SpaceX has now told the FCC multiple times that the agency should begin the process of phasing down and eliminating all rural high-cost subsidies from the Universal Service Fund. The company filed comments asking for the end of subsidies in FCC Docket 26-96, which is looking at reforming the High-Cost Fund for an all-IP future, and in Docket 10-90, which is looking at Universal Service Fund reform. In both filings, SpaceX says that its proliferation of low-orbit satellites means that rural subsidies are obsolete and are no longer needed. The company characterizes anyone who disagrees as a “subsidy-dependent incumbent.” SpaceX goes on to argue that the money currently spent on rural subsidies should be redirected to programs that lower the cost of broadband for low-income families.

It’s an interesting policy question that raises more questions about satellite broadband than it does about the rural companies that are receiving broadband subsidies. For example, the CAF II subsidy is being provided by a number of rural ISPs who use the subsidy to justify building and maintaining rural fiber, similar to what was done with the FCC RDOF.

I think the SpaceX request raises multiple policy questions. First, is satellite really providing broadband? Earlier this decade the FCC declared that Starlink was not providing broadband when the agency canceled the $885 million award Starlink had won in the RDOF reverse auction. At the beginning of this year, Ookla said that only 45% of Starlink customers were meeting the FCC’s definition of broadband at 100/20 Mbps. But Starlink’s speeds have been slowly improving, and will be boosted over the next five years as the company replaces the current V2 satellites with the new V3 satellites that provide 10 times more download capacity and 22 times more upload capacity.

As I have argued many times, the FCC’s 100/20 Mbps standard is no longer a reasonable definition of broadband. Recent data from OpenVault showed that 43% of U.S. households now subscribe to speeds faster than 500 Mbps download and 70% of homes subscribe to speeds of 200 Mbps or faster. It’s hard to look at these statistics and think that 100 Mbps is still an adequate definition of a good download speed. However, the real issue for satellite broadband is the upload speed. A large percentage of the homes cited by Ookla as having fast download also get far faster upload speeds than 20 Mbps. Fiber overbuilders are mostly providing symmetrical data speeds, meaning gigabit upload speeds. Cable companies across the country are upgrading the upload path and are delivering speeds of 50-100 Mbps at a minimum, and in some networks, gigabit upload speeds. The whole country learned during the pandemic that 20 Mbps upload is not adequate to support more than one user at a time—something the FCC has steadily ignored.

Another issue raised by the SpaceX request is whether Starlink provides a good substitute for voice service. Much of rural America lives in areas with little or no cellular service. The companies that receive high-cost subsidies all must pledge to offer voice service so that rural residents have access to 911. SpaceX argues that anybody with a satellite broadband connection can buy VoIP. That’s a true statement, but it raises two more policy questions of availability and affordability.

The companies receiving high-cost funding agree to service every home and business in their footprint. It’s pretty clear that Starlink can’t make that claim. While the company won’t disclose the number of homes it can serve in any given geography, there are examples, like last year’s Burning Man, where Starlink got overwhelmed by too many customers in a rural area.

I think the most important factor is affordability. Starlink’s price of $130 per month is a lot higher than other rural broadband options. Companies that receive high-cost support sell broadband for a lot less than $130, but more importantly, will sell voice-only to customers who don’t want broadband. It’s not reasonable that a rural household that can only afford voice and not broadband should have to spend $130 per month for satellite service.

In my mind, Starlink has to offer a different set of products if they want to declare that they can match the benefits that companies that receive high-cost funding bring to customers.

• Starlink needs faster upload speeds, which it probably will eventually get as it phases in the V3 satellites.
• Starlink would have to be able to serve everybody in a geographic area if it wants to see the subsidies end in a given area. I can envision a regulatory test similar to the one that cable companies have used to get regulators to declare a market to be competitive. High-cost subsidies should only stop in an area where every customer in the area could be served by a satellite instead.
• Finally, Starlink would have to be a lot cheaper. If SpaceX wants to see the rural high-cost subsidies ended, it should offer lower broadband prices in those markets, including a really low-cost connection for voice only.