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

Before the

Federal Communications Commission

Washington, DC  20554

 

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

 

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

 

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

 

  1. INTRODUCTION AND SUMMARY

GeoLinks is proud to service the largest coverage area of any single fixed wireless Internet service provider (“ISP”) in the state the California.  The Company’s fixed wireless technology platform depends on access to spectrum resources sufficient to support enterprise-level broadband connections.  Millions of Americans lack what is, by today’s standards, considered high-speed broadband access – especially in rural areas. Sparsely populated rural areas are not well suited for traditional, wired broadband service given the cost to build and deliver a cable/ fiber-based network.  However, fixed wireless broadband technology can provide high-speed broadband to consumers in these areas for a fraction of the cost.  For this reason, it is imperative that spectrum resources be allocated in ways that allow fixed wireless ISPs to deploy services to these regions.

Over the last two years, GeoLinks has made it a Company priority to reach more unserved and underserved areas within California and beyond.  GeoLinks believes that the 3.7 – 4.2 GHz band offers an opportunity for the Commission to allocate spectrum resources in a way that will promote competition and help bridge the digital divide while protecting current users of the band.  Specifically, the​ ​3.7–4.2​ ​GHz​ ​band​ ​is​ especially ​well-suited​ ​to​ ​support​ Point-to-Multipoint (“P2MP”)​ ​broadband​ ​access. As such, GeoLinks urges the Commission to affirmatively state the feasibility of commercial wireless applications and its intention to assess how the band can be properly allocated to maximize public benefit in its 3.7-4.2 Report.

 

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

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

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

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

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

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

 

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

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

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

 

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

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

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

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

 

  • CONCLUSION

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

 

 

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

May 31, 2018

[1] Office of Engineering and Technology, International, and Wireless Telecommunications Bureaus Seek Comment for Report on the Feasibility of Allowing Commercial Wireless Services, Licensed or Unlicensed, to Use or Share Use of the Frequencies Between 3.7-4.2 GHz, Public Notice, GN Docket 18-122, DA 18-446 (re. May 1, 2018).
[2] Broadband Access Coalition, Petition for Rulemaking to Amend and Modernize Parts 25 and 101 of the Commission’s Rules to Authorize and Facilitate the Deployment of Licensed Point-to-Multipoint Fixed Wireless Broadband Service in the 3700-4200 MHz Band, RM-11791 (filed June 21, 2017) (“Petition”) at 4.
[3] “The 3700 – 4200 MHz band satisfies two fundamental requirements for spectrum to provide high-speed fixed wireless broadband access to residential and small business customers and to community anchor institutions. First, the 3700 – 4200 MHz band has excellent propagation characteristics compared to high-band spectrum, offering near-line-of-sight (“nLOS”) capability at low power for last-mile services. Second, the band has 500 megahertz of contiguous spectrum, an amount sufficient to accommodate twenty-five 20 megahertz channels that can be bonded to create larger 40, 80, and 160 megahertz channels. These wide channels facilitate the provision by multiple entities of last-mile fixed wireless broadband connectivity at gigabit or near-gigabit speeds.”  Petition at 4.
[4] GeoLinks believes that a minimum of 120 MHz of clean spectrum (with no interference) is required to provide gigabit or near-gigabit broadband speeds.
[5] Petition at 5.
[6] This position is also shared by other parties.  See e.g. Comments of the Competitive Carriers Association, RM-11791 (filed August 7, 2017) at 2 and Comments of Starry, Inc., RM-11791 (filed August 7, 2017) at 1.
[7] “Part 101 frequency coordination will ensure that the incumbent Fixed-Satellite Service (“FSS”) and terrestrial point-to-point (“P2P”) Fixed Service (“FS”) will not suffer harmful interference from band-sharing with P2MP.” Petition at 1.
[8] Petition at 6.
[9] Specifically, GeoLinks recommends build out to a minimum number of locations.  In the alternative, GeoLinks recommends that the Commission require any new band user to make a showing that they are actually serving customers over the band within a reasonable timeframe.
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Promoting Investment in the 3550-3700 MHz Band

Before the

Federal Communications Commission

Washington, DC  20554

 

In the Matter of

Promoting Investment in the 3550-3700 MHz Band

GN Docket No. 17-258

 

COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

 

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

I. INTRODUCTION AND SUMMARY

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

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

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

II. DISCUSSION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

i. Small Service Provider Bidding Credit

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

ii. Rural Broadband Bidding Credit

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

iii. Connect America Fund Phase II Awardee Bidding Credit

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

iv. Wholesale Bidding Credit

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

v. PAL Awardee Payment Options

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

III. CONCLUSION

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

 

Respectfully submitted,

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

January 29, 2018

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

California ISP Connects Isolated Areas with Fixed Wireless Broadband

Original Article

Mimosa Networks, the provider of 5G Fixed wireless solutions, has announced that it is teaming with GeoLinks, a California-based communications service provider, on a number of statewide projects to revolutionize internet access at underserved government, educational, and healthcare organizations, the company said.

