FCC Satellite Snub is Just a Stumbling Block to Elon Musk’ Low Earth Orbit Domination

Dayton Williams
Brown Technology Review
6 min readJul 27, 2020

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Following the successful launch of the manned Falcon rocket in May, Elon Musk’s SpaceX is leading the new corporate race to space. That success, however, may have been met with a stumbling block regarding SpaceX’s other ambitious orbital project — Starlink. Starlink, currently under construction, is a multi-billion dollar low Earth orbit (LEO) satellite constellation composed of several hundred school lunch tray-shaped satellites. These satellites and their transceivers may be able to help close the rural-urban internet service gap by providing broadband internet services from space.

Despite Starlink’s enormous potential to increase broadband connectivity, SpaceX has been denied an opportunity to compete in the Federal Communication Commissions’ (FCC) Rural Digital Opportunity Fund, an auction where broadband providers bid on census areas to provide broadband to 14.5 million underserved Americans, in exchange for subsidy dollars. Even with the recent FCC authorization of 4,425 satellites and Musk’s ambitious plans to “serve [those] least served,” the constellation of satellites is not yet advanced enough to meet technical requirements for those lucrative subsidies from the FCC’s Rural Digital Opportunity Fund. The Starlink satellites constellation is an ambitious approach to broadband internet, but the technology is not seasoned enough in the Commission’s eyes to qualify for the FCC’s auction.

Satellite internet provides a stable connection to the web by leveraging — you guessed it — satellites. These satellites interface with various ground stations on Earth that relay data up to the satellites with radio waves, which are then broadcast back to Earn by a subscriber’s personal dish antenna. Historically, satellite internet has relied on the use of satellites in geostationary orbit (GEO), where the satellite is around 35,000 km from Earth and follows the Earth’s rotation over a specific place on the planet’s surface. The vast distance of the GEO satellites from Earth slows transmission and makes them ill-suited to provide high speed internet for modern consumers. This is where Starlink comes in. Instead of a dozen large satellites that are 35,000 km away from Earth locked to a specific location, Starlink’s constellation will be composed of hundreds of smaller low Earth orbit (LEO) satellites only 300km to 1300km from the surface. The LEO satellites can then whiz around the planet and share the responsibilities of an internet connection by hot potato-ing that connection to the closest available satellite right to the subscriber. Because high-speed internet services typically require laying fiber optic cables into the ground or erecting telephone wires, a LEO satellite constellation can leapfrog the infrastructural requirements which are costly to produce at scale in order to serve large rural areas and provide service directly to consumers. The FCC’s Rural Digital Opportunity Fund, in SpaceX’s view, can help to fund the initial investment of launching satellites, move into the broadband market for an untapped consumer base, and add more legitimacy to SpaceX’s already sterling reputation.

But unfortunately for Musk and Starlink, the LEO constellation fails to meet the FCC’s latency threshold of 100ms that the Rural Digital Opportunity Fund requires for its applicants. Latency is the measurement of time in milliseconds between data transmission; the lower the latency the better. An internet connection with a latency of over 100ms that is streaming Netflix will experience frequent content buffering and diminished picture quality. Starlink, as groundbreaking as it is in its planned scale and execution, does not yet have enough satellites in orbit to provide the high speed services that its founder has promised in time for the FCC’s application deadline. Broadband industry groups have expressed their doubts about Starlink meeting the latency requirements as well. Conexon, a consulting service for rural broadband co-ops commented in a recent FCC public notice that “[e]ven if SpaceX dramatically increases the pace of its launches and deploys 10,000 satellites by the first [interim service] milestone…SpaceX will not have sufficient capacity to provide Gigabit service throughout rural America.” Similarly, the WTA, an advocate for rural broadband, expressed doubt that the new Starlink technology’s readiness by the application date is “unduly optimistic and impossible to achieve.”

One of the core operating assumptions in the success of Starlink’s LEO constellation is the leveraging of a lot of satellites. And SpaceX has simply not deployed enough to meet the latency requirement for the Rural Digital Opportunity Fund. Elon Musk himself has said that 800 satellites over a specific geographic area would provide “moderate coverage.” Today, the constellation only contains around 540 — not enough to provide high-speed connection. Starlink broadband services are not even being offered commercially yet with beta testing beginning this summer, which is a testament to how the technology has not quite proven itself in the eyes of the FCC. This is in contrast to the other broadband providers competing in the Rural Digital Opportunity Fund, who have longer track records providing services with established technologies. Another important aspect of the Rural Digital Opportunity Fund is that it is, in fact, technology neutral. Starlink would not be competing just against other satellite broadband providers but DSL and fiber-optics providers too. In this way, more tested and traditional technologies have an advantage in meeting the requirements set out by the FCC. The Rural Digital Opportunity Fund in its design is implicitly biased towards DLS and fiber-optic broadband as these technologies require upfront investment for a specific area whereas LEO satellites require upfront investment but can be used anywhere. From the FCC’s perspective, there is a risk in providing subsidy dollars to SpaceX without a reliable expectation of the return on investment. As understandable as the FCC’s concerns are in investing in a technology not yet perfected at scale, the Commission should also caution itself on dissuading innovation in the information and communications technology sector. Creative innovations in broadband like Starlink’s LEO satellite constellation are exactly the kind of outside the box thinking that needs the competitive edge of government subsidies to be viable. Therefore, The Rural Digital Opportunity Fund’s technology-neutral bidding and technical requirements may in this way serve as a barrier to new innovative broadband approaches from entering the auction.

Even though SpaceX’s Starlink may miss out on Federal funding from the FCC, Elon Musk’s aspirations for his constellation seem to be bigger than just rural America. In 2019, SpaceX submitted paperwork for 30,000 Starlink satellites with the International Telecommunications Union (ITU). Those satellite allotments will likely be filled over the next few years as SpaceX continues to launch over a hundred more satellites in the next year. According to the United Nations Office for Outer Space Affairs, there have been 8,500 satellites, probes, landers, crewed spacecraft, and other flight elements launched into Earth since 1957. If and when SpaceX launches its planned 30,000 Starlink satellites with the ITU in addition to the 12,000 it already has planned through the FCC, SpaceX by itself will be responsible for a fivefold increase in the number of spacecraft launched by all of humanity. It is important to remember that to date Starlink has only deployed around 500 of its LEO satellites, which is a far cry from the 42,000 planned over the next ten years. Elon Musk and SpaceX realize that satellite broadband has the potential for much greater global coverage to reach corners of the world where internet service today is either spotty or nonexistent. Over the next decade, SpaceX will add more and more satellites to Starlink’s constellation, and the latency issue highlighted by the FCC will inevitably drop giving way to a more reliable and higher performing service. Although the FCC has passed on awarding subsidies to SpaceX for their Starlink constellation, the technology will continue to develop, improve, and, if Elon Musk is right, be able to provide high-speed internet to the majority of the world that lacks it.

Published exclusively in Brown Tech Review. Image source.

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