Starlink U.S. Download Speeds Misused By FCC For $885 Million Bid Rejection Says SpaceX

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After the Federal Communications Commission (FCC) rejected its $885 million award to provide internet coverage to rural areas, Space Exploration Technologies Corporation (SpaceX) appealed the decision late Friday afternoon. In the application, SpaceX points out that the Commission’s Wireline Competition Bureau ignored facts and relied on incorrect internet speed tests to determine the merits of the Starlink application. He argues that the decision should be reversed because not only does SpaceX have sufficient funds to cover rural areas, but the Internet speed tests used by the Bureau are not representative of the true performance of Starlink which will cover areas from 2025. .

SpaceX cites $125 billion market valuation and redacted information to bolster its case for rural internet coverage

SpaceX’s request covers several areas that the company says have not been sufficiently analyzed to withdraw the $885 million in funds. It begins by stating that not only was the awarding body’s decision to use internet speed test provider Ookla’s tests incorrect, but that the Bureau also used those tests to evaluate Starlink without informing SpaceX.

Ookla’s speed tests showed that despite constantly launching satellites, Starlink’s speeds plummeted in the US – a fact that’s also confirmed by several reports from disappointed users on social media. Its latest report, released in June and covering data for the first quarter of this year, pointed out that while Starlink continued to outperform high-speed internet by a wide margin globally, median speeds in the United States had fallen.

In its appeal request, SpaceX claims that Ookla used this data incorrectly – and without informing SpaceX – to disqualify it for the rural broadband subsidy. He goes on to say that this data is not representative of the performance Starlink will achieve in 2025. The company then shares redacted figures on the percentage of capacity used to serve rural areas and conservative estimates of data usage in times of crisis. peak and annual growth in peak usage. to declare that it is well equipped to provide service to rural users in accordance with FCC requirements.

Some of the redacted details SpaceX shared with the Commission, arguing that the decision to withdraw RDOF subsidies is inappropriate. Image: File No. 0009395128/FCC File 09-197

SpaceX’s head of satellite policy, Mr. David Goldman, takes issue with the decision to use Ookla’s data, pointing out that:

Notably, at the time of Ookla’s measurements in the first quarter, SpaceX had launched less than half of the Starlink network’s 4,408 licensed satellites, and some of them were still in orbit and not yet contributing to available capacity. Equally important, Ookla’s data only reflects technologies deployed on existing satellites. [REDACTED]

Second, the Bureau’s decision ignores that SpaceX was not informed that its national speeds in 2021 and 2022 would be used as a proxy to determine its ability to meet the 2025 speed requirements for its RDOF territories. SpaceX did not announce or attempt to offer 100/20 Mbps service during the time Ookla studied network speeds. [REDACTED]

The Bureau’s decision ignored these circumstances without any explanation. Third, the Bureau relied on Ookla’s speed test data for the entire United States, not SpaceX’s winning bid zones. [REDACTED] But SpaceX was not required to take these steps until 2025. For all of these reasons, Ookla’s data has no predictive value in assessing whether SpaceX is reasonably capable of meeting its RDOF performance obligations by 2025. Indeed, the Bureau appears to be penalizing SpaceX for making early broadband service available to underserved Americans ahead of the RDOF deployment stages.

The latest data from Ookla shows that while Starlink download speeds have increased each year, they have fallen sequentially. Image: Ookla

Another reason implicit in the filing appears to include the Bureau’s doubt that SpaceX would be able to meet an aggressive satellite launch cadence to meet the capacity needs of rural areas. However, since this is where most of the writing of the document begins, we cannot determine what doubts have been raised. SpaceX has launched more than 3,000 Starlink satellites to date and plans to launch even more this year as it aims to double its launch rate in 2022 compared to 2021.

The Bureau has also raised doubts about SpaceX’s financial ability to meet its rural broadband application, and on that front the company insists it has ample cash and a large backlog. . Those numbers are also redacted, and SpaceX insists the Bureau “misinterpreted” the total cost of deploying all satellites for rural coverage. He cites depreciation expense as part of the estimate he provided to the agency as being unrelated to actual costs. Depreciation is a non-monetary accounting charge on a company’s assets that reflects their decline in value due to use over time, and is added back as part of financial analysis to determine the feasibility of a project.

SpaceX says the Bureau did not consider future service revenue to offset layout costs. Image: File No. 0009395128/FCC File 09-197

Finally, SpaceX’s final two arguments against the decision indicate that federal broadband programs in the areas it won the tender won’t materialize anytime soon and that it has secured adequate financial support. from an anonymous bank for the project through a letter. credit. He argues that despite the Commission’s requirement that a letter of credit be assessed favorably in an award process, the Bureau refused to consider it – an omission that Mr. Goldman calls “remarkable”. “.

SpaceX is set to launch its next Starlink mission later today in an aggressive launch cadence that has put it on track to launch one mission per week this year. It aims to expand its satellite internet constellation through its Starship rocket by launching a larger second-generation spacecraft capable of communicating with mobile phones in emergencies and for other uses as well, and it is also fighting against efforts to restrict its use of the 12 Ghz spectrum for Starlink satellite terminals.

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