Starlink and RDOF

In August, the FCC denied the SpaceX (Starlink) bid to receive $885 million over ten years through the RDOF subsidy. This is something that Starlink won in a reverse auction in December 2020.

In the press release for the rejection, FCC Chairman Jessica Rosenworcel was quoted as saying, “After careful legal, technical, and policy review, we are rejecting these applications. Consumers deserve reliable and affordable high-speed broadband. We must put scarce universal service dollars to their best possible use as we move into a digital future that demands ever more powerful and faster networks. We cannot afford to subsidize ventures that are not delivering the promised speeds or are not likely to meet program requirements.”

The FCC went on to say in the order that there were several technical reasons for the Starlink rejection. First was that Starlink is a “nascent” technology, and the FCC doubted the company’s ability to deliver broadband to 642,925 locations in the RDOF areas along with serving non-RDOF areas. The FCC also cited the Ookla speed tests that show that Starlink speeds decreased from 2021 into 2022.

Not surprisingly, Starlink appealed the FCC ruling this month. In the Starlink appeal, the company argued, “This decision is so broken that it is hard not to see it as an improper attempt to undo the commission’s earlier decision, made under the previous administration, to permit satellite broadband service providers to participate in the RDOF program. It appears to have been rendered in service to a clear bias towards fiber, rather than a merits-based decision to actually connect unserved Americans”.

Rather than focus on the facts in dispute in the appeal, today’s blog looks at the implications on the broadband industry during the appeal process. Current federal grant rules don’t allow federal subsidies to be given to any area that is slated to get another federal broadband subsidy. This has meant that the RDOF areas have been off-limits to other federal grants since the end of 2020. This has included NTIA grants, USDA ReConnect grants, and others. Federal grant applicants for the last few years have had to carefully avoid the RDOF areas for Starlink and any other unresolved RDOF award areas.

As a reminder, the RDOF areas were assigned by Census block and not in large coherent contiguous areas. The RDOF award areas have often been referred to as Swiss cheese, meaning that Census blocks that were eligible for RDOF were often mixed with nearby ineligible Census blocks. A lot of the Swiss cheese pattern was caused by faulty FCC maps that excluded many rural Census blocks from RDOF that should have been eligible, but for which a telco or somebody else was probably falsely claiming speeds at least 25/3 Mbps.

ISPs that have been contemplating grant applications in the unresolved RDOF areas were relieved when Starlink and other ISPs like LTE Broadband were rejected by the FCC. It’s difficult enough to justify building rural broadband, but it’s even harder when the area to be built is not a neat contiguous study area.

The big question now is what happens with the Starlink areas during an appeal. It seems likely that these areas will go back into the holding tank and remain off-limits to other federal grants. We’re likely going to need a definitive ruling on this from grant agencies like the USDA to verify, but logic would say that these areas still need to be on hold in case Starlink wins the appeal.

Unfortunately, there is no defined timeline for the appeal process. I don’t understand the full range of possibilities of such an appeal. If Starlink loses this appeal at the FCC, can the agency take the appeal on to a court? Perhaps an FCC-savvy lawyer can weigh in on this question in the blog comments. But there is little doubt that an appeal can take some time. And during that time, ISPs operating near the widespread Starlink grant areas are probably still on hold in terms of creating plans for future grants.

The 12 GHz Battle

A big piece of what the FCC does is to weigh competing claims to use spectrum. It seems like there have been non-stop industry fights over the last decade on who gets to use various bands of spectrum. One of the latest fights, which is the continuation of a fight going on since 2018, is for the use of the 12 GHz spectrum.

The big wrestling match is between Starlink’s desire to use the spectrum to communicate with its low-orbit satellites and cellular carriers and WISPs who want to use the spectrum for rural broadband. Starlink uses this spectrum to connect its ground-based terminals to satellites. Wireless carriers argue that the spectrum should also be shared to enhance rural broadband networks.

