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GeoLinks Comments on Auction of Priority Access Licenses

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

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

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

INTRODUCTION AND SUMMARY

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

 

DISCUSSION

The Commission Should Refrain from Adopting CMA-Level Bidding

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

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

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

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

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

The Commission Should Not Establish Bidding Credit Caps

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

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

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

CONCLUSION

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

 

Respectfully submitted,

California Internet, L.P. DBA GeoLinks                                                  

/s/ Skyler Ditchfield, Chief Executive Officer

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

 

November 12, 2019

 

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

GeoLinks Earns Spot on Inc. 5000 List Third Year Running

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

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

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

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

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

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

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

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

About GeoLinks

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

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

More about Inc. and the Inc. 5000

Methodology

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

About Inc. Media

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

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

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

GeoLinks Formally Approved by USAC to Begin CAF Build Out

The Universal Service Administrative Company has officially cleared GeoLinks to begin CAF II build outs in California and Nevada

CAMARILLO, Calif.–(BUSINESS WIRE)–On Wednesday, June 5th, 2019 the Universal Service Administrative Company (USAC) formally approved GeoLinks to start receiving funding for the Company’s Connect America Fund Phase II (CAF II) buildout in California and Nevada. Announced by the Federal Communications Commission (FCC) in August of 2018 as the largest CAF II winner in the state of California, and 5th largest winner in the nation overall, with GeoLinks’ deployment plans and Letters of Credit officially approved, the innovative telecom will officially begin broadband deployment this summer.

Awarded a total of $87.8M in the auction, GeoLinks will provide more than 11,000 rural locations across California and Nevada with Internet at 100 megabits per second. The Company is also confident that this new infrastructure will simultaneously reduce the cost of bringing high speed broadband access to anchor institutions, such as Schools, Libraries, Hospitals, and Community Colleges, throughout both states.

“We are thrilled to have officially cleared both the FCC and USAC’s approval process for CAF II,” stated GeoLinks’ Co-Founder and CEO Skyler Ditchfield. “While the announcement back in August was undoubtedly exciting, we are now officially in the position to begin deployment throughout both states.”

With the GeoLinks’ team fully prepared to break ground, the Company is now looking forward to participating in the FCC’s LIFT America Act, which will support another $40B worth of broadband infrastructure deployment in aims of closing the digital divide.

For media inquiries and interview requests, please contact Lexie Smith at [email protected]

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.

GeoLinks’ CEO Skyler Ditchfield Appointed to the FCC’s Broadband Deployment Advisory Committee

The Federal Communications Commission announces Skyler Ditchfield as a member of the newly re-chartered Broadband Deployment Advisory Committee

CAMARILLO, Calif.–(BUSINESS WIRE)–On May 16, 2019, Chairman Ajit Pai of the Federal Communications Commission (FCC) announced his appointment of Skyler Ditchfield, Co-Founder and CEO of GeoLinks, to serve as an official member of the newly re-chartered Broadband Deployment Advisory Committee (BDAC). Of the 39 listed appointees, Skyler Ditchfield serves as the only Southern California representative.

According to the FCC’s official release, “In its second term, the BDAC will continue its work to craft recommendations for the Commission on ways to accelerate the deployment of high-speed Internet access, or ‘broadband,’ by reducing and/or removing regulatory barriers to infrastructure investment and strengthening existing broadband networks in communities across the country.” The release continues by outlining the BDAC as an opportunity for interested stakeholders to exchange ideas and develop recommendations to the Commission on broadband deployment, to enhance the Commission’s ability to deploy broadband to all Americans.

Previously appointed to the Streamlining Federal Siting Working Group in 2017, and the Disaster Response and Recovery Working Group in 2018 (both BDAC sub groups), Ditchfield’s elevated appointment will enable him to provide strategic recommendations and influence action to close the digital divide on a national scale.

