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Seems kind of odd that the FCC is basing their decision on safety in those orbits rather than something radio or communication based. I assume someone has to enforce that limit, but I'd have thought it'd be the FAA.
The FCC perspective is that issues like orbital debris mitigation fall within its remit of understanding whether the public interest is appropriately served by authorizing a particular use of the spectrum; which seems reasonable to me.
Whoever solves the orbital debris issue will be more important than Gates, Steve and Musk combined! It is a real issues, and nobody has a properly solution. Before we launch a bunch of tech into space, let's figure out how to do that. So we don't turn or orbit like the landfill here on earth.
There is no orbital debris problem in LEO. Anything in LEO experiences atmospheric drag and only stays up there for a few years unless periodically boosted. If the worst case scenario unfolded in LEO, a few thousand satellites in LEO got smeared by something like ASAT weapons and caused a huge cloud of debris that started wrecking anything new put up there, we could simply wait the problem out in less than one generation.
The FCC's job is to keep the space station safe.
Isn't it that more the FAA's job? I suppose if were chiefly talking about keeping the station and it's occupants safe from being harmed by an intentional radiator[0] I could see it being the purview of FCC. In this case it seems like what's of concern is the possibility of an orbital collision, that sounds like the FAA's bailiwick to me.

[0] https://en.wikipedia.org/wiki/Intentional_radiator

I was just kidding. I'm not sure who's job it is actually.
It's still a mystery to me how building a mega constellation of satellites is more achievable than burrowing some fibers and building cell towers.

The only application I see where Starlink is preferred to "traditional" communication system is warfare.

those things needs all sorts of permits and interactions with governments. This illuminates the true cost of such
Turns out that putting things in space isn't really all that expensive, once you move past the Old Space models.
You vastly underestimate the scale required to serve a large country like the US with cell towers. Maybe in Kansas sure, but hilly areas block line of sight.

I live an hour from SF and I don't have cell service in my house. I can make/receive calls because of Starlink.

I’m actually curious what’s the percentage of people not covered by cell reception in USA vs rural areas of other big countries like China and Russia. I know in Canada it’s somewhat similar, but people who live in northern Ontario/BC in tiny towns still have decent cell reception. Not everywhere, but still.

I could see governments with more top-down approach would be able to complete “everyone gets covered” mission much easier than US/Canada. A lot of money burning since there is no/little profitability, but I could see it being a greater good for the citizens.

Can you get land line service? When was your house built?
Similar reasons why flying can be better than ground based methods. There are lots of obstacles to putting in roads/tracks/etc. (existing structures, mountains, rivers/lakes/oceans, complex jurisdictions, and so on).
My friends in a village in Romania has gigabit internet. This is literally a first world problem, with mad permitting, and land ownership obscured through shell companies, etc. in UK it’s illegal to put up a cell tower over 20 meters in height. People submit objections to planning permission for underground cables, claiming they will ruin the landscape. Solar panels get noise complaints.

On warfare, it’s possibly the opposite - every major nation has ASAT missiles, and you don’t need to shoot down thousands - destroying just a small fraction will fill LEO with hypersonic debris and turn all remaining satellites into Swiss cheese.

The US isn't the only country in the world, either. Starlink has revolutionised communications at sea, in the air, and in countries where "burrowing some fibres" is nigh on impossible.
The US (and Germany where I'm from) seem to be the exception. Most countries have virtually complete coverage.
There's always that last 1% where there's no service or it's has unacceptable performance.

Hence people using starlink in South Korea, Japan and in within cities like Sydney, Rome, London and Boston.

You'd be surprised with the bad performance of some Fiber providers

> still a mystery to me how building a mega constellation of satellites is more achievable than burrowing some fibers and building cell towers

To get permission to build the mega constellation you need to convince a few regulatory agencies. To burrow fibers and building cell towers you need to convince and appease every local authority and land owner who is in your way.

Worst possible future this one. The brightest minds are all trying to figure out how to speedrun through the previous generation's Chesterton's fences.
Right but it shouldn't be this easy to pollute the sky.
There's a bunch of stuff in the way when installing fiber. Also humans telling you you can't build there.