The 12 GHz band is attractive to Starlink because it contains 500 MHz of contiguous spectrum with 100 MHz channels – a big data pipe for reaching between satellites and earth. The spectrum is attractive to wireless ISPs for these same reasons, along with other characteristics. The 12 GHz spectrum will carry twice as far as the other spectrum in point-to-multipoint broadband networks, meaning it can cover four times the area from a given tower. The spectrum is also clear of any federal or military encumbrance – something that restricts other spectrum like CBRS. The spectrum also is being used for cellular purposes internationally, which makes for an easy path to find the radios and receivers to use it.

In the current fight, Starlink wants exclusive use of the spectrum, while wireless carriers say that both sides can share the spectrum without much interference. These are always the hardest fights for the FCC to figure out because most of the facts presented by both sides are largely theoretical. The only true way to find out about interference is in real-world situations – something that is hard to simulate any other way,

A few wireless ISPs are already using the 12 GHz spectrum. One is Starry, which has recently joined the 12 GHz Coalition, the group lobbying for terrestrial use of the spectrum. This coalition also includes other members like Dish Networks, various WISPs, and the consumer group Public Knowledge. Starry is one of the few wireless ISPs currently using millimeter-wave spectrum for broadband. The company added almost 10,000 customers to its wireless networks in the second quarter and is poised to grow a lot faster. If the FCC opens the 12 GHz spectrum to all terrestrial uses, it seems likely that use of the spectrum would quickly be used in many rural areas.

As seems usual these days, both sides in the spectrum fight say that the other side is wrong about everything they are saying to the FCC. This must drive the engineers at the FCC crazy since they have to wade through the claims made by both sides to get to the truth. The 12 GHz Coalition has engineering studies that show that the spectrum could coexist with satellite usage with a 99.85% assurance of no interference. Starlink, of course, says that engineering study is flawed and that there will be significant interference. Starlink wants no terrestrial use of the spectrum.

On the flip side, the terrestrial ISPs say that the spectrum in dispute is only 3% of the spectrum portfolio available to Starlink, and the company has plenty of bandwidth and is being greedy.

I expect that the real story is somewhere in between the stories told by both sides. It’s these arguments that make me appreciate the FCC technical staff. It seems every spectrum fight has two totally different stories defending why each side should be the one to win use of spectrum.

Satellite Cell Service

T-Mobile and Starlink made a joint announcement recently about an arrangement where Starlink will enable voice and texting capabilities to T-Mobile cellphones by the end of 2023. This is a service that would work with existing cell phones and would supposedly kick in when a phone can’t find a signal from a cell tower. Starlink said the technology would be enabled by new satellites that have significantly larger antennae than the current satellites in the constellation. In the press release, Elon Musk touted this as being able to reach people lost in the wilderness, but the much bigger use will be to fill in cellular coverage in rural areas for T-Mobile.

While the two companies made a big splashy announcement about the arrangement, they are late to the game as other industry players already have similar plans underway.

AST SpaceMobile has been working on deploying satellites aimed specifically at the cellular market. The company plans to launch its first five satellites in 2024. The company’s business plan is to launch fairly large satellites weighing over 3,300 pounds to create a constellation dedicated to cellular coverage. The company has already created partnerships with more than 25 mobile operators around the world, including the giant cellular company Vodaphone.

Lynk is taking a different approach and will launch small satellites around the size of a pizza box. The company has one test satellite in orbit with another schedule this December. The company plans to have 50 satellites in orbit by the end of 2023. Lynk already has 14 commercial agreements in place and will support large corporations and governments as well as mobile providers.

Just yesterday, Apple announced that it will offer a texting service for those lost in the wilderness in a partnership with Globalstar. This service is going to be text only and is going to be exceedingly slow, but it will supposedly work for folks who have the latest iPhone and who also are able to point the phone directly at the satellite. There will be an app that will tell a user where the satellite can be found.

