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GeoLinks Comments on Auction of Priority Access Licenses

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

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these Reply Comments in response to certain Comments filed on the Public Notice seeking public input on procedures to be used for the auction of Priority Access Licenses (“PALs”) in the 3550-3650 MHz band.[1]

INTRODUCTION AND SUMMARY

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

 

DISCUSSION

The Commission Should Refrain from Adopting CMA-Level Bidding

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

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

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

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

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

The Commission Should Not Establish Bidding Credit Caps

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

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

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

CONCLUSION

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

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 12, 2019

 

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

FCC Comments – Microwave Flexible Use Service Licenses

Before the

Federal Communications Commission

Washington, DC  20554

 

In the Matter of

Preparation For Incentive Auction of Upper

Microwave Flexible Use Service Licenses In                            AU Docket No. 19-59

The 37 GHz, 39 GHz, and 47 GHz Bands

(Auction 103)

 

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) hereby submits these Comments in response to the Commission’s Public Notice released in the above-captioned proceedings.[1]

I. INTRODUCTION AND SUMMARY

GeoLinks is one of the fastest growing Internet and phone providers in America and the fastest growing telecom in California.  As such, and in order to be truly competitive within its service territory, the Company has a vested interest in promoting policies that allow fixed wireless broadband service providers to access spectrum resources suitable to providing high-speed broadband service.  Traditionally, fixed wireless ISPs have operated in the unlicensed bands (i.e. 2.4 and 5 GHz).  While several fixed wireless providers, including GeoLinks, have been successful in utilizing the unlicensed bands, their application is limited.  The availability of PAL licenses in the 37, 39, and 47 GHz bands, in addition to others the Commission is currently crafting rules for, could provide fixed wireless providers opportunities to provide fiber-like high bandwidth services and robust backhaul for 5G services in areas and in ways it was not previously possible.

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses and for seeking comment on ways to structure the upcoming Auction 103 to try to ensure participation from smaller companies.  While the Company believes that these efforts are a step in the right direction, it is concerned that Auction 103, if not structured the right way, will result in all available spectrum resources being consumed by large companies with seemingly endless capital.  As such, GeoLinks offers the following suggestions to help the Commission put would-be auction participants of all sizes on more equal footing in order to encourage additional licensees and innovative use of the 37, 39, and 47 GHz bands.

I. DISCUSSION

A. The Commission Should Make “White Space” Available for Auction

In the Public Notice, the Commission explains that it does not propose to make the “white space” that results in the 39 GHz band if incumbents chose to receive modified licenses, retaining only “partial PEA holdings (i.e., covering less than the full geographic are of a PEA).[2]  GeoLinks does not believe that leaving these “white spaces” unused promotes sound spectrum policy, especially when these white spaces can be used to further the deployment of advanced spectrum-based services.

In the Public Notice the FCC makes several proposals that would enable small businesses (e.g. small service providers) to participate in Auction 103.  However, as small providers have advocated in numerous proceedings, PEA-sized license areas can be too large.  For example, in the 3.5 GHz proceeding, GeoLinks previously advocated for smaller license areas because PEAs can so vastly differ in size as well as in urban vs. rural make up.[3]  The example GeoLinks provided, specifically, was PEA 2 in Southern California, which encompasses eight counties[4] and includes both large populous areas and large swaths of rural areas that are currently deemed “unserved” by high-speed broadband services.  If smaller “white space” license areas were made available within this PEA, for example, it might allow smaller carriers to provide more pinpointed services to specific communities without having to try and compete with the large providers for an entire PEA.

Attachment A hereto is a screenshot of PEA 2 taken from the California Interactive Broadband Map.[5]  The shaded areas represent areas that are considered unserved (no broadband access).[6]  While most of these areas fall within Connect America Fund Phase II grant areas, this map illustrates that large PEAs can contain both metropolitan areas as well as unserved areas. If “white spaces” in the 39 GHz band exist in PEAs that could be used to help provide much needed services to unserved rural areas, it stands to reason that the Commission should make those areas available to companies that wish to use them.  Conversely, if a remaining “white space” were to fall within a more populated area, allowing smaller companies the chance to utilize that spectrum would only serve to promote competition against companies who may opt for PEA-sized licenses.

GeoLinks fails to see the logic in creating auction procedures to encourage small companies to participate but refrain from creating possible license areas that these small companies could utilize – especially when they are available.  Moreover, not making these smaller license areas available will lead to these areas remaining unused, which will most likely disproportionately affect rural areas.  As such, GeoLinks strongly urges the Commission to reconsider its position to exclude “white space” areas from Auction 103.