Starlink also makes sense for rural uses.

Oh my friend, you should step into the country sometime! The US, alone, is 105,847,090,000,000 square feet. I used that awkward unit because it's easy to visualize. Not that we can visualize or even really imagine a hundred trillion, other than that it's just absurdly stupidly vast. Covering all of that region (or even just the parts with a human within a reasonable distance) with towers and wires is an absolutely massive undertaking.

This is why, to this day, many places in America still lack access to high speed internet. And then when a tower goes down, or a wire gets cut - it's a major issue that will result in downtime and require costly maintenance. By contrast a relatively small number of satellites can provide coverage to this entire area. And when a satellite goes down, it's not a problem at all - it's a perfectly normal part of the system, and is seamlessly replaced by another instantly. And all of this is just for one country! Starlink covers the entire globe meaning regardless of the state of the country you live in, you can get access to reliable high speed internet.

Ultimately everywhere that has wired power should be able to get fiber, if right of ways were reasonable.
Fibre can go about 100 km without a repeater which in the grand scheme of things isn’t very far. Keep in mind that Starlink works best with a fibre base station inside of the coverage cone. A few of those stations in northern Quebec built next to existing cell towers gets you a lot of connectivity for cheap.
Seems like a repeater could be powered just from induction with neighboring powerline, or solar+battery.
Subsea cables have built-in repeaters and they span thousands of miles.

On land it’s usually easier and cheaper to use huts with power.

You can do 400 km with unrepeated systems.

However, very seldom do you need or want to go that far on land since very, very few places worth connecting are more than 400 km from somewhere else.

Repeatered systems can go thousands of miles and the repeater sites are handy for local breakout.

> Ultimately everywhere that has wired power should be able to get fiber, if right of ways were reasonable.

That's quite a caveat, but still doesn't get you to 'fiber is feasible everywhere'.

Where I am (about 250km north-west of Sydney, Australia) my nearest exchange is 30km away, and no one is going to come up with the money to lay fiber out to me.

Starlink has been an amazing enabler.

What matters is the distance between the end of your driveway to the end of the next person’s driveway not the exchange. Like power lines many homes can all use the same cable.

And sure there’s going to be a few unprofitable edge cases, that’s what mandates are for. A company that wants to serve high density neighborhoods ends up paying for a few random houses far from each other. The average cost per home is what makes an area profitable at least when you setup the local monopoly correctly.

No, mandates absolutely should not be involved unless the agency that is issuing the mandate wants to cover those unprofitable edge cases.

Additionally the distance to the GP home and the exchange it what matters. Unlike electricity, you maybe only have a small percentage of a rural area wanting fiber. If GP is not in a very dense area, he may be the only person within a reasonable distance that wants fiber and no company wants to foot the bill for that.

Mandates are how we got electricity and phone lines to every home. Building such networks are a natural monopoly and communities have real leverage if they want to use it.

Subsidies as needed are fine, subsidies without mandates simply waste taxpayer money without actually fixing the underlying problem. Without a mandate companies just take that cash and build the same profitable network they would have build without it.

Also, 93% of Australian homes have home internet. Cheap fiber beats any other technology when it’s available. So perhaps the neighbor doesn’t want fiber today, in 2 or 20 years when someone else moves in you don’t need to lay a new fiber. It’s all just statistical noise from an investment perspective.

85% of the Australian population lives in a urban metro area.

It is not statistical noise in rural areas. Maybe where you live is different than what I have experienced in rural areas but rural America is not dense enough to always warrant building and maintaining connectivity like fiber. Sat. or Cell service is usually much more cost effective.

Sure if a community/city want to build out their own fiber setup, I think that is a great idea but I do not believe mandates should be required for companies that want to build out fiber unless similar to some areas in electrical grids you separate the concerns of running and maintaining the fiber lines and the exchange/connects.

Also you keep saying mandates but I think from an American perspective it was actually subsidies. If you are saying the government should subsidize the infrastructure I do think that can work but I believe its up to the local government to do it.

You’re misunderstanding what I am saying. In the US we handed out enough subsidies to pay for full fiber to the home at this point 90B from the federal government alone for rural communities.