All of these plans raise a lot of questions that we won’t get answered until somebody has a working satellite product. For example, could somebody inside a vehicle connect to a satellite? I have no problem connecting to the Sirius XM satellite service, so this might not be a problem. Will these connections somehow roam and connect back to cellular carriers when the user is in reach of a cell tower? That would be really complicated, and my guess is that this won’t work. Mike Sievert, the CEO of T-Mobile said this project is like putting a cell site in the sky, but much harder – and I believe him. I’ve been trying to picture how the satellites will pick out the right calls because filtering through the many billions of cellphone calls to find the right ones sounds like a huge data processing challenge.

The service would certainly be a boon to somebody lost in the  woods, but this is a much-needed service for a lot of people. My consulting firm does surveys, and it’s not unusual to find rural counties today where 30% or more of homes say they have no cellular coverage at their homes. The national coverage maps of the big cellular companies are a joke in many rural places.

T-Mobile and Starlink said that these connections would be only for voice calls and texting at first but that using cellular data might be on the horizon. That would be a significant accomplishment since a receiver many times larger than a cell phone is needed today to communicate with a satellite.

The real potential for this product is not in the U.S. and Europe where a large percentage of folks can connect today to cellular networks. The real market is the many parts of the world where modern cellular towers are a rarity. Most Americans probably don’t understand or appreciate that there is still a lot of the world where folks are not connected, or perhaps only connected through one universal connection that is shared by a whole community.

FCC Nixes Starlink and LTD Broadband

On August 10, the FCC issued a press release denying the long-form applications of Starlink and LTD Broadband in the RDOF reverse auction. This is big news because these are two of the biggest winners of the reverse auction. LTD Broadband was the largest winner of the auctions at $1.32 billion while Starlink had claimed over $885 million in the auction.

The FCC press release quoted FCC chairman Jessica Rosenworcel asking why the FCC should subsidize Starlink since it’s a “still developing technology” that requires customers to pay for a $600 dish, even with the FCC subsidy. I have to imagine that the FCC was relying, at least in part, on Ookla speed tests that show that Starlink’s performance has been worsening over time as more customers come onto the network. The speed tests also show that Starlink doesn’t meet the 20 Mbps upload speed that Starlink pledged to meet in the auction. We may not know the full reasoning behind the rejection unless the FCC follows this press release with a longer document.

The release says that the FCC rejected LTD Broadband because the agency deemed that the company was not capable of deploying a network of the scope, scale, and size required to satisfy the RDOF buildout requirements. This is not surprising since LTD is a small regional WISP in Minnesota that promised to build a fiber network that would cost many billions of dollars. LTD has already been having problems and had failed to win state approval for Eligible Telecommunications Carrier status in seven of the fifteen states where the company won the RDOF auction. There is also an open proceeding at the Minnesota Public Service Commission asking to revoke the existing ETC status.

These two cancellations of RDOF will have a significant ripple effect through the rest of the carrier world. The areas that were claimed in the RDOF auction have been off-limits for other federal grants like ReConnect. This ruling means that any areas that were claimed by these two companies can now be included in future federal grants.

The other issue caused by RDOF is that the awards were by Census block, and this resulted in award areas that have been described as swiss cheese. This meant that the RDOF awards were not contiguous but were often a scattering of Census blocks mixed in with areas that seemed to be identical but were mysteriously not included in RDOF – fully as a result of faulty FCC maps. This made it nearly impossible in some cases for other ISPs to seek grants for the areas not covered by RDOF since the areas are scattered.

I’m only speculating, but I suspect that the pending BEAD grants have a lot to do with the FCC decision. If the FCC had awarded the RDOF, then folks living in the Starlink areas would have been precluded from getting fiber or other broadband that is faster than Starlink. This was a particularly troublesome situation in my part of the world, where Starlink won the RDOF reverse auction in some of the western mountainous wooded counties in North Carolina. We now have a lot of evidence that Starlink struggles in heavily wooded areas.