B. The Commission Should Eliminate the Proposed Bidding Credit Caps

GeoLinks has previously expressed that incentive auctions tend to only benefit large companies with large amounts of capital to spend.  For this reason, GeoLinks commends the Commission on its decision to implement bidding credits for small businesses and primarily rural service providers.  However, while the bidding credits set forth in the Public Notice will help level the playing field for all bidders in the Auction 103, the Company believes that if the Commission truly wants to “promote small business and rural service provider participation in auctions and in the provision of spectrum-based services,” it must allow the playing field to remain level throughout the entire auction process.  Specifically, GeoLinks urges the Commission to eliminate the bidding credit caps it proposes in the Public Notice.[7]

GeoLinks recognizes that most companies eligible for the bidding credits do not have access to the kind of capital needed to even come close to reaching the bidding credit caps set forth in the Public Notice.  However, this does not mean it’s impossible. To truly create an auction process that promotes the deployment of advanced spectrum-based services, the Commission must account for the financial differences between larger companies and smaller, competitive companies or those focused on serving rural areas.  For example, if a small competitive broadband provider or rural service provider were to successfully raise enough capitol prior to the auction, it is possible that that company could compete head-to-head with a larger provider for the same block of spectrum within a specific license area.  In this circumstance, the smaller/ rural service provider should not be hamstrung by a limit on bidding credits, which could mean the difference between obtaining needed spectrum or not.  To promote innovation, these smaller companies must be given an opportunity to obtain spectrum licenses. Therefore, GeoLinks urges the Commission to refrain from imposing bidding caps on could-be auction winners and make the Auction 103 bidding credits applicable to all bids made by an eligible company, no matter how large.

II. CONCLUSION

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses and to encourage small businesses to participate in Auction 103.  However, in order to truly promote expanded participation in the Auction, GeoLinks recommends that the Commission reconsider making “white spaces” in the 39 GHz band available for auction and remove the bidding credit caps that will only serve to hamstring smaller providers from bidding against large providers.

/

/

/

/

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

May 15, 2019

 

Attachment A

FCC Comments - Microwave Flexible Use Service Licenses

[1] Incentive Auction of Upper Microwave Flexible Use Service Licenses in the Upper 37 GHz, 39 GHz, and 47 GHz Bands for Next-Generation Wireless Services; Comment Sought on Competitive Bidding Procedures for Auction 103, Public Notice, AU Docket No. 19-59, FCC 19-35 (rel. April 15, 2019) (“Public Notice”).
[2] Public Notice at para. 5.
[3] See Reply Comments of California Internet, L.P. dba GeoLinks, GN Docket No. 17-258 (filed January 29, 2018).
[4] PEA 2 encompasses Kern, Los Angeles, Orange, Riverside, San Bernardino, San Luis Obispo, Santa Barbara, and Ventura Counties.
[5] See http://www.broadbandmap.ca.gov/ (screenshot taken May 10, 2019).
[6] Based on California’s definition – areas that are not served by speeds of at least 6 Mbps down/ 1 Mbps up.
[7] See Public Notice at paras. 11-17.

Get to know GeoLinks’ General Counsel and VP of Government Affairs and Education Melissa Slawson

Melissa Slawson - GeoLinks

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

My official title is General Counsel and V.P. of Government Affairs and Education. I handle all legal and regulatory matters, which includes tracking policies and legislation that may affect GeoLinks’ business and advocating for GeoLinks’ interests before various regulatory bodies (including the FCC). In short…I’m the lawyer, and I make sure we follow rules and the rules work for us.

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

I love how fast-paced everything is. There’s never time to get bogged down in the weeds of an issue because a decision usually has to be made quickly. It has made me good at thinking on my feet, researching issues efficiently, and trusting my experience.

Melissa Slawson - GeoLinks - Jerry Brown3. What got you to the position you are in today…what came before GeoLinks?

I’ve been practicing law in the telecommunications regulatory space for over 11 years (wow…that sounds so long when you type it out). I started at the California Public Utilities Commission (CPUC) as a regulator, then entered private practice at a law firm specializing in regulatory work for a variety of telecommunications companies (cable, wireline, wireless, etc.), and then was GC for a small wireless company. The breadth of my legal experience and seeing the telecom world from multiple perspectives really prepared me for my role at GeoLinks. I understand the business side but also understand how regulators and lawmakers see the industry. That’s invaluable when trying to traverse the sometimes rocky legal landscape of providing telecom services.   