“I have been continually impressed by Chairman Pai, his administration, and all the work that they have done thus far,” stated Ditchfield. “They’ve truly worked hard to level the playing field for all sized ISPs. They’ve put forward significant new dollars towards broadband investment and are staying true to their promise of closing the digital divide. With GeoLinks’ founding mission being to close the digital divide, we have a multitude of case studies that have proven capable of closing the gap in California. Being that all of these projects demonstrate proven and transferrable methods, I am very excited to get to work with both the BDAC and my two designated working groups to cultivate the most realistic and feasible path forward nationally.”

The renewed BDAC will hold its first meeting on Thursday, June 13, 2019, in the Commission Meeting Room at FCC Headquarters, located in Washington, DC. The meeting is open to the public. The FCC will accommodate as many attendees as possible; however, admittance will be limited to seating availability. The Commission will also provide audio and/or video coverage of the meeting over the Internet from the FCC’s web page at www.fcc.gov/live.

The FCC’s official Public Notice can be accessed online via the following link: https://www.fcc.gov/document/fcc-announces-re-chartered-bdac-membership-and-first-meeting

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

About GeoLinks

Headquartered in Southern California, GeoLinks is a leading telecommunications company and competitive local exchange carrier (CLEC) public utility, nationally recognized for its innovative Internet and Digital Voice solutions. Ranked first in category on Inc. Magazine’s Inc. 5000 Fastest Growing Companies in America in both 2017 and 2018, GeoLinks delivers Enterprise-Grade Internet, Digital Voice, SD-WANCloud On-ramping, Layer 2 Transport, and both Public and Private Turnkey Network Construction expertly tailored for businesses and Anchor Institutions nationwide.

GeoLinks’ accelerated success is largely due to its flagship product, ClearFiber™, which offers dedicated business-class Internet with unlimited bandwidth, true network redundancy, and guaranteed speeds reaching up to 10 Gbps. Named “Most Disruptive Technology” in the 2018 Central Coast Innovation Awards, GeoLinks’ ClearFiber™ network is backed by a carrier-grade Service Level Agreement boasting 99.999% uptime and 24/7 in-house customer support. With an average installation period of 4 to 7 days, GeoLinks is proud to offer the most resilient and scalable fixed wireless network on the market.

Contacts

Media Inquiries:
GeoLinks
Lexie Smith, VP of Business Development
[email protected]

Local internet service provider wins $87.8 million in government funding

 Local internet service provider wins $87.8 million in government funding - GeoLinks - Ryan Hauf

Photo taken by GeoLinks Co-Founder and CTO Ryan Hauf

 

A local internet service provider is going regional, thanks to $87.8 million in funding from the federal government.

GeoLinks, an 8-year-old Camarillo-based ISP that primarily serves businesses and rural areas, is among several companies that will receive funding from the Federal Communication Commission’s Connect America Fund Phase II Auction. The company plans on using the capital to bring high-speed internet to rural communities previously lacking connectivity.

The first phase of the fund was held around five years ago and catered to larger, national ISPs.

Money from the fund’s second phase, which totals around $1.5 billion, will be paid out in monthly installments over a 10-year period. GeoLinks will receive $731,000 monthly starting in May, according to CEO Skyler Ditchfield. The company is primarily focused on providing internet service to rural regions and businesses that may be overlooked by the nation’s larger ISPs.

Ditchfield said money from the Connect America fund would allow GeoLinks to create a residential division but said the focus would still be on primarily rural areas.

“It enables connectivity in rural parts of California,” Ditchfield said. “People that live in those locations can try new business ventures, educate themselves better and enable a lot of new internet services like video.”

GeoLinks currently provides internet service to various parts of Ventura County and most other Southern California counties. Local areas serviced by the company include rural parts of Ojai and Thousand Oaks. The company also services entities such as schools, libraries and hospitals in rural areas across the state.

The company plans on using the bulk of the money for new equipment and infrastructure, such as towers, wireless links and distribution. GeoLinks also plans on using around $5.5 million of the funding it will receive to service areas on the California-Nevada border. While GeoLinks will use some of the funding to begin servicing parts of Camarillo and Oxnard, it will also allow the company to make a larger regional push into the Central Valley and around northeastern parts of the state.

