Our Broadband Future Lies Not in Starlink, But in Ourselves

It’s been some time since I last wrote about Starlink. I don’t find the satellite industry terribly interesting. But it’s worth contemplating briefly every so often.

What’s new:

• Last month, the FCC found that Starlink had not demonstrated the ability to satisfy its RDOF obligations to deliver reliable 100 Mbps downstream and 20 Mbps upstream broadband internet access.
• The FCC rejected Starlink’s long-form application for $886 million in subsidies.
• Last week, Starlink sought a review of this decision by the full Commission.

This means:

• The 4-member Commission must vote 3-1 to overturn the decision by the Wireline Competition Bureau.
• Since the Bureau reports to the Chairwoman, one can presume she will not vote to overturn the decision.
• The two Republicans will vote against the Chairwoman.
• The other Democratic Commissioner will support the Chairwoman.
• Having failed to overturn the decision, Starlink will appeal to the DC Circuit Court.

What’s next:

I expect Starlink is hoping to have the whole matter remanded to the FCC by 2025.

• In other words, Starlink’s lawyers will be trying to keep the issue alive until the 2024 presidential election.
• If a Republican wins and names one of the current Republican Commissioners as Chair, there is a chance Starlink will prevail.

The bottom line:

The odds are long, but nearly $1 billion is at stake.

A Starlink Thought Experiment

If you wonder whether the Democratic or Republican Commissioners are correct in their analysis of Starlink, try this thought experiment:

Do you believe Starlink’s service is reliable broadband, defined as 100 Mbps downstream and 20 Mbps upstream?

If you do, then consider Starlink’s claim of coverage.

• Light blue is available now.
• Dark blue is available in 2023.

The Infrastructure Act plainly states the $42.45 billion allocated to the states for broadband may be spent only in areas that lack reliable service of at least 100 Mbps downstream and 20 Mbps upstream.

• NTIA, administrator of the program, has determined that Starlink’s service is not reliable broadband service.
• Why it matters: To determine otherwise would have effectively meant that the Infrastructure Act funding could not be spent anywhere Starlink offers service.

The bigger picture:

If the FCC were to give $886 million to Starlink in subsidies, NTIA will still allocate $42.45 billion to states — which will include money to be spent in Starlink RDOF areas.

• Why it matters: Both Republican and Democratic legislatures and governors and state broadband offices will spend public funds where Starlink provides service.
• If a future FCC were to release $886 million to Starlink, that would be money spent in the same places as BEAD funding.
• If the federal or state governments believe that Starlink does provide reliable broadband service, then that means the BEAD funding should not be spent.

So, Can Starlink Cover Rural America?

Go deeper with another thought experiment:

SpaceX has launched 3,000 Starlink satellites to date and plans to launch 10,000 or maybe 40,000 or maybe some other astronomical number. We don’t know because they don’t know.

Let’s assume:

1. SpaceX dramatically increases the pace of launches and deploys 10,000 satellites while the BEAD program is developed.

2. Each satellite can do 20 Gbps. (20 1-Gigabit beams would be a feat, but let’s give them the benefit of the doubt.)

By the numbers:

• Using some napkin math, the earth is 197 million square miles, of which less than 4 million square miles is the U.S.
• So, only 2 percent of satellites are over the U.S. at a given time.
• That would mean 4 Tbps combined for the entire country.
• Let’s say Starlink served only rural America, or 24 million homes.
• That would mean only 160 kbps per home.
• To meet the required 100 Mbps, it works out to an oversubscription ratio of 600 to 1.
• Even this is a stretch because it assumes that demand is spread out evenly.
• In reality, people live in clusters, so in each rural area you will have amore houses competing for the same few satellites overhead, and oversubscription could be closer to 2,000 to 1.

The bottom line:

Starlink cannot serve all of rural America, nor can it serve all of the RDOF locations or BEAD-eligible locations.

• RDOF, ARPA and BEAD are infrastructure programs, which are ill-suited for satellite infrastructure.
• Other universal service programs like Lifeline and the Affordable Connectivity Program are portable subsidy programs. They are available to Starlink, but Starlink has chosen not to participate.
• Universal service programs, such as RDOF, have never been vehicles for the FCC to speculate on technological development.

I expect SpaceX would dispute many of my assumptions. SpaceX’s plans are confidential and proprietary, as they should be.

But: They are asking for preferential treatment in getting access to nearly $1 billion of public funds and by so doing, attempting to impact $42.45 billion in funds.

So: I’ll stick with my assumptions until SpaceX makes its assumptions or plans public in something more detailed than a redacted filing with the FCC.

It goes without saying:

I shouldn’t have to point out that the FCC intends these funds to be used for U.S. customers.

Sure, some of the funds sought by SpaceX and Starlink could be spent on CPE in the U.S.

But SpaceX would effectively spend 98 percent of U.S. subsidies on non-U.S. operations.

Final Thoughts

I am biased.

• I think broadband is an essential service.
• I think rural Americans should have access to broadband services comparable to those available in urban and suburban areas.
• I think the way to achieve that is to invest in long-term fiber infrastructure.
• I think it best to invest locally in networks that are constructed, owned, operated and maintained locally, which produces both near-term and long-term jobs.
• I expect RDOF, ARPA, and BEAD to lead to hundreds of thousands of jobs created in rural America, rather than a handful of jobs in California.

Why it matters:

Like electric infrastructure, an investment in a fiber network will last for decades.

By contrast, an investment in a Starlink satellite will last perhaps five to seven years, after which Elon Musk will need more of our money.

The bottom line:

Yes, I occasionally agree with the FCC. I agree with them on their rejection of Starlink subsidies.

Rural America deserves better.