FBA, NTCA Help FCC to Evaluate LEO Satellite RDOF Apps

Network Infrastructure

The Fiber Broadband Association (FBA) and NTCA–The Rural Broadband Association today submitted to the FCC a technical assessment and model to aid the agency’s efforts to scrutinize the Rural Digital Opportunity Fund (RDOF) long-form applications for Low Earth Orbiting (LEO) Satellite broadband networks.

The FCC awarded almost $900M of assigned RDOF funds to SpaceX™ with a commitment to connect 640,000 locations across the U.S. with its Starlink™ satellite broadband technology.

The sample analysis conducted by Cartesian, based upon current publicly available information, estimates that Starlink would face a capacity shortfall by 2028 and over 56% of Starlink’s RDOF subscribers would not be fully served.

Through this analysis, the Cartesian paper provides a roadmap for the FCC to evaluate more information as it becomes available and to verify ultimately whether the network will in fact perform as promised in the RDOF auction.

“The Fiber Broadband Association continues to work toward a better broadband future for everyone. We’re collaborating with organizations across the globe to advance broadband initiatives, like RDOF, to boost opportunities for work, education and economic development. We applaud the FCC’s efforts to provide broadband subsidies as we work to eliminate the rural and urban digital divide,” said Gary Bolton, President and CEO at the Fiber Broadband Association. “Our goal with our latest FCC filing is to provide tools and technical analysis that will support more indicative assessments of incipient technologies so that the agency can ensure that RDOF winners can deliver the broadband performance promised.”

“NTCA members are based in the rural communities they serve and recognize the great hope that the RDOF auction offers for Americans living in other rural areas that lack quality broadband. But, steps must be taken to ensure that the RDOF auction delivers on this promise – and that winning bidders will deliver more specifically on their own promises to rural America,” said Shirley Bloomfield, CEO of NTCA. “NTCA called upon the FCC to vet bidders more thoroughly before the auction given the stakes. This did not happen, making it all the more important now to examine carefully each bidder’s ability to perform. If each winning bidder performs as promised, only then can we declare the auction a success. We must do the hard work today to confirm capabilities rather than discovering any issues only years from now – and it is in this spirit that we offer recommendations in this filing for such due diligence.”

The sample analysis conducted on Starlink technology was based on Starlink’s RDOF commitment and reported fleet specifications. Anticipated peak broadband usage demands were calculated through the year 2030 and using optimistic network conditions the research showed that Starlink may fail to provide enough bandwidth to over half of all subscribers at peak hours. Further, the analysis indicates that additional states with RDOF locations awarded to Starlink will not achieve the required obligations if these satellites were to serve non-RDOF commercial subscribers.

The study also highlights that the FCC may not be able to use terrestrial performance measurement and monitoring for LEO Satellites, as currently used in the CAF program. Unlike a terrestrial fixed network, Starlink can be dynamically reconfigured after deployment, meaning that Starlink’s network could deviate at any given point from the design submitted in the long-form application.