However we didn’t attach strings to that money aka mandates so they effectively just pocketed it.

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I am not so sure that is true.

Speaking only for the US. I don't have the data but I suspect most of the grid in rural America was built long ago. Everyone needs power, it is a natural monopoly. When they were building it out, everyone got hooked up and only requires regular maintenance. Sure, if there was a sudden growth spurt maybe more lines are run or higher capacity but I suspect for most of rural America that this is not true. I even suspect most of this electrification happened for free or very low rates to the household. Now, if you are building a new home that needs a grid tie-in, it usually costs quite a bit.

Now fiber on the other hand, not so much of a natural monopoly. There may be state imposed regulation where a cable company has rights to areas. You could have a totally free market and many different providers. In a rural area you might be able to sign up only 20% of the population with your service, you would still need to build out the infrastructure though and perhaps that 20% would not even cover costs.

It is easy to say everywhere with power should have fiber but America is vast and that would be quite expensive, I am not even sure a local effort would be able to cover costs.

GP said, "if right of ways were reasonable."

In the context of internet connectivity, I interpret a reasonable right-of-way policy being collectively-owned fiber which can be shared.

We don't say, "everybody who wants a road should build their own road along this path" we just build the damn road and share it.

I do not believe your interpretation is correct or what most others would assume to be the case but hey I could be wrong.

Right of way being reasonable means that the owner of the transmission lines did not charge unreasonable fees or requirements for using the same poles to run fiber.

And you are partly wrong on your last part, yes of course each individual is not building their own road but again, roads are natural monopolies, everyone wants a road of at least some minimum quality (dirt). Additionally it would be near impossible to get "right of way" to build your own road. In rural areas roads are indeed just dirt and to get it paved would require some majority of the individuals living out there to pay for it, YMMV depending on local rules. Since its a road its easier to get a majority to agree to to pack it with gravel or pave it, everyone that lives down that road is driving on it. I am not arguing that internet is or is not a right that everyone should have but that it is not always a natural monopoly, some people maybe don't want it, some have cell service, some are using Dish, maybe there are some cable connections available in certain areas. So yes, each individual does not build their own road but often in rural areas the burden for that road is shared and often stays as a dirt road because of it.

Your liberatarian dreamland example (though not reflective of any rural [public development] area for the last few decades that I'm aware of) is a perfect illustration of my point.

Even those areas with private roads [private developments generally] only have a single private road that everyone shares on a given route. The argument why is that it's a natural monopoly. But what does that mean?

It means high barriers to entry (often infrastructure) mean the first mover has an overwhelming advantage. Isn't that precisely the case with fiber, as you yourself were arguing?

So is provisioned fiber a sufficient barrier to entry to qualify as a natural monopoly or is it not? Please clarify.

Sorry I am not a "libertarian", republican or even a democrat but can we please try our best to keep politics out of this discussion, its such a low brow way to share your point.

I simply pointed out that when it comes to building infrastructure, right of way typically means the ability to build said infrastructure using someone's property. That could be land rights, rights to the transmission pole, rights underground etc. Additionally I was simply pointing out that people may be served by other forms of internet connectivity already (including starlink). That is all, nothing about politics, sorry to have ruffled your feathers.

I didn't mean to imply your own political beliefs, merely describe the character of the example given.

It is certainly the case that (in the old US of A at least) we seem to make a sport of trying to tear up our roads as frequently as possible so that each individual utility can separately work on the same shared space, to the detriment of those living in the area. Is that an ideal way to organize infrastructure projects?

No, of course not! It would be much better if we all coordinated to commonly achieve our shared goals rather than stepping on each other in a vain race to the top! Oh well, a man can dream.

You just included a lot of land nobody lives on in that number.

The US only has 4.09 million miles of road, that’s roughly how much fiber you need to get it to everyone’s driveway. At ~1-10$ a foot we’re talking ~20-200billion dollars etc and most of it’s already in the ground or dangling from utility poles.

We don’t have fiber everywhere because we didn’t mandate it the way we mandated electricity or phone lines to every home. It was billions of subsidies without sufficient strings so of course companies only built the most profitable networks.