4. What government related project are you most passionate about?

I have always tried to make sure that the work I do is also doing good. I started my career as a public servant and while I have moved to the private sector, there is still good to be done. Specifically, I am passionate about connectivity for all. All people, rich or poor, urban or rural, etc. etc. etc. should have access to telecommunications services. This is an issue that I have worked on in some capacity throughout my entire career, and I am so happy to be working for a company with a founding mission to close the digital divide.  

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

Melissa Slawson - geolinks

I started taking Improv classes last May and have started performing fairly regularly. Otherwise, I spend my non-work time doing crossfit, spending time with friends and my dog, Logan, cooking…and watching TV. I love TV.  

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

I’ve never had a cavity. Thanks, Mom!

7. Alright pressure is on….give us your best or favorite motivational quote?

“Wherever you go, there you are.”  It’s a simple statement and really, quite painfully obvious, but I take its meaning to be pretty deep. Wherever you go in this world, no matter who you meet, what job you are doing, etc., you are still you. It is a constant. It is a center. And if things get hard or weird, you can fall back on knowing who you are and move forward from there. And by the same token, it means to be true to yourself, your beliefs, and your values no matter how the world around you changes. I strive to be me all the time.

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?

Be a rockstar.  I want a full sleeve of tattoos, crazy hair, and to sing in front of a stadium full of screaming fans. Sounds amazing!!!

9. Congratulations on recently being elected onto the Schools, Health & Libraries Broadband Coalition’s (SHLB) Board of Expert Advisors. So, what exactly is SHLB and how do you contribute?

I’m excited about being part of the SHLB Board. SHLB is doing some amazing work to close the digital divide by connecting anchor institutions (schools, libraries, hospitals, etc.) which are cornerstones of so many communities. It’s just another piece of the puzzle that is getting connectivity to all Americans. Being part of the board means helping shape the path that SHLB will forge in its efforts over the next few years. It also means having direct input into how companies can help (and be incentivized to help) SHLB’s mission.

Melissa Slawson - GeoLinks - SHLB

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

With our recent Connect America Fund award, all of the work we’re doing to connect anchor institutions, and other opportunities we’re engaged in to help connectivity in California, I am so excited to see how GeoLinks can help change the digital landscape in California and beyond. In just a few short years, GeoLinks will be providing high speed broadband services to areas that may have otherwise never had more than dial-up speeds. (If that!) We are doing good while being successful in business. THAT is my American dream.

Invisible Infrastructure Connecting Rural and Unserved Areas via Spectrum

Presented at CENIC’s 2019 Annual Conference.

SPEAKERS:

Melissa Slawson, General Counsel and VP of Government Affairs and Education, GeoLinks | Louis Fox, President and CEO, CENIC | Rachelle Chong, Attorney/Lobbyist, Law Office of Rachelle Chong | Luis Wong, CEO, K-12 High Speed Network

ABOUT:

Millions of Americans still lack access to high-speed broadband service, especially in rural areas. According to data collected by the California Public Utilities Commission (CPUC), as of the end of 2016, more than 500,000 households were without access to internet service of at least 6 Mbps download and 1 Mbps upload, the minimum threshold for high-speed service in California. This is due largely to the costs associated with building fiber networks to these unserved areas. Wireless services may provide cost-effective solutions and bring much-needed high-speed access to these communities and the anchor institutions that serve them. This panel will explore the role of spectrum-based wireless technologies (i.e. fixed wireless) in closing the digital divide; the benefits to various industry segments and success stories using this technology; and what spectrum policy changes are needed to promote this kind of connectivity at both the federal and state levels.

 

Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz

Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz - GeoLinks

REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS

California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) hereby submits these Reply Comments in response to comments filed on the Notice of Proposed Rulemaking (“NPRM”) released in the above-captioned proceedings.[1]

 

  1. INTRODUCTION AND SUMMARY

GeoLinks is one of the fastest growing Internet and phone providers in America and the fastest growing telecom in California.  In an effort to be a truly competitive service provider throughout its service territory, the Company has a vested interest in ensuring that the FCC’s policies allow fixed wireless broadband service providers access vital spectrum resources.  GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses.  It is undeniable that additional spectrum is necessary to meet “America’s appetite for wireless broadband connections.”[2]  However, GeoLinks urges the Commission not to assume that more unlicensed spectrum is sufficient in and of itself to meet the ever-growing demand for these connections.  Moreover, GeoLinks urges the Commission not to limit how fixed wireless service providers may use these new unlicensed resources, and to create rules that allow for Point-to-Multipoint (“P2MP”) use within the 6 GHz band.

