More broadband-industry groups are lining up against SpaceX’s bid to get nearly $900 million in Federal Communications Commission funding. Two groups representing fiber and rural Internet providers yesterday submitted a report to the FCC claiming that Starlink will hit a capacity shortfall in 2028, when the satellite service may be required to hit a major FCC deployment deadline.
The study was commissioned by the Fiber Broadband Association (FBA) and NTCA-The Rural Broadband Association. They are urging the FCC to carefully examine whether SpaceX’s Starlink broadband service should receive money from the Rural Digital Opportunity Fund (RDOF), which recently awarded SpaceX $885.51 million over 10 years to bring Starlink to 642,925 homes and businesses in 35 states. The funding for SpaceX and other ISPs won’t be finalized until the FCC reviews their long-form applications, which were submitted after the reverse auction.
In a filing accompanying the study they commissioned, the FBA and NTCA told the FCC:
The Commission faces a daunting but essential task in ensuring that winning bidders can meet their public interest obligations and not strand these unserved consumers. And, the stakes become greater when a bidder won the rights to serve hundreds of thousands of unserved locations and intends to use technologies and network infrastructure not yet proven in the market—especially when it may not be discerned for years to come whether those technologies will evolve to the point where they can in fact satisfy the bidder’s RDOF commitments.
One such winning bidder is SpaceX… which has not yet deployed its full constellation of satellites and ground stations and has just begun to offer commercial service. The general public and communications engineers alike, including at FBA and NTCA member companies, often marvel at SpaceX’s plans and efforts; yet, those with engineering experience know there is often a large gap between theoretical and actual network performance.
The FCC won’t necessarily accept the groups’ claims. Forecasting a capacity shortfall seven years in advance is tricky, and the groups who commissioned the study have a vested interest in preventing SpaceX from getting funding. Money that isn’t distributed to SpaceX could be given to other ISPs. SpaceX’s haul of $885.51 million is a large chunk of the $9.2 billion awarded to 180 entities nationwide to expand networks to 5.2 million homes and businesses.
We contacted SpaceX today and will update this article if we get a response.
NTCA represents 850 small telcos while the FBA represents a mix of ISPs, municipalities, and vendors that sell equipment and services to ISPs. The FBA and NTCA filing comes days after lobby groups for electric co-ops that provide broadband told the FCC that SpaceX’s low Earth orbit (LEO) satellite technology is experimental and unproven, and it shouldn’t get funding. The electric co-op groups also raised concerns about fixed-wireless services that are slated to receive FCC funding.
Predicting a capacity crunch
If its funding gets final approval, SpaceX will have to provide 100Mbps download and 20Mbps upload speeds to 642,925 locations to meet its commitment to the FCC. The FBA and NTCA hired consulting firm Cartesian to analyze whether SpaceX can get it done. Conducting the analysis is “no small task given that: (a) SpaceX has provided limited information publicly about its network and the performance capabilities; (b) SpaceX’s network plans and performance capabilities continue to shift; and (c) actions by the Commission in pending and future proceedings may cause SpaceX’s plans to change further,” the groups said.
The results are “based upon the best information publicly available and conservative assumptions with respect to factors such as demand,” but the FBA and NTCA acknowledged that “information furnished confidentially by SpaceX through the long-form process may provide additional inputs and yield different results.” With those caveats, Cartesian’s report predicts that in 2028, 56 percent of subscribers in SpaceX’s FCC-funded areas would “experience service degradation” due to congestion. Cartesian chose 2028 because that’s when a six-year deadline to deploy all required broadband is likely to pass.
“More locations will be impacted if RDOF usage is higher, or SpaceX launches fewer satellites by 2028,” the report continued. “RDOF service could be significantly worse if Starlink capacity is allocated to non-RDOF use cases.” Cartesian said its “model assumes Starlink is able to meet its goal of 12,000 satellites before the mandated RDOF completion date” and that the “throughput capacity of a single satellite is set at 20Gbps per previous SpaceX public statements.”
To predict the capacity required per subscriber, Cartesian said it drew from “current estimates of average bandwidth usage per subscriber, during peak hours, range from 1.7 to 2.7Mbps.” It raised those estimates of peak-hours usage “to establish a minimum capacity required of 3.6Mbps per subscriber to provide 25 percent headroom at highest peak usage.”
Cartesian further tried to account for future growth in bandwidth demand from sources such as 4K streaming video. By 2028, Cartesian estimated that SpaceX will need to provide 15.3 to 20.8Mbps per subscriber to meet its obligations. This is lower than the 100Mbps required download speeds because scenarios in which every broadband subscriber uses every available bit are not realistic. Not all subscribers actively use the Internet during peak hours, either. Cartesian said that previous FCC “testing requirements have imposed an 80/80 threshold, meaning 80 percent of testing locations must equal or exceed speed tests of 80Mbps.”
“We modeled Starlink’s best possible share of subscribers fully served under the low case and high case capacity requirements of 15.3 and 20.8Mbps respectively—customers receiving less will experience service degradation,” the report said. At 15.3Mbps in 2028, 56 percent of subscribers would be under the threshold; at 20.8Mbps in 2028, 57 percent of subscribers would be under the threshold, the report said.
“The median capacity allocation is 14.7-17.1Mbps, and 25-29 percent of subscribers [would] receive less than 10Mbps during peak times,” Cartesian wrote.
Fiber is better—but not available to many
The FCC will examine SpaceX’s technical claims before approving the money, but Starlink may in fact be the best option for numerous Americans who live in broadband deserts. Fiber-to-the-home is obviously today’s gold standard for broadband, providing the fastest speeds, uploads that are as fast as downloads, and excellent reliability. But incumbent ISPs haven’t extended fiber-to-the-home to huge portions of the United States, especially in rural America and even in many urban and suburban areas.
If Starlink can handle the 5 million users that SpaceX is planning for in the US, it could be a huge upgrade in cities and towns where wireline ISPs failed to upgrade old DSL networks. (Customers who at least have cable-broadband access aren’t as likely to need something like Starlink, though cable does lag far behind fiber on upload speeds.)
While SpaceX hasn’t responded to the FBA/NTCA study, the company touted Starlink’s progress last week in a petition to the FCC seeking designation as an Eligible Telecommunications Carrier, saying that “Starlink’s performance is not theoretical or experimental.” The Starlink beta already serving 10,000 users in the US and abroad demonstrates “technical maturity and inherent capacity to support high-throughput, low-latency broadband service to unserved or underserved communities in even the most remote and rural areas of the United States,” the filing said.
“Starlink continues to improve as SpaceX deploys additional infrastructure and capability, averaging two Starlink launches per month, to add significant on-orbit capacity alongside activation of additional gateways to improve performance and expand service coverage areas across the country,” SpaceX said.
While incumbent ISPs are wary of the new competition from Starlink’s low Earth orbit satellites, traditional wireline telcos are no guarantee to meet FCC deployment requirements. CenturyLink and Frontier recently missed FCC deployment deadlines in dozens of states, and both of them are slated to get more money from the new RDOF program.