GeoLinks, named one of America´s fastest growing companies by Inc. Magazine, is connecting these previously unreached organizations by providing ultra-reliable, fiber-fast broadband throughout the state of California and beyond, using pioneering wireless broadband technology from Mimosa.

On Catalina Island, for example, GeoLinks successfully deployed Mimosa´s fiber-fast broadband solutions to bring high-speed internet access to the island community for the first time in its history.

Taking into account the unique location — 41 miles offshore — and leveraging the existing infrastructure, a team of engineers considered a number of advanced options to tackle the challenge of connecting the island to the mainland. GeoLinks ultimately selected Mimosa for the last mile of the installation, deploying Mimosa A5 access and C5 client devices throughout the harbor town of Avalon.

Speeds on the island are typically 300 Mbps, and the ultra-fast broadband connection provides support for essential communications services, tourism services, and commerce.

Back on the mainland, GeoLinks is actively addressing one of the state´s most critical infrastructure needs — connecting rural schools to the internet. In order to help these schools provide the highest and most advanced educational services to their students, GeoLinks again turned to Mimosa solutions to reach these hard-to-reach customers. Thanks to Mimosa´s ease of use, reliable performance and Gigabit-plus connectivity, Geolinks will be continuing its rapid deployment to rural school customers.

Mimosa Networks is the provider of next-generation, Hybrid Fiber-Wireless fixed access broadband solutions. Founded in 2012, Mimosa is based in Silicon Valley and deployed in over 130 countries worldwide.

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Local internet service provider relocates to Camarillo, creates job openings

Local internet service provider relocates to Camarillo, creates job openings

Original Article

A local internet service provider is expanding throughout the region and aims to become one of Ventura County’s leading technology businesses.

GeoLinks, which was created by Ventura resident Skyler Ditchfield in 2011, began as a two-person team interested in providing internet service to rural residents overlooked by the nation’s larger internet service providers. Since then, GeoLinks has hired over 50 employees and shifted its focus to providing internet packages to large businesses, including Amgen Inc. and several regional McDonald’s restaurants.

Although the privately-owned company’s internet services are largely restricted to businesses, GeoLinks’ continued growth has resulted in a steady stream of job openings for people with technology and customer service skills, according to Ditchfield.

“We started with two people, have over 50 now and are still hiring nonstop,” Ditchfield said in an interview. “We’ve got everything from sales opportunities to customer service, to field tech opportunities, installation and infrastructure technicians, help desk and eventually those jobs can open up to middle and upper-level positions in the company.”

The Camarillo-based business relocated from Ventura to 251 Camarillo Ranch Road last week to house its rapidly growing staff. The building, which was previously owned by mobile video game developer Zindagi Games Inc., includes amenities such as an exercise facility, basketball court, game room and kitchen. GeoLinks’ expanded office matches its growing coverage. The business services companies from northern Ventura County to San Diego and is beginning to spread to other states, such as Arizona.

Beyond job opportunities, Ditchfield considers GeoLinks’ expansion to be an important example of how local businesses can provide compelling alternatives to national companies. Ditchfield stressed that customer service played a major role in his company’s success, and said that GeoLinks’ local focus allowed the business to thrive despite competition from larger internet service providers such as AT&T and Verizon.

“People are fed up with the poor customer service and tech support from the big guys,” Ditchfield said in an interview. “The whole methodology is to get off the phone and move you away, while we’re actually trying to solve the problem. Customer service is why we win (business) accounts, so it’s incredibly important to us that we maintain that level of service.”

Going forward, GeoLinks aims to begin providing internet options to California residents, as opposed to just businesses, in early 2018, with a particular focus on rural communities. For more information about the business, visit GeoLinks’ website.

Skyler Ditchfield GeoLinks

GeoLinks CEO Skyler Ditchfield is shown at the basketball court in the new building the company recently moved into in Camarillo. The local internet company is expanding and hopes to provide internet services to individuals as well as businesses. CHUCK KIRMAN/THE STAR

GeoLinks CEO Skyler Ditchfield talks about the expansion of the internet service business. The company was launched in 2011 as a two-person enterprise and now has over 50 people working at its Camarillo facility. It is continuing to expand and hire. CHUCK KIRMAN/THE STAR

The sales and marketing department of GeoLinks in Camarillo is a busy place. The local internet service provider is expanding and hiring more staff. After starting a a provider of internet services to rural areas not served by the bigger companies it it now focused on serving business like Amgen Inc. CHUCK KIRMAN/THE STAR