  1. DISCUSSION 

  1. Unlicensed Spectrum is Not a One-Size-Fits-All Solution

Traditionally, fixed wireless ISPs have operated in the unlicensed bands (i.e. 2.4 and 5 GHz).  The lack of access to licensed spectrum has forced fixed wireless providers to get very creative about how they provision highspeed and high capacity broadband services (including multi-gigabit speeds).  While several fixed wireless providers, including GeoLinks, have been very successful in utilizing the unlicensed bands, the application of these bands is limited.  As several commenters note, increased use of the unlicensed bands has created congestion.[3]  As Broadcom points out, “demand for unlicensed services, especially Wi-Fi, continues to grow, and the existing unlicensed spectrum in the 2.4 GHz and 5 GHz bands has become congested.”[4]  In addition, as WISPA’s comments show, the issue of congestion in the unlicensed bands has also been recognized by all current FCC Commissioners.[5]

While GeoLinks sees merit in Broadcom’s assertion that making the 6 GHz band available for unlicensed use “will be a critical step in addressing the looming unlicensed spectrum crunch,”[6] ultimately, GeoLinks believes that relying solely on more unlicensed spectrum availability (without additional opportunities for licensed spectrum) is, at best, a short-term solution.  As Commissioner Rosenworcel notes in her NPRM statement, “by the end of the decade, we will see as many as 50 billion new devices connecting to our networks through the internet of things.”[7]  GeoLinks cautions that as innovation and new devices seek room in the unlicensed bands, the wireless broadband providers that offer competitive connectivity to these new devices will continue to get squeezed.  Inevitably with so many wireless devices and wireless service providers clamoring for the same spectrum, the result will be the same – congestion in the bands and limited opportunities for competition and innovation.

As GeoLinks has expressed before, the availability of unlicensed bands is not a one-size-fits-all solution to the ever-growing demand for spectrum.  In order to craft a more complete, long-term solution, GeoLinks urges the FCC to expand the availability of unlicensed bands in conjunction with efforts to create more opportunities for licensed spectrum for competitive broadband providers.  This dual approach will ensure less congestion in the unlicensed bands for those carriers supplying the connectivity that drive further innovation.

  1. The Commission Should Ensure the New Rules Regarding the Use of the 6 GHz Band Allow for P2MP Use

With respect to new rules to govern unlicensed use of the 6 GHz band, GeoLinks agrees with various commenters that urge the Commission to create new rules that allow for and promote P2MP operations.  For example, the Dynamic Spectrum Alliance (“DSA”) and Starry urge the Commission to allow higher gain antennas and P2MP operations.[8]  Similarly, WISPA makes a number of suggestions that would allow for P2MP operations such as refraining from limiting the types of services that can be offered in the U-NII-5 and U-NII-7 bands.[9]

As GeoLinks has previously explained, P2MP technology creates opportunities to connect multiple users in a more cost-effective manner (even if miles apart), making it ideal for serving multiple customers in one area at a lower cost.  As Starry notes, “point-to-multipoint deployments are essential to fixed wireless providers.”[10]  Moreover, DCA explains that these technologies (as well as point-to-point) “will help improve connectivity and competition in all markets, including but not limited to underserved areas and rural communities.”[11]  For these reasons, GeoLinks urges the Commission to develop rules that allow for P2MP use in the 6 GHz Band.

  1. CONCLUSION

GeoLinks applauds the Commission’s efforts to make more spectrum resources available for wireless uses.  However, as the Commission strives to create policies and rules for unlicensed spectrum use in the 6 GHz Band, GeoLinks urges the Commission not to assume that more unlicensed spectrum is sufficient in and of itself to meet the ever-growing demand for these connections and to promote competition by creating rules that allow for P2MP use.

 

Respectfully submitted,

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

March 18, 2019

[1] Unlicensed Use of the 6 GHz Band; Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz, Notice of Proposed Rulemaking, ET Docket No. 18-295 and GN Docket No. 17-183, FCC 18-147 (rel. Oct. 24, 2018) (“NPRM”).  The NPRM was published in the Federal Register on December 17, 2018.  See 83 Fed. Reg. 64506 (Dec. 17, 2018).
[2] NPRM at para. 4.
[3] See Comments of Broadcom Inc., ET Docket No. 18-295 (filed February 15, 2019) (“Broadcom Comments”) at 1, Comments of the Wireless Internet Service Providers Association, ET Docket No. 18-295 (filed February 15, 2019) (“WISPA Comments”) at 5, Comments of Dynamic Spectrum Alliance, ET Docket No. 18-295 (filed February 15, 2019) (“DSA Comments”) at 1.
[4] Broadcom Comments at 1.
[5] See WISPA Comments at 6-7 citing NPRM statements of Chairman Pai and Commissioners Carr, O’Rielly, and Rosenworcel.
[6] Broadcom Comments at 1
[7] NPRM statement of Commissioner Rosenworcel at 1.
[8] DSA Comments at 3, Comments of Starry, Inc., ET Docket No. 18-295 (filed February 15, 2019) (“Starry Comments”) at 2.
[9] See WISPA Comments at 10.
[10] Id.
[11] DSA Comments at 15.