The risk of awarding the RDOF to LTD Broadband is that the company would fail to execute on the fiber buildout. It wouldn’t be evident for a number of years if the buildout wasn’t going to succeed, and by that time, all of the current state and federal broadband grants would be long gone. I think this rejection shows that the federal government is really hoping that the BEAD grants will bring broadband to all rural areas.

There are still a few other large RDOF winners that have not been awarded. These are companies that are proposing gigabit wireless capability. The FCC is obviously not yet ready to make the awards to these companies, but it’s also apparently not ready to reject them. The clock is ticking for these areas. ISPs and local governments need to know if these areas won’t get RDOF since it takes time to plan for the BEAD grants, so it’s important for the FCC to make or reject the remaining RDOF applications soon.

How Fast is Starlink Broadband?

We got a recent analysis of Starlink broadband speeds from Ookla, which gathers huge numbers of speed tests from across the country. The U.S. average download speeds on Starlink have improved over the last year, from an average of 65.72 Mbps in 1Q 2021 to 90.55 Mbps in 1Q 2022. But during that same timeframe, upload speeds got worse, dropping from an average of 16.29 Mbps in 1Q 2021 to 10.70 Mbps in 1Q 2022.

It’s likely that some of this change is intentional since ISPs have a choice for the amount of bandwidth to allocate to download versus upload. It seems likely that overall bandwidth capacity and speeds are increasing due to the continually growing size of the Starlink satellite constellation – now over 2,500. Starlink subscriptions are climbing quickly. The company reported having 145,000 customers at the start of the year and recently announced it is up to 400,000 customers worldwide. This fast growth makes me wonder when Starlink will stop calling the business a beta test.

These speed tests raise a few interesting questions. The first is if these speeds are good enough to qualify Starlink to be awarded the RDOF awards that have now been pending from the FCC for over a year and a half. While these speeds are now approaching the 100 Mbps speed promised by Starlink in its RDOF bids, it’s worth noting that the 90 Mbps number is an average. There are some customers seeing speeds of over 150 Mbps while others are seeing only 50 Mbps or even less. I’ve talked to a number of Starlink customers and what they’ve told me is that Starlink needs a view of the ‘whole sky’ from horizon to horizon to operate optimally, and many homes don’t have the needed view. This doesn’t bode well for the Starlink RDOF awards areas of heavy woods and hills like the awards in western North Carolina.

There is a lot of speculation that Starlink is limiting the number of subscribers in a given geographic area in order to not dilute speed and performance. The RDOF awards require any winning ISP to serve everybody, and there is still a big question about the kinds of speeds that can be delivered for a geographic area that has a lot of subscribers.

The BEAD grant rules also open the door for Starlink and other satellite providers to some extent. While satellite technology is not deemed reliable enough to directly be used for grant awards, the NTIA has also opened the door to using alternate technologies like satellite and fixed wireless using unlicensed spectrum in areas where landline technologies are too costly. Each state will have to decide if grants can be awarded for satellite broadband in such cases, and it seems likely that some states will allow this.

The Ookla article also shows the Starlink average speeds around the globe. Some of the average speeds are much faster than U.S. speeds, and this might be due to smaller countries that cover a smaller and less diverse terrain than the U.S. Here, speeds are likely much higher in the open plains states than for customers located in hills, mountains, and woods. There can’t be a technology difference since the same satellites serve around the globe.

There is an interesting app that shows the location of the Starlink satellites. It’s fascinating to watch how they circle the globe. What is most striking about the world map is how few satellites there are over the U.S. at any given time. The app shows a few closely packed strings of satellites that are recent launches that haven’t yet been deployed to their final orbits.

The skies are going to soon get a lot busier. The original business plan for Starlink was to deploy 11,000 satellites. Jeff Bezos and Project Kuiper have FCC permission to deploy satellites, with launches starting this year. OneWeb, which is now aiming to serve business and government customers, has much of its constellation launched but has yet to begin delivering services. Telesat is still marching slowly forward and has fallen behind due to supply chain issues and funding concerns – but still has plans to have a fleet in place in the next few years. I would imagine that in a few years, we’ll see Ookla reports comparing the different constellations.