The GeoLinks recreation room has pool tables at the new building the internet service provider recently relocated to in Camarillo. The internet company is expanding after moving from Ventura. CHUCK KIRMAN/THE STAR

GeoLinks CEO Skyler Ditchfield is shown near the main conference room of the company’s new building in Camarillo. The internet company is expanding and hiring as it focuses on providing internet services to area businesses. CHUCK KIRMAN/THE STAR

GeoLinks CEO Skyler Ditchfield talks about the company’s expansion and the new headquarters it recently moved into in Camarillo. After starting in 2011 with two people, the internet service provider now has more than 50 employees and anticipates more hiring. CHUCK KIRMAN/THE STAR

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California Internet Expands Nationally Rebranding as GeoLinks

California Internet Expands Nationally Rebranding as GeoLinks

Southern California’s fastest growing B2B ISP California Internet expands nationally relocating company headquarters and changing company name to GeoLinks.

VENTURA, CA (PRWEB) JUNE 13, 2017

California’s fastest growing B2B ISP, California Internet LP, is excited to officially announce its new brand name, GeoLinks. The company’s rebranding coincides with a variety of notable company milestones including its official launch into the national market, induction as a Competitive Local Exchange Carrier (CLEC) public utility and headquarter relocation.

“We’ve reached a pivotal moment in GeoLinks’ history,” shared GeoLinks Chief Revenue Officer Phillip Deneef. “We chose to migrate away from the name California Internet due to overwhelming demand pulling our company outside of state borders. Wanting a name that isn’t geographically correlated, we ultimately decided on GeoLinks—Geo meaning Earth in Latin and Links because we are linking the world with the most advanced connectivity available today.”

With the company’s accelerated growth, GeoLinks officially welcomed its 50th employee in June and expects to employ upwards of 100 within the next 18 months. In effect, GeoLinks is thrilled to simultaneously announce its national headquarters are moving to Camarillo, California. The recently acquired 38,000 sq ft office building, previously home to Zynga Games, features a fully equipped employee gym, basketball court, spacious kitchen, break room, and much more.

“Our new office is a direct representation of our cutting-edge company culture,” said GeoLinks CEO Skyler Ditchfield. “In addition to the incredible amenities, I plan on bringing a wellness coach and private chef on board to promote health and wellness throughout the entire staff. I am very aware of the fact that we spend more than one-third of our lives at work these days so it’s important to me to give back to my team by creating a fun work environment that makes them eager to come to work every day. GeoLinks is bringing ‘Silicon-Valley Style’ to Ventura County.”

What’s next for the booming ISP? With Ditchfield and GeoLinks’ instrumental lobbying efforts in the recent passing of AB-1665 Telecommunications: California Advanced Services Fund, otherwise known as the Internet For All Act (IFAN), and GeoLinks’ California Public Utilities Commission Certificate of Public Convenience & Necessity, GeoLinks will continue to expand coverage and service offerings while developing strategic partnerships with national carriers and federal level agencies such as HUD, the Department of Interior and the Department of Education.

“The certificate from the California PUC is an important step for GeoLinks as it allows it to not only provide fast Internet service to customers but also Voice over Internet Protocol services,” said its regulatory counsel, former CPUC and FCC Commissioner Rachelle Chong. “This certificate makes GeoLinks eligible to provide E-rate Internet and voice services to eligible schools, libraries and health care providers under the FCC program, and to provide California Teleconnect Fund services under the CPUC public purpose program. Given a goal of the company is to help bridge the digital divide for rural schools and libraries, this is an important milestone.”

GeoLinks assures customers and partners that its underlying corporate identity will remain unchanged for all legal and regulatory purposes issuing no major alterations to their contracts, support or contact information.

For media inquiries, interview requests or to schedule an office tour, please contact Lexie Olson at lolson(at)geolinks(dot)com.

About GeoLinks:

Founded in 2011 by CEO, Skyler Ditchfield, and CTO, Ryan Hauf, GeoLinks is the fastest growing B2B fixed wireless ISP in Los Angeles, California. With immediate access to Southern California, GeoLinks services the largest coverage area of any single provider in California delivering enterprise-grade internet, layer 2 transport, and turnkey construction that is expertly tailored for all businesses and Anchor Institutions such as hospitals, libraries and schools.

With industry leading installation times, GeoLinks’ flagship service, ClearFiber™, offers customers fixed wireless on the most resilient and scalable network ever built. Boasting Sub 25MS latency, 99.99% uptime, sub 4ms jitter, and a 4-hour max repair time, GeoLinks is proud to offer the state’s best industry service level agreement.

Amongst its many accolades, GeoLinks was the largest construction grant winner for California K-12 schools and libraries in both 2016 and 2017. Servicing thousands of businesses across the state, GeoLinks officially became a CLEC and public utility in 2017.

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