[Starlink] [NNagain] FCC Upholds Denial of Starlink's RDOF Application

Sebastian Moeller moeller0 at gmx.de
Sat Dec 16 06:14:37 EST 2023


Hi Alexandre,


> On Dec 16, 2023, at 09:09, Alexandre Petrescu <alexandre.petrescu at gmail.com> wrote:
> 
> Hi, Sebastien,
> 
> Le 15/12/2023 à 14:06, Sebastian Moeller a écrit :
>> Hi Alexandre,
>> 
>> 
>>> On Dec 15, 2023, at 13:07, Alexandre Petrescu via Starlink <starlink at lists.bufferbloat.net> wrote:
>>> 
>>> 
>>> Le 14/12/2023 à 19:51, Nathan Simington via Starlink a écrit :
>>>> Hi folks,
>>>> 
>>>> (Apologies in advance to non-Americans or anyone who doesn't care about American home broadband policy! Please feel free to immediately delete!)
>>>> 
>>>> I don't want to get overly political on this mailing list, but my statement on this topic is a matter of public record: https://docs.fcc.gov/public/attachments/FCC-23-105A3.pdf. As this item is now closed, there is no risk of any impermissible side-barring ("ex partes" that would have to be filed on the record, in regulatory jargon) if anyone wants to discuss this.
>>>> 
>>>> The FCC is funded through regulatory fees which, traditionally, fell predominantly on broadcasters and monopoly-era AT&T. This mechanism, or at least how we calculate it, is increasingly inapposite for a world in which so much video and voice traffic takes place via unregulated services. That's one reason the agency is shrinking even as the communications industry is growing. Another is that many of our necessary functions, such as RF emissions enforcement, are on a non-fee basis and thus short-term painless to cut (even if that means that we're abandoning oversight of a rising noise floor, or of a device world where post-licensure quality fade on emissions control is normal business practice.)
>>>> 
>>>> I'm on the record as saying that the FCC should reallocate resources and seek additional money with the goal of hiring 500 more engineers and field enforcement staff. That number is probably too small, but it would be a good start ;-) I was horrified to learn recently, while researching my Title II statement, that the FCC essentially has no internal experts left on peering and transit. How in blazes was this allowed to happen? (I hired one of the handful left as my chief of staff, but that just makes her unavailable to the career staff, so...)
>>>> 
>>>> On this specific issue, I think a reasonable person could look at current federal broadband programs and see a significant bias in favor of fiber to the home. Someone drawing that conclusion might point, in addition to StarLink's situation, to the specific exclusion of unlicensed-frequency fixed wireless from the BEAD program, in defiance of the current tech trends. Anyone finding bias there might further note that the federal government talks incessantly about line speed but never about traffic management or router firmware and conclude that technically shallow federal politicians have no better ideas than to resort to the same metric that ISPs use in their advertising.
>>>> 
>>>> I don't always see eye to eye with TechFreedom, which is why I so appreciated their filing on the same NOI that some in this group were involved with filing on. Their filing noted that line speed is a misleading and inappropriate proxy for customer experience quality, though not in the detail of the engineering filers, and also pointed out (among other points) that selling broadband to the public on the basis of telehealth and education is belied by the traffic numbers, which show that entertainment uses predominate. Not that I have anything against entertainment, but the feds haven't been candid (and perhaps the public has allowed itself to be deceived as well) about the reality of how its enormous fiber infrastructure subsidy commitments will be used in practice.
>>>> 
>>>> If we can provide good service to people without the huge lift of a universal fiber to the home build, then the United States is headed in the wrong direction and will be wasting a lot of public money. And, unlike StarLink, we still won't have connected Dave's boat :-)
>>>> 
>>>> All best,
>>>> Nathan
>>>> 
>>>> On Thu, Dec 14, 2023 at 12:49 PM David Bray, PhD via Nnagain <nnagain at lists.bufferbloat.net> wrote:
>>>> 
>>>>    FCC's staff continues to shrink. 1420-or-so employees in 2022,
>>>>    1755-or-so in 2012, 1952-or-so in 2004. So about a 25% reduction
>>>>    over the last twenty years. There are several good people there
>>>>    among the staff, however they also face an increasing number of
>>>>    tasks and demands with less resources. Public service depends on
>>>>    folks being willing to step up and be of service.