Bringing Broadband to the Arctic

The Arctic region has largely been left out of the broadband arena in the past due to the high cost of building last-mile broadband infrastructure. The primary broadband available in the region has been provided for decades by Iridium Communications, which provided only low-bandwidth connections capable of supporting satellite phones and low-bandwidth monitoring devices. The lack of broadband looks to be changing as multiple satellite companies are targeting the region as a good business opportunity.

Starlink and OneWeb already have polar-orbiting satellites that can serve the region. In fact, the original OneWeb business plan focused on the Arctic as its first priority due to the lack of competition.

Telesat has negotiated to connect to indigenous communities in the Arctic through a partnership with the Canadian government. The government has already provided some grants and last year announced a financing deal that will invest $690 million in preferred equity and $790 million in loans to enable Telesat Lightspeed to complete its low-orbit satellite constellation. The government will also receive warrants that can be exchanged in the future for additional shares of Telesat stock. This adds to the $400 million provided by the government of Quebec. The low-orbit constellation will begin with 298 satellites positioned to deliver speeds up to a gigabit across Canada.

SES plans to serve the Arctic with a fleet of medium-earth-orbit satellites that should start launching by the end of the year. MEO satellites deploy in orbits higher than 1,200 miles but closer than the geostationary satellites at 22,000 miles above the earth. The biggest challenge for these satellites is finding orbits that avoid the high-energy Van Allen radiation belts. The SES business plan is to provide high-bandwidth connections to remote places and in addition to the Arctic, will be pursuing broadband for cruise ships, cellular towers, and government networks.

The Arctic Satellite Broadband Mission (ASBM) is being built by Northop Grumman and is a joint venture between Inmarsat, the British satellite operator, the Norwegian Ministry of Defense, and the U.S. Air Force. These satellites are aimed at providing cellular telephone service and also supporting the military. Two satellites are scheduled to launch by the end of this year and will have highly elliptical orbits that will vary between 5,000 and 27,000 miles above the earth. The orbits can be changed to avoid radiation storms.

The Russian Satellite Communications Company (RSCC) announced plans to launch four satellites in highly elliptical paths within a few years to serve the far north polar regions. I have to wonder if these plans are on hold due to the severe economic sanctions in place against the country.

Satellite broadband is an awesome solution for places where there are likely to be no alternatives. I understand why rural residents of the U.S. are flocking to Starlink since, for many of them, it’s the only workable broadband solution on the horizon. I continue to wonder how satellite broadband will stay competitive in the lower forty-eight after the many grant-funded networks are finally built. But there will always be homes in the U.S. out of reach of landline networks or customers that don’t like the landline ISPs, so it would not be surprising to see the satellite companies with a small but steady customer base south of the Arctic for the long-haul.

But satellite broadband ought to dominate the Arctic for decades to come. It can bring decent bandwidth to remote places that may never be candidates for building landline networks. It will be an interesting change for the area as it goes from barely connected to fully connected.

Can Satellite Broadband be Affordable?

When we first heard of the possibility of broadband from low-orbit satellites, there was a lot of speculation that the technology could bring affordable broadband to the masses around the globe. The latest announcement from Starlink shows that affordable broadband is probably not coming in the immediate future.

Starlink announced a premium tier of service with a $500 monthly fee for 150-500 Mbps. The receiver has a one-time cost of $2,500. The product offers faster speeds by doubling the size of the receiving area of the receiver. These prices are a big step up from the current Starlink broadband product that offers 50-150 Mbps service for $99 per month with a $500 fee for the receiver.

I’ve been thinking about the issues faced by a satellite constellation owner in trying to recover the cost of the network to make a profit. At current costs, it’s incredibly expensive to launch Starlink satellites. It’s rumored that it currently costs about $60 million for one launch that can place 49 satellites into orbit. That’s a cost of over $1.2 million per satellite before considering the cost of the satellite hardware. But this cost is supposed to be dropping due to the ability to reuse rocket components, with near-future costs soon to be around $30 million per launch. That would still mean a cost per satellite of $600,000 each. Elon Musk says his goal is to get the cost per launch down to $10 million, and that would still mean a launch cost per satellite of over $200,000.

