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Experts Investigating Starlink Are Not Convinced that Elon Musk’s Satellite Project Provides Rural Broadband Solution

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Photo of Cartesian Vice President Michael Dargue from February 2015 by Telecom Finance

February 16, 2021—While SpaceX touts Starlink as the answer to the world’s dearth of broadband coverage, experts are not convinced that it will be able to meet increasing demand.

Elon Musk’s SpaceX began launching a constellation of small satellites early in 2018 with the goal of providing affordable satellite broadband coverage to areas around the globe that historically lacked any access to the internet. On February 16, 2021, Space X launched its 19th mission adding to the hundreds of satellites in low orbit.

Cartesian, a U.S.-based technology consulting firm, recently published its final report as part of its “Starlink RDOF Assessment.” According to its findings, even under generous circumstances, Starlink would be unable to provide reliable internet coverage to its consumers.

To be considered for the RDOF bidding process, a company must commit to providing 100 megabits per second download and 20 megabits per second upload speed to consumers.

Michael Dargue, vice president of Cartesian, wanted to be clear that the assessment was based on publicly available information and that the specific technical abilities of the satellites are largely unknown. Dargue stated that the assessment made several assumptions. He spoke at a Tuesday webinar.

First, he stated that the assessment assumed that the satellites could transfer 20 gigabits per second and that each satellite had an effective range of 300,000 square miles. Additionally, he stated that the assessment assumed that the maximum latitude of center of satellite coverage area was 53 degrees. Dargue added that natural features such as mountains and forests were not accounted for in the assessment.

Dargue stated that with these assumptions made, the assessment indicated that 56-57 percent of consumers reliant on Starlink would experience degradations in their broadband service during peak hours (between 6PM and 12AM). Cartesian modeled two scenarios with megabits per second as the independent variable and percent of subscribers that received uncompromised service as the dependent variable.

The first model assumed that during peak hours users were using 20.8 megabits per second, and the second model assumed that peak hour users were using 15.3 megabits per second. These models both found that more than half of users would experience degradation in their service.

Dargue said that because SpaceX plans to use Starlink for military, commercial, and other non-fixed broadband sources (such as “smart” cars), Starlink’s ability to provide sufficient broadband coverage would be even further diminished. The Cartesian assessment estimated that if 50 percent of Starlink’s satellite capacity is dedicated to non-RDOF network users, 95-92 percent of RDOF users would receive insufficient coverage.

Screenshot of the Tuesday webinar

He stated that these issues will only become worse as the number of users and their broadband dependent devices increase, and that there would be a significant capacity shortfall by 2028. Dargue added that because SpaceX’s future business plans for Starlink are always changing the FCC may find it difficult to determine if SpaceX is complying with its contractual obligations.

Late last year, it was announced that SpaceX had secured a sizeable contract with the FCC’s Rural Digital Opportunity Fund. SpaceX’s contract was worth $885.5 million of a total of $9.2 billion that was made available to the fund.

SpaceX’s Starlink will be responsible for providing 640,000 locations with broadband coverage, mostly on the East Coast and northwestern U.S. Almost 88.3% of the locations Starlink will be covering are considered rural, with its five largest regions being Pennsylvania, Virginia, Washington, Mississippi, and Alabama.

Starlink will work by assembling its planned fleet of approximately 12,000 satellites into an overlapping tessellation of coverage to ensure that no region that is ought to be covered is missed.

Reporter Ben Kahn is a graduate of University of Baltimore and the National Journalism Center. His work has appeared in Washington Jewish Week and The Center Square, among other publications. He he covered almost every beat at Broadband Breakfast.

FCC

FCC to Establish New Space Bureau, Chairwoman Says

‘The new space age has turned everything we know about how to deliver critical space-based services on its head.’

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Photo of FCC Chairwoman Jessica Rosenworcel, via fcc.gov

WASHINGTON, November 3, 2022 — The Federal Communications Commission will add a new space bureau that will modernize regulations and facilitate innovation, Chairwoman Jessica Rosenworcel announced Thursday.