>>>> 
>>>>    Also, ultimately it is the decision of the Commissioners. Staff
>>>>    can brief the Commissioners and present evidence, the
>>>>    Commissioners are there to make the policy decisions. Remember
>>>>    Commissioners are Presidentially-appointed, Senate-confirmed which
>>>>    selects for certain things in keeping with our Constitution. For
>>>>    the staff, this means accepting that politics may supersede even
>>>>    the best technical briefing.
>>>> 
>>>>    Such is how representative governments work. And if you circle
>>>>    back to Plato's The Republic, the conclusion is such is how
>>>>    humanity wants it - we don't want a perfectly wise, benevolent,
>>>>    philosopher king. Each of us wants compromises - the difference
>>>>    being those specific compromises. Plato (through the voice of
>>>>    Socrates) also concludes humanity would probably kill a perfectly
>>>>    wise, benevolent, philosopher king if we were to ever have one -
>>>>    again because despite everyone saying they want this, they really
>>>>    only want such a person if that person agrees with them fully. Or
>>>>    as Tears for Fears aptly put it: "Everybody Wants to Rule the
>>>>    World" = https://www.youtube.com/watch?v=awoFZaSuko4
>>>> 
>>>> 
>>>> 
>>>> 
>>>>    On Thu, Dec 14, 2023 at 1:00 AM Frantisek Borsik via Nnagain
>>>>    <nnagain at lists.bufferbloat.net> wrote:
>>>> 
>>>>        Thanks, Robert. Exactly what I meant. Therefore I added NN
>>>>        list, because Nathan was engaging with us there, and with Dave
>>>>        (me and some others, to my knowledge) either directly or via
>>>>        his staffers and he really wanted to catch up on tech things
>>>>        that are the culprits of Net Neutrality (bufferbloat.)
>>>> 
>>>>        So instead of assuming that Nathan Simington and Brendan Carr
>>>>        are “bought” as someone did, I can the FCC itself as an entity
>>>>        can be understaffed at worse.
>>>> 
>>>>        But still, I appreciate efforts to learn about what’s going in
>>>>        here and getting it right.
>>>> 
>>>>        All the best,
>>>> 
>>>>        Frank
>>>>        Frantisek (Frank) Borsik
>>>> 
>>>>        https://www.linkedin.com/in/frantisekborsik
>>>>        Signal, Telegram, WhatsApp: +421919416714
>>>>        iMessage, mobile: +420775230885
>>>>        Skype: casioa5302ca
>>>>        frantisek.borsik at gmail.com
>>>> 
>>>> 
>>>>        On Thu, 14 Dec 2023 at 3:46 AM, Robert McMahon
>>>>        <rjmcmahon at rjmcmahon.com> wrote:
>>>> 
>>>>            I think this common in that appointment of commissioners
>>>>            go through a political process. The FCC has a technology
>>>>            group, too. When I worked with them about 8 years ago,
>>>>            they had skilled researchers on staff and a highly skilled
>>>>            director. They asked good questions about engineering
>>>>            decisions, like what is limiting the number of mimo
>>>>            streams on devices.
>>>> 
>>>>            Their physical facility is a bit dated, and they don't get
>>>>            stock grants. I respect the engineers I worked with for
>>>>            what they did.
>>>> 
>>>>            Bob
>>>>            On Dec 13, 2023, at 2:38 PM, Frantisek Borsik via Nnagain
>>>>            <nnagain at lists.bufferbloat.net> wrote:
>>>> 
>>>>                I would love for Nathan to be here with us, and
>>>>                comment on that :-) so I will add NN list as well.