SHLB Coalition Announces 5 New Board Members

Original Source SHLB.org

Washington, D.C. (December 5, 2018) – Today the Schools, Health & Libraries Broadband (SHLB) Coalition announced five additions to its board of directors for 2019:

  • Cindy Aden, state librarian, State of Washington;
  • Erik Heinrich, senior manager SLED business development, Ruckus Networks, an ARRIS Company;
  • Tim Koxlien, CEO, Telequality Communications;
  • Ray Timothy, CEO and executive director, Utah Education & Telehealth Network; and
  • Melissa Slawson, general counsel and VP of government affairs and education, GeoLinks.

“These individuals and their organizations are dedicated to achieving digital equity through connecting community anchor institutions (CAIs),” said John Windhausen Jr., executive director of the SHLB Coalition, “Their passion and diverse areas of expertise will make SHLB’s advocacy for CAI broadband connectivity even stronger.”

The current SHLB board of directors appointed Aden, Heinrich, Koxlien, and Timothy, while SHLB’s membership elected Slawson to serve. The incoming members, who begin their three-year terms on the board on January 1, 2019, made the following statements:

“As the State Librarian for Washington State, I am eager to get more involved in the nuts and bolts of broadband and e-rate issues, as my state readies itself for significant broadband legislation that will include the State Library as one of the stakeholders. I am honored to follow the work of my esteemed colleague, the Montana State Librarian Jennie Stapp, and I look forward to working with the SHLB board.” – Cindy Aden, State Librarian, Washington State.

“As a research and education network, we have found SHLB to be a great resource for our organization as we strive to network for education and telehealth in Utah. I am excited to be on the board so that we can share our experiences and strengths with others throughout the country.” – Ray Timothy, Utah Education & Telehealth Network

“SHLB is the only voice representing the common broadband interests of community anchor institutions, local and state government entities and service providers. Under John Windhausen’s leadership, our members receive the benefit of a well respected, hard working and dedicated organization. I am grateful to be a part of the work that SHLB does in helping to solve broadband problems throughout the US.” – Tim Koxlien, Telequality Communications.

“I am honored to join SHLB in raising awareness around the challenges of Digital Equity and advocating for solutions to the disparity in online access among our Nation’s diverse populations of students, teachers and their communities. SHLB’s mission is closely aligned with this very issue and I look forward to fulfilling a role as a member of the SHLB board of directors while working closely with the SHLB member community to help close the digital divide.” – Erik Heinrich, Ruckus Networks, an ARRIS Company.

“I am excited and honored to have been chosen as the newest member of the SHLB Board of Directors. Universal broadband access has always been a personal passion of mine and I look forward to representing GeoLinks as I work with SHLB and my fellow Board members to bring more awareness to the issue and create policies that help bridge the digital divide.” – Melissa Slawson, GeoLinks.

###

About SHLB:

The SHLB Coalition is a non-profit, 501(c)(3) advocacy organization that supports open, affordable, high-quality broadband connections for anchor institutions and their surrounding communities. The SHLB Coalition is based in Washington, DC and has a diverse membership of commercial and non-commercial organizations from across the United States. To learn more, visit www.shlb.org.

For Immediate Release

Contact:
Alicja Johnson
[email protected]
(202) 261-6599

Comments to Consider Modifications to the California Advanced Services Fund

BEFORE THE
CALIFORNIA PUBLIC UTILITIES COMMISSION

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

 

OPENING COMMENTS OF CALIFORNIA INTERNET, L.P. (U-7326-C) DBA GEOLINKS ON PROPOSED DECISION OF COMMISSIONER GUZMAN ACEVES IMPLEMENTING THE CALIFORNIA ADVANCED SERVICES FUND INFRASTRUCTURE ACCOUNT REVISED RULES

November 29, 2018 

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

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

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

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

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

Respectfully submitted,

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

November 29, 2018

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

Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band

Before the

Federal Communications Commission

Washington, DC  20554

Expanding Flexible Use of the 3.7 GHz to 4.2 GHz Band - GeoLinks

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 (“NPRM”) released in the aforementioned docket.[1]

  1. INTRODUCTION

GeoLinks is the fastest growing Internet and phone provider in America and the fastest growing telecom in California.  In addition, GeoLinks was recently awarded Connect America Fund Phase II Auction funding to serve 3883 Census Blocks in California and Nevada.  The Company has a vested interest in ensuring that the FCC’s policies allow competitive broadband providers to access vital spectrum resources and believes that the 3.7-4.2 GHz band provides opportunity for such access, subject to certain rules and requirements.