The new bureau is intended to facilitate American leadership in the space economy, boost the Commission’s technical capacity, and foster interagency cooperation, Rosenworcel said, speaking at the National Press Club.

“The new space age has turned everything we know about how to deliver critical space-based services on its head,” Rosenworcel said. “But the organizational structures of the [FCC] have not kept pace,” she added.

The space economy is “on a monumental run” of growth and innovation, the chairwoman argued, and the FCC must remodel itself to facilitate continued growth. Rosenworcel said the commission is currently reviewing 64,000 new satellite applications, and she further noted that 98 percent of all satellites launched in 2021 provided internet connectivity. By the end off 2022, operators will set a new record for satellites launched into orbit, she said.

The FCC will not take on new responsibilities, Rosenworcel said, but the announced restructuring will help the agency “perform[] existing statutory responsibilities better.” In September, Rep. Cathy McMorris Rodgers, R–Wash., warned the FCC against overreaching its statutory mandate and voiced support for robust congressional oversight – a position reiterated by House staffers Wednesday.

“The formation of a dedicated space bureau within the FCC is a positive step for satellite operators and customers across the United States,” said Julie Zoller, head of global regulatory affairs at Amazon’s satellite broadband Project Kuiper, on a panel following Rosenworcel’s announcement.

“An important part of [Rosenworcel’s] space agenda is ensuring that there is a competitive environment in all aspects of that space,” said Umair Javed, the chairwoman’s chief counsel, during the panel. “So we’ve taken action to update our rules on spectrum sharing to make sure that there are opportunities for multiple systems to be successful in low Earth orbit.

“We’ve granted a number of experimental authorizations to companies that are doing really new…things,” Umair continued.

The FCC in September required that low–Earth orbit satellite debris be removed within five years of mission completion, a move Rosenworcel said would clear the way for new innovation.

In August, the FCC revoked an $885 million grant to SpaceX’s Starlink satellite-broadband service. FCC Commissioners Brendan Carr and Nathan Simington criticized the reversal, and Starlink has since appealed it.

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Satellite

Starlink Should Prevail in RDOF Challenge, Says Tech Think Tank

TechFreedom argued that the FCC overstated the flaws of Starlink’s network.

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Screenshot of FCC Commissioner Nathan Simington at the Commission's September 2022 open meeting.

WASHINGTON, October 6, 2022 – The Federal Communications Commission’s decision to revoke Starlink’s $885 million award was “arbitrary” and “capricious,” said TechFreedom in comments filed with the commission last week.

Starlink secured the award from the Rural Digital Opportunity Fund in December 2020, but the agency changed course and pulled the plug on the grant last August, claiming the company’s satellite technology is too new and unreliable to meet RDOF’s requirements. Starlink submitted an application for review of the decision in September.

In its filed comments, TechFreedom, a think tank “dedicated to promoting the progress of technology that improves the human condition,” argued that the FCC overstated the flaws of Starlink’s network. Starlink’s growing constellation of satellites – already numbering in the thousands – is “revolutionary,” and network performance will rapidly improve as more satellites are launched, the comments said.

In response to FCC reservations about lagging upload speeds, the TechFreedom argued that Starlink will reach the required service speeds ­in the remaining three years before the Commission’s official deadline.

“How can the FCC pull all funding for Starlink based on current speed tests for a system that is not yet fully built, and for which deployment, speed, and latency milestones don’t apply for several more years,” the think tank wrote.

TechFreedom also argued that Starlink’s is the only technology able to reach some of the hardest-to-serve areas in America: “When the dust settles on this round of broadband deployment in a few years, and the new maps still show many Americans with no access to high-speed broadband, there will be no one to blame but this Commission.”

Viasat, the Ensuring RDOF Integrity Coalition, and ADTRAN each submitted letters hostile to Starlink’s appeal. The three criticized the at-times heavy redactions in Starlink’s application for review.