The company is allowed up to six years to use the funds to build out its network, although Ditchfield said GeoLinks aims to complete work within four years. As payments will be doled out throughout the next decade, funds received after the network is built will be used for operating costs, such as rent and maintenance.

Applications for the third phase of the fund will likely open in late 2019.

Tyler Hersko covers business news for the Ventura County Star. Reach him at [email protected] or 805-437-0312.

MORE: Camarillo-based GeoLinks joins universities on wildfire project

Wildfire Technology Innovation Summit

Lessons Learned in San Diego – Panel at California’s First Ever Wildfire Technology Innovation Summit

Moderator:

Jessica Block, Assistant Director of WIFIRE Lab, Qualcomm Institute, UC San Diego

Panelists:

1. Skyler Ditchfield, CEO, GeoLinks

2. Tony Mecham, San Diego Unit Chief, CAL FIRE

3. Brian D’Agostino, Director of Fire Science & Climate Adaptation, SDG&E

4. Graham Kent, Director, Nevada Seismological Lab, University of Nevada-Reno

Connect America Fund Making Federal Dollars Work for California

Presented at CENIC’s 2019 Annual Conference.

SPEAKER:

Skyler Ditchfield, Co-Founder and CEO, GeoLinks

ABOUT:

The Connect America Fund Phase II Auction (CAF II) was created by the Federal Communications Commission to distribute federal grant dollars to enable broadband infrastructure buildout to rural areas of the country that lack basic broadband services. In August 2018, GeoLinks was awarded approx. $88 Million to deploy high-speed broadband network facilities to eligible areas in California and Nevada (to be distributed over 10 years). In this discussion, GeoLinks’ CEO, Skyler Ditchfield, will discuss the CAF II application process, awarded areas, and opportunities for creating synergies between CAF II and other broadband grant programs. He will also discuss possible pain points and policy changes needed to streamline deployment and ensure CAF II funding is used as efficiently as possible to connect unserved Americans.

Strategies for Addressing the Broadband Digital Divide

Strategies for Addressing the Broadband Digital Divide

Presented at CENIC’s 2019 Annual Conference.

Featured Speakers:

Skyler Ditchfield, Co-Founder and CEO, GeoLinks | Louis Fox, CEO and President, CENIC | Matt Rantanen, Director of Technology, Southern California Tribal Chairmen’s Association | Sunne Wright McPeak, CEO, California Emerging Technology Fund | Steven Huter, Director, Network Startup Resource Center, University of Oregon

About:

A recent article in the New York Times titled, “Digital Divide Is Wider Than We Think, Study Says” (12/4/18), notes that, “Fast internet service is crucial to the modern economy, and closing the digital divide is seen as a step toward shrinking the persistent gaps in economic opportunity, educational achievement and health outcomes in America.” While the FCC concludes that broadband is not available to 24.7 million Americans, a recent study by Microsoft states that “162.8 million Americans do not use the internet at broadband speed” and that this “discrepancy is particularly stark in rural areas.”

Many projects that might address this broadband disparity have been unattractive to private sector providers, given the difficulty of generating a return on investment necessary for the capital expenditures for construction of necessary middle-mile infrastructure. And, while there is a tendency to see the digital divide as a rural issue, many urban areas show a similar lack of access to fast home Internet, though often for different reasons — lack of affordable broadband and/or lack of motivation for broadband adoption.

The picture is not entirely gloomy: There are many creative approaches to address issues of access, affordability, and adoption, often pooling sources of funds, integrating two (or more) broadband technologies, and through partnerships that involve public, government, and private sector partners. The panelists, all of whom are engaged in every aspect of broadband from public policy to project deployment, will highlight and discuss successful strategies to address the broadband digital divide and engage conference participants in a discussion about how to scale locally instantiated projects to reach across all of California (and beyond).

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.