  1. DISCUSSION

  2. GeoLinks Supports the BAC’s Proposed Solution to Allow Spectrum Access for Fixed Wireless Providers in the 3.7-4.2 GHz Band

Millions of Americans lack what is considered, by today’s standards, highspeed broadband access – especially in rural areas.  As GeoLinks has previously advocated, 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, often resulting in these areas being left on the wrong side of the digital divide.  However, fixed wireless broadband technology can provide highspeed broadband to consumers in these areas for a fraction of the cost of traditional, wired networks. In addition, fixed wireless providers can (and do in some areas) offer competitive choice to consumers in urban and suburban areas.

Like other fixed wireless providers, GeoLinks’ technology platform depends on access to spectrum resources sufficient to support enterprise-level broadband connections. While spectrum resources do exist that have allowed fixed wireless providers to successfully deploy internet services in some areas, these resources have primarily been available on an unlicensed basis only.  Unlicensed bands are not a one-size-fits-all option as they are often subject to congestion and interference that can degrade wireless signals.

In order for fixed wireless broadband providers to truly compete with traditional, wired service providers, additional spectrum resources are needed. GeoLinks believes 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.

The BAC has set forth a “win-win-win solution that: (1) protects incumbent FCC operators from harmful interference; (2) clears a portion of the band for exclusive flexible use licensing; and (3) enables fixed P2MP broadband providers to deploy badly needed high-throughput broadband to unserved and underserved customers.”[2]  GeoLinks believes that this proposed solution strikes the right balance with respect to spectrum sharing, frequency coordination, buildout requirements, and Point-to-Multipoint (“P2MP”) deployment.  As such, GeoLinks supports the opening comments submitted by the BAC in response to the NPRM.

  1. The Commission Should Reject Any Arguments that Fixed Wireless Providers Already Have Access to All the Spectrum Resources They Need

GeoLinks urges the Commission to reject any argument that the spectrum resources that fixed wireless providers have now are “good enough.”  This status-quo mentality is exemplified in comments that appear to suggest that fixed wireless providers have all the spectrum they need or will get it eventually, so there is no need to look to the 3.7-4.2 GHz band for more.  Specifically, the C-Band Alliance explains that “any legitimate requirement for more spectrum for P2MP networks can be met using bands that are either currently available or are being considered for such operations.”[3]

GeoLinks strongly disagrees that fixed wireless providers have enough spectrum already.  As explained above, currently fixed wireless providers primarily have access to only unlicensed spectrum.  In situations where only unlicensed spectrum is available, most connections are limited to point-to-point (“P2P”) connections over short distances to avoid interference with other users.  While fixed wireless providers have had success with these P2P connections, considering them “good enough” fails to account for all of the benefits that the technology couldprovide.  First, even with extensive engineering and coordination, there is no guarantee that interference won’t occur at some point over unlicensed spectrum bands.  This is especially true in densely populated, urban areas where there are numerous users in the unlicensed band.  This interference can make it difficult and costly to engineer a dedicated link to a customer to ensure enterprise-grade broadband service – a service that a fixed wireless provider mustoffer to be competitive in urban markets.  Second, P2P connections require expensive transmission equipment for each link (vs. one for multiple links).  These costs can make it difficult for fixed wireless providers to competitively price broadband services, especially in residential markets where P2P equipment may be cost prohibitive for residential subscribers.

GeoLinks has advocated for the benefits of P2MP services in numerous filings before the Commission.  This technology creates opportunities to connect multiple users in a more cost-effective manner (even if miles apart), making it ideal for serving multiple customers in one area at a lower cost.  Despite the benefits of this technology, however, current spectrum policies hinder fixed wireless providers’ ability to take advantage of it.  For example, P2MP connections are more susceptible to congestion and interference caused from extensive use of the unlicensed bands, especially in urban, highly-populated areas. This makes high-quality P2MP connections over unlicensed spectrum nearly impossible in some areas, clearly refuting the concept that fixed wireless providers have all the spectrum they need.

Moreover, while there are a number of active proceedings before the Commission that may provide fixed wireless providers the ability to access additional licensed, light-licensed, or shared spectrum resources, many of those proceedings are also considering whether specific spectrum bands are better used for other uses (e.g. mobile wireless).  In addition, the outcomes of those proceedings are still very much pending before the Commission and the Commission should not foreclose the option of fixed wireless use in the 3.7-4.2 GHz band just because spectrum might be available in another band at some point.