I don't follow your last part but yes, in the US the federal government subsidized the electrification of rural America and with a add-on to give loans to telephone companies that wanted to expand service at the same time. I do not believe it is so much of a "mandate" but a subsidy that allowed for the majority of expansion. At this point most of rural America is already serviced by cell, satellite and now starlink that in a lot of areas it may not be cost effective. I say cost effective not from a corporate profitability but a non-profit community run initiative.
The last part is this:

The government already handed over the full cost of Fiber to the home everywhere. Just the Federal government alone has handed out over 90 Billion dollars for rural high speed internet. That estimate I gave also included profitable areas, the unprofitable rural network requiring strings is only a fraction of the total cost.

The money just didn’t have enough strings to require companies taking it to actually build out their networks everywhere.

Your cost estimate is not really reasonable for what it would cost to lay fiber out in the middle of nowhere at extreme scale using labor sources that don't currently exist. But the differences here are so stark that I'm not even going to argue against that, beyond what I've done. Let's go with it, while also considering you also have maintenance costs of course - quite large ones in fact when you're obligated to support and maintain wiring/towers even out in the middle of nowhere.

Now let's compare to Starlink. That system was privately designed, built, and deployed for a total cost of ~$10 billion. And while I don't know their maintenance costs, I do know they're now already turning a profit with a relatively small number of users. So that's providing complete and stable connectivity for the entire globe, at half of the bottom of an unrealistically low price for wiring a single country. And you get vastly better reliability, and near 0 labor maintenance. I don't think this is particularly close.

This is a silly argument.

The US is about the same size as Europe.

Size is not a reason why the US has lack of access to high speed internet.

coverage to an entire area is either via "small number of satellites" in geostationary orbits or massive amounts of satellites for low earth orbits, you cannot have both.

"Just replaced by another" is massively oversimplifying every aspect of this, not just the act of putting an object in orbit, but also the coordination of that many MOVING satellites, their fuel levels / end-of-life procedures, all the ground infrastructure needed to support it, and the total amount of energy that this system requires (both on the side of the service providers and users).

Connecting rural or places without internet is not a technical problem, like everything in the world we built it is an issue of priorities. Starlink was not created "for the good of the farmer".

So how did this great rich nation, leader of the free world, owner of the largest army, manage to get cables to all those imperial square feet of people for power, telephone and water and is now in 2024 at the height of its power incapable of getting a much thinner cable in the same direction?

What happened in the last generation that you just so easily buy this cheap copout of "oh no, the whole nation is big and we now can't even cover a small state"?

As for water much of it uses wells drilled on each persons property. Electrical and telephone a lot was done as a new deal jobs programs like the Tennessee Valley authority. As such it was more about making endless work to give the unemployed untrained labor jobs trying to get the US out of the great depression.
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Satellites got cheaper and land work became more expensive
> only application I see

You have never seen a ship or a plane before? Are you just perilously saying nonsense?

More generously, those examples just hadn’t come to mind when they were writing their comment.
When they wrote 'warfare' did they not think of planes and ships?
A company I know, uses it to build out internet on inside industrial construction sites. Even if the basic infrastructure like power is there, sufficient internet often isn't (yet).

Much easier to setup a few starlink terminals and/or LTE antennas on the roof/container and temporarily bolt a few wifi router to the ceiling than run cables all around.

Exactly LTE or 5G... If there is enough demand, supplying that should be reasonable enough if the system wasn't entirely broken. And if there was no demand, well there would not be enough paying customers either...
>It's still a mystery to me how building a mega constellation of satellites is more achievable than burrowing some fibers and building cell towers.

NIMBYs is why

Yet the US spends a greater amount EVERY year on building fiber into ever more remote areas (between FCC and NTIA programs, over $10 billion per year) than it has cost Starlink TOTAL to build a network that covers the entire country. Starlink needs more satellites to increase the max number of subscribers they can support, but their costs are actually going down.

Digging trenches in the ground is expensive. It’s a big country. You need immense amounts labor and at the end of the day, you just have a barely profitable fiber line, if that. Many of the new fiber lines will only survive on further government subsidies. Meanwhile, Elon builds a spaceship to launch satellites and people pay him handsomely for access to it. That’s not to mention that construction is heavily unionized, requires locality by locality planning permission and rights of way, etc.

