreck.  That’s especially true of 5G, but also includes “Software Defined” networks (SDN and SD-WAN), Network Function Virtualization (NFV), and LPWANs for the Internet of Things (IoT).  All those suffer from the lack of inter-operability which is due to either the lack of standards, too many specs/standards (LPWANs) or proprietary implementations (e.g. SDN from AT&T, Google, Amazon, Microsoft, etc are not interoperable with each other. They each use different specs, with many being proprietary while others are based on open source software).  None of them will make much money for any company in the coming year.  Perhaps a few SD-WAN start-ups will be acquired and investors in those companies will profit, but that’s about it.

Enterprises cut the cord with LTE

Hansang Bae, CTO, Riverbed

For enterprises, 2019 isn’t a forecast of all doom and gloom. The year will also bring freedom from the persistent “last-mile” telecommunications problem. With the advancements in LTE, the technology will finally reach a point where the physical cables that connect end-users to their Internet Service Providers will no longer be a necessity — or a handcuff to a particular ISP.

The “last-mile” problem has long been the most critical and most costly component of an ISP’s network, as well a speed bottleneck. But now, on the heels of widespread adoption, LTE will allow enterprises to forego the last mile of physical cable for a reliable and robust connection.

Purpose-built Security Software will emerge

Don Boxley, Co-Founder and CEO, DH2i

Making smart products, IoT devices, is the new product differentiator — today, even ovens have IP addresses. Companies that have been investing in IoT initiatives understand that the IoT gateway layer is the key that unlocks a high return on those IoT investments. IoT gateways manage device connectivity, protocol translation, updating, management, predictive and streaming data analytics, and data flow between devices and the cloud. Improving the security of that high data flow with a Zero Trust security model will drive enterprises to replace VPNs with micro-perimeters. Micro-perimeters remove an IoT device’s network presence eliminating any potential attack surfaces created by using a VPN.

Likewise, many organizations are pursuing a hybrid strategy involving integrated on-premises systems and off-premises cloud/hosted resources. But traditional VPN software solutions are obsolete for the new IT reality of hybrid and multi-cloud. They weren’t designed for them. They’re complex to configure, and they give users a “slice of the network,” creating a lateral network attack surface. A new class of purpose-built security software will emerge to eliminate these issues and disrupt the cloud VPN market. This new security software will enable organizations to build lightweight dynamic micro-perimeters to secure application- and workload-centric connections between on-premises and cloud/hosted environments, with virtually no attack surface.

Hybrid Networks become more common

Louis Fox, CEO & President, CENIC

In terms of widespread internet connectivity, the low-hanging fruit has long been picked. To achieve a complete mesh across the state, and thereby to include all of our communities and lift all boats, private-sector technology companies will need to work more collaboratively with government and nonprofit community organizations to approach an underserved geographic region with a comprehensive strategy that stitches together fiber, fixed wireless, unlicensed spectrum, TV whitespace, and more. We can no longer deploy in a series of one-offs if we are ever to serve some of the hardest to reach places.

More Internet Networks deploying IPv6

John Curran, President and CEO, ARIN

The Internet has grown remarkably over the past few years and as a result we now have over four billion people online. The Internet will continue to grow at a remarkable pace to meet the requirements of broadband, mobile, and Internet-of-Things (IoT) growth, and this will only increase pressure on Internet Service Providers (ISPs) to deploy the next version of the Internet Protocol (IP version 6, or IPv6) — just as many broadband and mobile providers have already done today. The good news is that the IPv6 transition happens in the “lower layers” of the Internet, so this behind-the-scenes upgrade to the Internet will continue to happen without any noticeable change for Internet users.

Public and Private Clouds will be much more accommodating of each other

Jai Menon, Chief Scientist and IBM Fellow, Cloudistics

[In 2019] only about 5 viable general-purpose public cloud vendors will survive. This is because successful public cloud vendors will need to spend a lot of money, and few can afford to spend as much as the Top 2 — AWS and Microsoft Azure. [Furthermore] Public and private clouds will be much more accommodating of each other. More and more of the services provided by a public cloud vendor, such as their AI services, will become accessible to apps running elsewhere, including on private clouds. At the same time, there will be more and more examples of private cloud capabilities extended to the public cloud — such as VMware Cloud on AWS. Finally, federated orchestration and management of workloads across private and public clouds, all from a single, easy to use, portal will be commonplace.

Political turbulence and possible decrease in network investment

John Windhausen, Executive Director, Schools, Health & Libraries Broadband (SHLB) Coalition

2019 could be a turbulent year in the telecom/broadband space. If the FCC approves the proposed Sprint/T-Mobile merger, and if the court allows the AT&T-Time Warner merger, that could encourage even more consolidation in the marketplace. Of course, more consolidation among big players also opens up more opportunities for smaller, more nimble players to increase their market share. But there are increasing signals of an economic slow-down in 2019, which could mean belt-tightening and reduced investment by all players. The tariffs on Chinese-made equipment could mean increased prices for telecom gear, which could also lead to a pause in network investment. These trends may give a boost to the idea of a grand broadband infrastructure spending bill that both the President and Hill Democrats are trying to get in front of (assuming the government shutdown does not ruin the chances of bipartisan agreement forever.) Such legislation would only have a 30% chance of enactment but could be exciting to watch, as there are so many industry players that could benefit from government funding, especially in rural markets. I expect net neutrality to continue to percolate because the court is likely to remand the case to give the FCC another chance to justify its decision. Congress could and should step in, but there is no sign of compromise on the issue and likely will remain gridlocked. For anchor institutions, work will continue to get the E-rate and Rural Health Care programs running smoothly, but I do not anticipate major structural changes.

Do you agree or disagree with any of the above predictions? If so, feel free to visit the original article here, and leave a comment.

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

Smart City Technology- Lexie Smith - GeoLinks

Read the original article on Medium.com

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

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

Why Not?

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

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

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

Why being hyper fiber-minded is our fatal flaw:

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

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

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

Who are people in positions of influence?

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

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

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

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

Smart City - Lexie Smith - GeoLinks

Related Suggested Articles:

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

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

Digital Divide Is Wider Than We Think, Study Says

How Community Anchor Institutions Can Help Close the Digital Divide

Rural service is key to bridging the digital divide

Promoting Investment in the 3550-3700 MHz Band

Before the

Federal Communications Commission

Washington, DC  20554

In the Matter of

Promoting Investment in the 3550-3700 MHz Band

GN Docket No. 17-258



California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these reply comments in response to comments filed on the Notice of Proposed Rulemaking and Order Terminating Petitions (“Notice and Order”) issued October 24, 2017.


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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

i. Small Service Provider Bidding Credit

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

ii. Rural Broadband Bidding Credit

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

iii. Connect America Fund Phase II Awardee Bidding Credit

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

iv. Wholesale Bidding Credit

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

v. PAL Awardee Payment Options

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


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


Respectfully submitted,



/s/ Skyler Ditchfield, Chief Executive Officer

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


January 29, 2018

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