These costs wouldn’t be bad if the satellites had some longevity, but it’s estimated that low-orbit satellites will remain in orbit from 5-7 years, meaning a satellite owner must recover its launch costs in a relatively short period of time.

This is not to say that Starlink can’t make money, and I have to assume that the current prices are set so that the company can become profitable. But it’s hard to imagine lowering prices until a satellite company has a large enough customer base to cover operating costs and the continued cost of replacing satellites.

Starlink also admits that it is subsidizing the home receivers it sells for $500. But with mass production, that cost is likely to plummet. But for now, it’s one more financial hurdle to overcome.

The other component of cost to consider is the cost of backhaul. In the U.S., it will be easy for Starlink to build a series of earth stations that can download and upload data with the satellite constellation. We have fiber backhaul routes crisscrossing the country, and there are numerous carriers willing to negotiate good prices with Starlink for connecting earth stations to the Internet.

But this is not going to be so in much of the rest of the planet. Consider places like inland Africa where there are far fewer fiber middle-mile routes, and where the amount of bandwidth is limited and expensive. Lack of backhaul could make it a challenge to operate in markets like Africa.

There are also countries that will block Starlink or that might impose big license fees to deliver the broadband. China is unlikely to allow broadband connections that bypass the Great Firewall of China. India is discussing license fees with Starlink, and could make it expensive to do business there. Those two countries alone contain 36% of the world’s population.

The last complexity faced by any satellite broadband company will be competition from other satellite owners. It’s likely that within five years that we’ll see worldwide coverage from Starlink, OneWeb, and Project Kuiper – and other companies and countries are considering satellite constellations. The industry math will quickly get challenging if there is any downward pressure on prices through competition. Starlink is only going to be able to sell $500 premium connections if no other satellite company offers something less expensive.

Elon Musk has said many times in the last year that there is no guarantee of financial success at Starlink and that the company could easily go bankrupt. The company must be losing money during this early beta stage, but that’s experienced by all new ISPs. Let’s also not forget the stated original reason for funding Starlink. The goal was to create a cash cow that would spin off the funding needed to settle Mars. The need to generate cash isn’t going to tempt the company to have affordable rates. There is a lot of moving parts to operate a satellite business, with many of the long-term costs still unknowable. It will be interesting watching the satellite companies figure out the business on the fly.

Is Space Getting Too Busy?

Satellite broadband made the news again recently when the Chinese government said it had to adjust the orbits of the Chinese space station to avoid collisions with Starlink satellites. China claims it had to make adjustments in July and October of last year.

The Chinese are not the only ones making this claim. In 2020, the CEO of Rocket Lab said that it is becoming increasingly difficult to plot a clear trajectory when launching a rocket. The head of the European space agency recently accused Starlink of “making the rules” for everybody else in the way the company is launching satellites. The recent reaction by Elon Musk to these criticisms is that space is huge and can accommodate tens of billions of satellites.

What seems to be in play here is that there are no international regulations in place to define parameters for space launches. The last international treaty on space is over fifty years old and never envisioned the huge number of satellites we’re already starting to see. Starlink alone already has over 1,700 satellites and plans to launch new satellites twice per month throughout 2022. One earlier Starlink business plan called for over 30,000 satellites.

There have already been a few notable collisions between satellites. The most recent was when the Yunhai-1 Chinese satellite was apparently destroyed in March 2021 from pieces of debris from a Russian Satellite. There is a huge amount of space debris. There are over a million pieces of debris between 1 and 10 centimeters (4 inches) in size. The U.S. Space Surveillance Network was actively tracking 15,000 objects larger than 4 centimeters as of November 2021.