The BAC’s suggested solution for the 3.7-4.2 GHz band addresses the current spectrum limitations experienced by fixed wireless providers by proposing practical options for P2MP use within the band that will not interfere with existing use by FSS Operators.  The Commission should reject any arguments that fixed wireless providers have enough spectrum now (or will eventually) and therefore the Commission should not consider expanded use of the 3.7-4.2 GHz band.  Instead, GeoLinks urges the Commission to look to implement the BAC’s proposal and adopt spectrum policy that promotes innovation and competition.

  1. The Commission Should Adopt Robust Build-Out Requirements for the Band

As GeoLinks has advocated before, the Company believes that spectrum rights should be subject to robust build-out and “use it or lose it” requirements.  In its opening comments, the BAC supports the NPRM’s 12-month build-out period and proposes other build out requirements including limitations on channel reservation periods, minimum build-out standards for P2MP licensees, and limitations on P2MP spectrum use until build out is complete.[4]  GeoLinks supports these suggested build-out requirements and urges the Commission to adopt them.

  • CONCLUSION

GeoLinks supports the BAC’s opening comments submitted on the NPRM and urges the Commission to adopt its win-win-win proposal for the 3.7-4.2 GHz band.

 

Respectfully submitted,

GEOLINKS, LLC

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 27, 2018

[1]Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Order and Notice of Proposed Rulemaking, GN Docket No. 18-122, FCC 18-91 (rel. July 13, 2018) (“NPRM”).
[2]Comments of the Broadband Access Coalition, GN Docket 18-122 (filed October 29, 2018) (“BAC Comments”) at 3.
[3]Comments of the C-Band Alliance, GN Docket 18-122 (filed October 29, 2018) at 45.
[4]SeeBAC Comments at 25.

Procedures to Identify and Resolve Location Discrepancies in Eligible Census Blocks Within Winning Bid Areas

Before the

Federal Communications Commission

Washington, DC  20554

 

Procedures to Identify and Resolve Location ) WC Docket No. 10-90 Discrepancies in Eligible Census Blocks ) Within Winning Bid Areas

 

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 filed on the Public Notice released by the Wireline Competition Bureau (“Bureau”) regarding procedures to identify and resolve location discrepancies in eligible census blocks within Connect America Fund Phase II (“CAF II”) winning bid areas on September 10, 2018.[1]

 

  1. INTRODUCTION

Several commenters in the aforementioned proceeding share GeoLinks’ view that the Bureau should create a straightforward process for resolving location discrepancies that may exist in Phase II auction support areas.  GeoLinks believes that such a process is necessary to ensure that CAF II recipients and relevant stakeholders are able to gather and report accurate location-specific data.  As such, GeoLinks makes the following recommendations.

 

  1. DISCUSSION
  2. Prospective Developments

In the Public Notice, the Commission asks whether “actual locations should include prospective developments that have a reasonable certainty of coming into existence within the support term.”[2]  GeoLinks agrees with commenters that ask the Commission not to require CAF II recipients to include prospective developments into the definition of “actual location.”

In both California and Nevada, the states for which GeoLinks has been awarded CAF II funding, there have been many instances where housing developments have been planned, or even started, but then downsized, abandoned, or put on indefinite hold.  While many of these developments do eventually get built, as WISPA notes, there is no guarantee that information regarding new developments will stay constant past the one-year period of determining “locations” or that those plans won’t be modified to increase or decrease the number of housing units, small businesses, etc.[3]  As USTelecom explains, “Providers cannot be omnipresent in local real estate planning over the next year and auditing whether a provider could have, or should have, known about a prospective development would be extremely subjective.”[4] Moreover, other commenters advocate for the Bureau to “permit support recipients to rely on any reasonably current data source” and to avoid “imposing evidentiary burdens beyond those that are strictly necessary.”[5]

For these reasons, GeoLinks urges the Bureau not to requirethat prospective developments be included in the definition of “actual location.”  However, if a CAF II recipient chooses to include prospective developments in its definition of actual locations, GeoLinks agrees with WISPA that it should be allowed to do so if it can provide information to show that specific prospective locations are more likely than not to be constructed and inhabited within the six-year buildout period.[6]

 

  1. Reliability and Validity of Data

In its opening comments, GeoLinks urged the Bureau not to limit broadband providers’ ability to determine what methodology may work best for them to gather information regarding the number of locations within an area so long as the provider can explain that methodology.  This sentiment was echoed by several commenters that offered numerous proposals beyond those methodologies that the Public Notice called “generally accepted.”[7]

