FCC and Starlink guerilla marketing

You never let a serious crisis go to waste. And what I mean by that it's an opportunity to do things you think you could not do before.

Rahm Emanuel



FCC denied SpaceX possibility to bid for low latency tier of Rural Digital Opportunity Fund, effectively putting Starlink into the same basket as other MEO/GEO based broadband providers (Viasat, SES Americom and HughesNet). This is a big deal and a big blow to SpaceX, since the weight associated with latency (40) is almost as significant as providing gigabit capacity (50) above the minimum baseline. 

In essence, this fund has over 20 billion USD that will be allocated to ISPs that can provide broadband Internet in rural areas. Of that amount, 16 billion will be awarded using reverse auctions from October 2020. The auction rules split the bidders into low latency (less than 100 ms round trip) and high latency (less than 750 ms round trip) tiers. Higher latency obviously targets GEO providers like Viasat. And Starlink has been effectively put into the same category as Viasat and Hughes. Since GEO providers will have lower capital expenditure on the space segment (essentially focusing on a single geostationary satellite) and lower number of gateways, they have excellent opportunity to outbid Starlink by carefully selecting focus areas. 



FCC explains in sections 107 and 108 that SpaceX cannot prove Starlink performance. GEO broadband providers have existing networks that can prove their performance. New satellites will not change that significantly, they will just apply frequency reuse on a greater scale. The same rationale holds for terrestrial ISPs. FCC quoted article, arguing that there are other latencies above and beyond pure physical propagation delay. And it is all well and valid for geostationary satellites. But guess what? Cisco has the same problem. Signals require modulation and error correction in fiber optics too. So they have serialization issues. Or TCP or WAN acceleration issues. That is well known problem. Akamai, F5, Cisco, Juniper make billions solving that very problem. And it has nothing to do with space based communications. I know that. I do access sites on the other continents too. Applying this problem as specific for space based connectivity is pure discrimination for a NGSO constellation. 

In the current design without inter-satellite links, SpaceX will have to provide local gateways that will introduce the same latency as for other terrestrial ISPs. But the radio signal has to travel between the ground station and the satellite four times. With average distance of 750 km between these two points, that amounts to 3000 km. It takes radio wave 10 ms to travel that distance. For GEO satellites, it takes 540 ms on average. Standard client PC connected over LAN and optical network can have under 10 ms connectivity to nearest CDN Internet edges. Just try to ping www.gov.cn or www.latimes.com or www.whitehouse.gov. Most of popular sites will have less than 10 ms round trip time. So unless SpaceX really had bad network engineers...you know, from these GEO companies....which managed to add 200 ms delay in addition to the physical limitations. Because, speed of light is even slower in fiber than in space. And still, pinging uncached site on the other side of the world has round trip of 330 ms. To access a site on the other side of the globe. Roughly 40000 km round trip distance. My packets passed through Budapest in Europe. And Frankfurt. And New York. And Seattle. And Osaka. And Hong Kong. Twenty nodes in total. 

So compared to any terrestrial or 4G/5G ISP, SpaceX disadvantage can be at most 10 ms due to physical limitations. And they do need to perform conversions between photons and electrons as signal carriers at least 8 times. But remember that each network node on your route to www.whitehouse.gov needs to do the same. On average this introduces less than 1 ms of round trip latency. From my computer it takes just 14 nodes to reach nearest whitehouse.gov edge device. Under less than 10 ms. Since Google and Facebook and Cisco and Akamai did solve this problem...probably SpaceX could design terminals and gateways that would introduce such a small delay. But even if it is three times as much. Let it be 22 network nodes. That is 66 ms. Plus 10 ms for physical limitation of going to space and back. Twice. That is still 76 ms. Under 100 ms limitation.

So what can SpaceX do? They need to play nice with FCC. Of course, there is always a legal way. File a complaint. Sue FCC. Lobby like hell. Or....maybe there is a better way. I mean, SpaceX already has hundreds of Starlink satellites up there. They plan to provide broadband connectivity by the end of this year in some parts of the USA. Continuous broadband connectivity. And they do need to start marketing their user terminals. We know that Elon Musk hates typical marketing strategies. But making a conflict with a big government agency? Just like Tesla reopening Fremont factory against Alameda country order? 

How could this be done? How about taking a Tesla model X. Mount a big LCD billboard on top of the car. And a Starlink terminal. On the big LCD screen, ping www.starlink-to-slow-for-fcc.com. And just drive around Washington. Carefully time passing by FCC headquarters while you have connectivity. Maybe even compare it with local 4G connection. And why use just one car? Why not ten of them, cruising around Washington D.C.? Or twenty? Using Autopilot all the time? Ok, that might be too much for now.  

While at it, why not do a live streaming from some remote site in the middle of nowhere connected through another Starlink terminal. They could show bird hatching in HD quality, giving  homage to Sillicon Valley episode Two Days of Condor. They could show the views from some deserted island with zero inhabitants, located somewhere in the Caribbean. Just a view of sandy beach, with Starlink terminal and waves in the background. 

That would definitely illustrate that FCC technical evaluation of Starlink latency is clearly wrong. And it would get free publicity as a clear statement of unjust evaluation. We know from ancient times that sarcasm is often more powerful that direct confrontation.  


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