Debris matters because orbiting objects are moving fast – at 150 miles above the earth, a satellite needs to be going 17,500 miles per hour to maintain orbit. A collision with even a small object can be devastating.

Scientists have been warning about space debris for a long time. In 1978, NASA scientist Donald Kessler warned that collisions in space could result in a cloud of debris that would create an effective barrier to launching rockets or sending people into space.

This is no longer a theoretical problem since much of what we do on earth is now reliant on satellites. Most of our cable TV signals are launched from space. GPS relies on a series of satellites. Ships and airplanes navigate with support from satellites. Satellites are used to track weather patterns. There are now satellites tracking and monitoring everything from the movement of foreign armies to the water temperature of the oceans.  There will soon be millions of broadband customers using low-orbit satellites.

It’s hard for any layman to understand the real risks. Some of the controversy likely stems from international wrangling between nations. But there are also a lot of notable scientists that are worried that we might make space unusable.

It will be ironic if the world solves rural broadband with satellites only to find one day that there is too much debris to launch more satellites. It seems like a remote possibility, but some scientists say it’s possible. It makes sense for the international community to come together and work out rules that everybody can agree to.

FCC – Please Do the Right Thing with RDOF

The $42.5 federal BEAD broadband grants that are being funded from the Infrastructure Investment and Jobs Act should be a gamechanger for rural broadband. There will be many hundreds of millions of grants given to each state to fund the construction of broadband networks. This is likely once-in-a-generation funding, so there will only be one chance to do this right.

There is one pending issue that could really gum up the BEAD grants – there are pending RDOF awards that should not be funded. These pending RDOF grants fall into three categories.

First are RDOF auction winners that have probably bitten off more than they can chew. An example of this might be LTD Broadband. I don’t have any inside knowledge of the company, but I’ve seen estimates that the company would need to raise something north of $7 billion dollars to go along with the $1 billion RDOF award. There are likely other similar companies in the auction. The FCC has had almost a year to determine the financial ability of grant winners to fund the rest of the projects they won. If these companies don’t have the needed funding, it’s time for the FCC to cut them loose. This shouldn’t be a hard determination.

The second category is unique. Starlink won nearly a billion dollars of RDOF funding. There are still a lot of unknowns about the company’s capabilities. I know some of the RDOF areas won by Starlink are heavily wooded, and from what I hear, that’s a big problem for the technology. There are also still questions about the ability of Starlink to serve every home in a grant area – which is what the RDOF requires. I have nothing against Starlink, and if I lived in a rural area, I would have been first in line for the beta test. But the company is still an unproven technology in terms of being able to serve everybody. The company is still a start-up with no guarantee of success or longevity. At the end of the day, Starlink doesn’t meet the basic requirement that federal funding should only go to companies that can guarantee to meet the requirements of the award.

Finally, are the RDOF auction winners that claim to be able to deliver gigabit wireless technology. Like Starlink, these are not field-proven technologies and likely will never deliver what is being promised. Over the last year, I haven’t talked to a single engineer who thinks it’s possible to deliver a wireless gigabit to every customer in rural Census blocks with gigabit wireless. I have no doubt that the new wireless technologies have the capability of being a lot faster than current fixed wireless technology. But these grants weren’t awarded to deliver a few hundred megabits per second. These grant winner should be tossed for overclaiming the technology, since doing so gave them an unfair advantage in the auction. If they had bid with the ability to deliver 200 Mbps the auction results would have been very different. These companies gamed the auction rules and that alone should have invalidated the awards. Unfortunately, the FCC might be ready to make these awards, having recently awarded funding to Resound Networks to provide gigabit wireless broadband.

It’s obvious that the FCC is already wrestling with all of these issues because it’s been eleven months since the RDOF winners filed their long-form information. But the FCC must know that the BEAD grants change everything. If it had known that BEAD grants were coming, the FCC probably would not have held the reverse auction. This new federal grant money changes the equation and brings a new paradigm that should make it easier for the FCC to make up its mind about questionable RDOF awards.