US Telecom suggests that providers should be able to rely upon desktop geolocation or automated address geocoding.[8]  WISPA discusses the possibility of aerial imagery (which GeoLinks also suggested in its opening comments) in addition to the possibility of combining the findings from desktop geolocation using web-based maps and imagery with other qualitative criteria such as roof size or other visual evidence.[9] Verizon suggests refining initial analysis with web-based maps or targeted GPS data in the field.[10]  Hughes urges the Bureau to allow recipients to utilize third-party geocoding providers.[11]  Moreover, Commnet, explains that any process to collect required location-specific showings “must account for areas such Tribal Lands where standard street addresses are not available and commercial geocoding data are scant and unreliable.”[12]

GeoLinks believes that the proposal of many different options makes clear that there are many ways for CAF II recipients to verify location data.  So long as a CAF recipient’s selected methodology (or methodologies) can be explained, it should not be precluded from using any reasonable method.  Therefore, GeoLinks continues to urge the Bureau not to limit available methodologies to verify location data.

 

  1. Relevant Stakeholder’s Evidence

With respect to the definition of “relevant stakeholders,” GeoLinks strongly agrees with WISPA that this definition should be limited to individuals, state and local authorities, and Tribal governments, in the relevant supported area.[13]   Additionally, GeoLinks strongly agrees that “the evidence submitted by stakeholders should be the same as is required to be submitted by participants.”[14]  Both GeoLinks and WISPA urge the Bureau to require relevant stakeholders to submit a narrative description of the methodology they used to challenge the location information provided by a CAF II recipient and to certify under penalty of perjury that 1) the location data they are providing is accurate, 2) the stakeholder is located (or represent individuals that are located) within the relevant geographic area, and 3) that the stakeholder is not associated in any way with a competitor.[15]  As WISPA explains, “it should not be sufficient for a stakeholder to solely allegedeficiencies in the participant’s methodology.”[16]

 

  • CONCLUSION

Based on the foregoing, GeoLinks urges the Bureau to adopt the recommendations discussed herein, as agreed to by several parties to this proceeding, regarding procedures to identify and resolve location discrepancies in eligible census blocks within CAF II winning bid areas.

 

Respectfully submitted,

 

GEOLINKS, LLC

 

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 13, 2018

[1]Public Notice, “Wireline Competition Bureau Seeks Comment on Procedures to Identify and Resolve Location Discrepancies in Eligible Census Blocks Within Winning Bid Areas,” WC Docket No. 10-90, DA 18-929 (rel. Sept. 10, 2018) (“Public Notice”).
[2]Public Notice at 5.
[3]See Comments of the Wireless Internet Service Providers Association, WC Docket 10-90 (filed Oct 29, 2018) (“WISPA Comments”) at 3.
[4]Comments of USTelecom, WC Docket 10-90 (filed Oct. 29, 2018) (“USTelecom Comments”) at 3.
[5]Comments of Verizon, WC Docket 10-90 (filed Oct. 29, 2018) (“Verizon Comments”) at 5 and Comments of Hughes Network Systems, WC Docket 10-90 (filed Oct. 29, 2018) (“Hughes Comments”) at 2, respectively.
[6]WISPA Comments at 3.
[7]SeePublic Notice at 11.
[8]USTelecom Comments at 4.
[9]WISPA Comments at 4-5.
[10]Verizon Comments at 3,
[11]Hughes Comments at 3
Comments of Commnet Wireless, Inc., WC Docket 10-90 (filed Oct. 29, 2018) at 2.
[13]SeeWISPA Comments at 6.  See alsoUSTelecom comments at 5.
[14]WISPA Comments at 7.
[15]SeeWISPA Comments at 6.
[16]WISPA Comments at 7 (emphasis added).

Spectrum as Infrastructure – Connecting Rural and Underserved Areas

Spectrum as Infrastructure – Connecting Rural and Underserved Areas

Panel discussion at the 8th Annual SHLB Conference.

Panel Description: More than 15 million Americans in rural and tribal areas still lack access to 25/3 broadband, and a disproportionate number of rural schools and libraries lack high-capacity broadband connections. Wireless services may provide cost-effective solutions to address this rural broadband gap. Fixed wireless access can provide broadband at high capacity (100/10 Mbps or better), or over long distances to remote locations, at a fraction of the cost of trenching fiber. This panel will describe three pending FCC rulemakings that could open access to a large new supply of both unlicensed and lightly-licensed shared spectrum.

Featured Speakers in Highlights: Melissa Slawson (GeoLinks) Andrew Clegg (Google), Moderator: Michael Calabrese (New America OTI)