SpaceX to FCC: Starlink 'not required to show' it meets RDOF speed needs yetSpaceX to FCC: Starlink 'not required to show' it meets RDOF speed needs yet
Viasat urged the FCC to deny Starlink's effort to appeal the commission's rejection of its RDOF awards, noting a 'steep decline' in performance. But Starlink says it will meet speed needs later.
October 10, 2022
SpaceX is continuing to counter claims about Starlink's broadband speed capabilities, as the company pursues an appeal of the FCC's decision to deny its awards through the Rural Digital Opportunity Fund (RDOF). Viasat, another satellite company that repeatedly lobbied the FCC to reject Starlink's bids, is pushing back against the appeal.
SpaceX filed its appeal – or application for review (AFR) – in September after the FCC rejected the long-form application for Starlink's RDOF awards. The company was initially approved for $885.5 million to cover 642,925 estimated locations in 35 states with low-Earth orbit (LEO) satellite broadband. In rejecting its awards in August, FCC Chairwoman Jessica Rosenworcel said, "We cannot afford to subsidize ventures that are not delivering the promised speeds or are not likely to meet program requirements."
In the publicly available version of SpaceX's AFR, which is heavily redacted, SpaceX's senior director of satellite policy, David Goldman, said the FCC's decision to reject Starlink's bids "rests on unsupported conjecture and outside-the-record information apparently cherry-picked from somewhere on the Internet."
To refute such "cherry-picked" data – specifically, Ookla Q1 speed test data which showed Starlink slowing down – Goldman supplied Starlink's own data (redacted from the filing) in order to show that the service "will easily meet the applicable performance requirements in SpaceX's winning bid areas by the RDOF milestones, starting in 2025."
Figure 2: Example of redacted speed data from Starlink's AFR.
But according to Viasat – which indicated its intention to participate in the proceeding on SpaceX's AFR in a letter to the FCC shortly after the AFR was filed – speed test data for Starlink is only getting worse.
Indeed, in a recent filing, Viasat pointed again to Ookla speed data – this time for Q2 2022 – showing that the service is slowing down, "with median speeds significantly lower than those that Starlink was providing even a few months ago."
As Viasat notes, Ookla's Q2 2022 speed test data showed Starlink users getting median download speeds of 62.53 Mbit/s and median upload speeds of 7.24 Mbit/s.
"Ookla's latest findings reflect a steep decline from Starlink's previously reported speeds—which were already well below the applicable 100/20 Mbit/s requirement for RDOF," said Viasat. "These findings show a quarter-over-quarter decrease in median download speeds of about 31 percent, and a decrease in upload speeds of at least 22 percent."
This confirms that "Starlink is falling further and further behind the RDOF speed requirements—even with no RDOF-based demands on Starlink capacity, and despite ongoing launches of additional Starlink satellites," added Viasat in its filing.
In a response filing posted last week, SpaceX called Viasat's arguments "unavailing" and said that the speed data referenced "lacks any predictive value in assessing whether SpaceX is reasonably capable of meeting its RDOF performance obligations, which would not begin until near the end of 2025, in its winning bid areas."
Furthermore, SpaceX argued, it's not the current network that counts.
"SpaceX is not required to show that its network as currently deployed is capable of meeting its performance obligations in all of its winning bid areas. As the Commission explicitly acknowledged, 'a longform applicant ... may be in the process of constructing its network,'" the company added.
'Hold the line'
The FCC's rejection of Starlink's RDOF bids in August was met with mixed reactions, with fiber broadband advocates celebrating the news while others – including FCC Commissioner Brendan Carr – argued the commission was "rejecting a proven satellite technology" and telling families that "they should just keep waiting on the wrong side of the digital divide even though we have the technology to improve their lives now."
Echoing that sentiment in the company's AFR, SpaceX's Goldman referenced the commission's decision as showing "clear bias towards fiber, rather than a merits-based decision to actually connect unserved Americans" and said the FCC used "different standards" to evaluate Starlink because it uses satellite technology.
In a recent letter to members, Gary Bolton, CEO of the Fiber Broadband Association – a vocal critic of subsidizing LEO satellite technology – celebrated the FCC's decision and said he expected the commission to ultimately deny Starlink's appeal.
"This decisive action by the FCC provided clarity and a path forward for fiber and closing the digital divide, while returning $885.5M of this precious funding back into the RDOF fund for more appropriate broadband projects," said Bolton. "Starlink is protesting this decision and we are keeping a careful eye on the Starlink Application for Review, but we are confident that the FCC will hold the line."
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