If the FCC gets this wrong, then the RDOF areas in question won’t be seeing the same broadband solutions that are coming everywhere else. The BEAD grants make it easy for the FCC to reject applicants that have not demonstrated the financial wherewithal to fund the promised RDOF solution. The BEAD grants should make it easy to reject Starlink – the company is still free to market broadband to all of rural America, and it already has a huge waiting list of people willing to buy service. The BEAD grants should make it easier for the FCC to admit it erred in letting bidders overclaim technology.

It’s not going to be easy for the FCC to publicly admit that it made some big mistakes in the RDOF auction. Most of these issues could have been avoided if the FCC had pre-screened applicants. Any technology that was not already proven to work in the real world should have been excluded from the auction. Applicants should have been given a dollar limit for participation in the auction based on their balance sheet. But the FCC has a chance to set this right by rejecting the questionable awards and letting the folks that live in these areas have a chance for a better and more permanent broadband solution through BEAD grants. FCC – please do the right thing.

The Fight Over 12 GHz Spectrum

For an agency that has tried to wash its hands from regulating broadband, the FCC finds itself again trying to decide an issue that is all about broadband. There is a heavyweight battle going on at the FCC over how to use 12 GHz spectrum, and while this may seem like a spectrum issue, it’s all about broadband.

12 GHz spectrum is key to several broadband technologies. First, this is the spectrum that is best suited for transmitting data between the earth and satellite constellations. The only way Starlink is going to be able to grow to serve millions of remote customers in the U.S. is by having enough backhaul to fuel the huge amounts of data that will be passed to serve that many customers. Lack of backhaul bandwidth will significantly limit the total number of customers that can be served and is an obvious major concern of the satellite companies.

It turns out that 12 GHz is also the best spectrum for transmitting large amounts of data with 5G. The carriers have been dabbling with the higher millimeter-wave spectrum, but it’s turning out that there are squirrelly aspects of millimeter-wave spectrum that make it less than ideal in real-world wireless deployments. The 12 GHz spectrum might be the best hope for carriers to be able to deliver gigabit+ wireless drops to homes. Verizon has been deploying fiber-to-the-curb technology using mid-range spectrum and seeing speeds in the range of 300 Mbps. Using the 12 GHz spectrum could provide a reliable path to multi-gigabit wireless drops.

The big question facing the FCC is if 12 GHz can somehow be used to satisfy both needs, pitting the 5G carriers against the satellite carriers. As an aside, before talking more about the issue, I must observe that the satellite companies bring a new tone into FCC proceedings. Their FCC filings do everything except call the other side a bunch of dirty scoundrels. Probably only those who read a lot of FCC documents would notice this, but it’s something new and refreshing.

The current argument before the FCC comes from filings between Starlink and RS Access, which is associated with Michael Dell, who owns a lot of the spectrum in question. But this is part of the larger ongoing battle, and there have been skirmishes that also involved Dish Networks, which is the largest owner of this spectrum.

The FCC will have to somehow untie the Gordian knot on a tough issue. As is to be expected with any use of spectrum, interference is always a major concern. The usefulness of any band of spectrum can be negated by interference, so carriers only want to deploy wireless technologies that have minimal and controllable interference issues. Both sides in the 12 GHz fight have trotted out wireless engineers who support their positions. RS Access says that spectrum can be shared between satellite and terrestrial usage, supporting the idea of not giving more spectrum solely to Starlink. Starlink says the RS Access engineers are lying and wants dedicated spectrum for satellite backhaul. I don’t know how the FCC can sort this out because the only way to really know if spectrum can be shared is to try it.

What I find most unusual about the fight is that the FCC is being dragged into a broadband issue. The last FCC Commission, Ajit Pai, did his best to wash broadband out of the vocabulary at the FCC. But in today’s world, almost everything the FCC does, other than perhaps chasing robocallers, is ultimately about broadband. While this current 12 GHz fight might look like a spectrum battle to an outsider, it’s all about broadband.