Let me resolve that confusion for you. Its because there's not enough money in rural fiber. Its not worth it or someone would have already done it.
There is also not enough money in rural powerlines or rural roads yet somehow we manage to build those.
Not well. I have power down 10-20 days a year and I'm less than 12 miles as the crow flies from the Googleplex. There's no cable, fiber, or cell here and our neighborhood has to maintain a mile of its own road to service 35 homes because the county will not. Same for water. AT&T is in the process of ending our landline service.
Hold that thought. We built also all of them nearly a century ago now, and we can barely keep them up.
It's not a replacement for land-based connectivity. The available bandwidth will not permit the same density (by far) nor cell coverage indoors.

This is for the more rural areas, or downright remote ones.

The ISS will be gone in a few years anyway, so this problem should sort itself out.
It's not even clear that the ISS is the issue, that's just the opinion of one dude from the UK. It's a very strange article.
It's quoted in the article in the first paragraph and is mentioned on page 16 of the order that is linked in the article...
Yeah the ISS is actually a big consideration when doing orbital stuff. If you plan on changing orbit across the path of the ISS (remembering that all orbits of a given altitude insect) you have to do significantly more paperwork and be able to show you can make the transit quickly without stopping and getting stuck on a collision course with it.
If you're regulated by the European Union, the US, Russia or Japan sure. Otherwise low earth orbit is close to a free for all.
SpaceX is in the US.

Also, it's where you're located, not just where you're regulated. People have gotten their pp smacked pretty hard for playing the "oh, you won't grant an FCC license? We'll just use a launch provider in India" game.

Nobody seems to be talking about the main point. Latency.

> very low earth orbits (VLEO) ranging from 340 to 360 kilometers

> Starlink currently has nearly 6000 satellites orbiting at around 550 kilometers

> its service ... with average latencies ... over 30 milliseconds at best, and double that at peak times.

What is unsaid in the article is how much of that latency is due to time of flight and how much is due to buffers and processing inside a satellite.

The stated fact that the latency "doubles at peak times" implies that some portion of the stated 30ms is not time of flight So how much is actually due to time of flight? One of the linked articles claims:

> 8 ms is the absolute minimum latency for a satellite at 550 km

When a satellite is exactly above head the round trip time at the speed of light is a bit shy of 4ms. This "8ms" must be some average over a minimum solid angle that still allows for an acceptable level of signal reception. It is a reasonable number.

Lowering to VLEO gives the above head latency of a bit over 2ms. Being lower, the solid angle for reception is less. They may actually need in total more satellites than at higher orbits. In any case, the average would probably be something less than the 2x from the 550km case. But, let's say "4ms" compared to "8ms".

So, by going to VLEO, the best they can do is knock off about 4ms from their "30ms at best". It seems that polluting VLEO will not even achieve "The biggest single goal for Starlink from a technical standpoint is to get the mean latency below 20 milliseconds," said Elon Musk.

There is some other reason for pushing into VLEO than reducing latency.

Maybe closer to earth -> better signal -> less processing needed / cheaper satellites? I don't even work with RF so this is baseless guessing.
You seem to only consider the roundtrip to the satellite and back. To talk to anything other than the satellite itself, you need to double that. The lowest allowed angle to the horizon is 25°. This makes the worst-case RTT for talking to someone near you on the ground 17ms.

> They may actually need in total more satellites than at higher orbits.

This is a desirable feature. There are limits on how much bandwidth they can push through a single satellite, and minimum allowed angular separations between two satellites the same place can be talking to. Lower orbit allow larger constellations, because the ground stations cumulatively have "more sky".

The primary reason to push for VLEO is that it is a safer orbit. As a general rule, everyone is better off the lower large constellations are, because in case of a worst-case collision the debris will deorbit faster. It's also better for astronomy.

How does the FCC have jurisdiction in space? If one was to say its because signals are being sent back to the US, fair enough but why would the point of origin of the satellite from earth come into play. At what point does their jurisdiction end?

Genuine questions