“The Commission should not allow Starlink to use redactions as a shield to prevent the public from participating meaningfully in this critical proceeding,” ADTRAN wrote.

Starlink did not respond to a request for comment.

In addition, Viasat’s submission rejects the notion that Starlink will eventually meet the required performance standards: “SpaceX also was fully aware of the substantial evidence that Starlink could not meet these performance obligations—evidence that has only continued to mount in the public record since SpaceX filed its long-form application and that SpaceX has consistently refused to refute.”

Among other evidence, Viasat pointed to a recent Ookla study that showed significant drop-offs in Starlink’s median download and upload speeds relative to the previous quarter.

The FCC’s internal dissent

The revocation of Starlink’s grant was met with significant pushback from inside the Commission as well. In August, Commissioner Brendan Carr blasted the decision, saying, “The FCC’s decision offers no reasoned basis for determining that Starlink was incapable of meeting its regulatory obligations.”

Commissioner Nathan Simington outright endorsed Starlink’s challenge. “I am troubled that the decision to rescind SpaceX’s RDOF award applied standards that were not in our RDOF rules, were never approved by the Commission, and in fact made their first appearance in this drastic action,” he said.

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Satellite

As LEO Industry Grows, FCC Adopts Rule to Limit Space Debris

The vote on space debris comes as an increasing number of LEO satellites are gearing up for launch.

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Illustration of simulation of communications from Globalstar LEO network used with permission

WASHINGTON, September 29, 2022 – The Federal Communications Commission on Thursday unanimously adopted an order that requires operators of low-Earth orbit satellites to dispose of their spacecraft within five years of mission completion.

The new “five-year rule” applies to all low-Earth orbit satellites that are planned to be disposed of via uncontrolled reentry into the Earth’s atmosphere. It replaces a non–legally binding recommendation that LEO satellites be removed within 25 years. The adopted order follows the commission’s 2020 further notice of proposed rulemaking that sought comment on the 25-year benchmark.

The commission said it hopes the five-year rule will limit the amount of debris in space. “We recognize the merits of shortening the 25-year period and agree with commenters who argue that a shorter benchmark would promote a safer orbital debris environment,” the order said.

FCC Chairwoman Jessica Rosenworcel argued the order would remove an impediment to innovation. “Right now there are thousands of metric tons of orbital debris in the air above—and it is going to grow,” her statement read. “We need to address it. Because if we don’t, this space junk could constrain new opportunities.”

“Our space economy is moving fast,” she added. “The second space age is here. For it to continue to grow, we need to do more to clean up after ourselves so space innovation can continue to respond.”

An FCC press release following the order’s adoption on Thursday noted, “There are more than 4,800 satellites operating in orbit as of the end of last year, and the vast majority of those are commercial low-Earth orbit (LEO) satellites.” According to that release: “The satellite and launch industry is now an estimated $279 billion-a-year sector.”

LEO satellites are a relatively new source of broadband connectivity. Amazon’s Project Kuiper plans to launch a “constellation” of 3,236 low-Earth orbit satellites the company says will bring broadband service to unserved and underserved areas. Last Spring, Amazon announced it agreements with Arianespace, Blue Origin, and United Launch Alliance for 83 launches.

The FCC approved Kuiper’s constellation application in 2020. Last year, the commission approved Boeing’s proposed constellation of LEO satellites for connectivity. Other companies such as OneWeb and ATS SpaceMobile have also been active in the LEO space.

SpaceX’s Starlink program, the most high-profile satellite player, recently lost a $885.5 million grant from the FCC’s Rural Digital Opportunity Fund in August – a decision panned by Commissioner Brendan Carr. Starlink appealed the setback earlier this month.

Other measures adopted at Thursday’s meeting

At Thursday’s meeting, the FCC also unanimously approved three other measures. The commission adopted an order to improve access to communication services for incarcerated individuals with disabilities, an order that will improve the clarity of emergency alerts, and a notice of proposed rulemaking to modernize regulations for television broadcast stations.

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