>>>> 
>>>> 
>>>>                All the best,
>>>> 
>>>>                Frank
>>>>                Frantisek (Frank) Borsik
>>>> 
>>>>                https://www.linkedin.com/in/frantisekborsik
>>>>                Signal, Telegram, WhatsApp: +421919416714
>>>>                iMessage, mobile: +420775230885
>>>>                Skype: casioa5302ca
>>>>                frantisek.borsik at gmail.com
>>>> 
>>>> 
>>>>                On Wed, 13 Dec 2023 at 11:21 PM, Richard Roy
>>>>                <dickroy3777 at comcast.net> wrote:
>>>> 
>>>>                    ------------------------------------------------------------------------
>>>> 
>>>>                    *From:*Starlink
>>>>                    [mailto:starlink-bounces at lists.bufferbloat.net]
>>>>                    *On Behalf Of *Frantisek Borsik via Starlink
>>>>                    *Sent:* Wednesday, December 13, 2023 1:26 PM
>>>>                    *To:* Dave Taht via Starlink
>>>>                    *Subject:* [Starlink] FCC Upholds Denial of
>>>>                    Starlink’s RDOF Application
>>>> 
>>>>                    “*Elon Musk*’s Starlink was not the only major
>>>>                    company to inflate its capabilities
>>>>                    <https://broadbandbreakfast.com/2021/04/rdof-reverse-auction-criticized-google-makes-pandemic-gains-california-broadband-access-for-k-12/> in
>>>>                    RDOF bids. Nearly 100 bidders have defaulted since
>>>>                    the auction, leaving in limbo an estimated $2.8
>>>>                    billion
>>>>                    <https://broadbandbreakfast.com/2023/06/what-happens-to-the-estimated-2-8-billion-in-rdof-defaults/> of
>>>>                    the $9.2 billion originally awarded.
>>>> 
>>>>                    The FCCupheld another denial
>>>>                    <https://broadbandbreakfast.com/2023/12/fcc-proposes-22-million-fine-against-ltd-over-rdof/>on
>>>>                    Monday in the case of LTD Broadband, which
>>>>                    appealed the commission’s finding that it could
>>>>                    not reasonably serve the more than 500,000
>>>>                    locations to which it had committed. The
>>>>                    commission also hit LTD with a $21.7 million fine
>>>>                    for its default.
>>>> 
>>>>                    The commission’s two Republicans dissented to
>>>>                    Starlink’s denial, claiming they saw a path for
>>>>                    the company to improve its speeds before the first
>>>>                    deployment deadline in 2025.”
>>>> 
>>>>                    */[RR] The reason two lawyers “saw a path” is
>>>>                    because they were bribed/conned into to see it. In
>>>>                    my nearly 50years of experience dealing with the
>>>>                    FCC, extremely rarely are the people at the top in
>>>>                    the commission tech savvy.  In general, they have
>>>>                    NO CLUE when it comes to technology … period! /**/JJ/*
>>>> 
>>>>                    https://broadbandbreakfast.com/2023/12/fcc-upholds-denial-of-starlinks-rdof-application/
>>>> 
>>>> 
>>>> 
>>>> 
>>>>                    All the best,
>>>> 
>>>>                    Frank
>>>>                    Frantisek (Frank) Borsik
>>>> 
>>>>                    https://www.linkedin.com/in/frantisekborsik
>>>>                    Signal, Telegram, WhatsApp: +421919416714
>>>>                    iMessage, mobile: +420775230885
>>>>                    Skype: casioa5302ca
>>>>                    frantisek.borsik at gmail.com
>>>> 
>>>>                ------------------------------------------------------------------------
>>>> 
>>>>                Nnagain mailing list
>>>>                Nnagain at lists.bufferbloat.net
>>>>                https://lists.bufferbloat.net/listinfo/nnagain
>>>> 
>>>>        _______________________________________________
>>>>        Nnagain mailing list
>>>>        Nnagain at lists.bufferbloat.net
>>>>        https://lists.bufferbloat.net/listinfo/nnagain
>>>> 
>>>>    _______________________________________________
>>>>    Nnagain mailing list
>>>>    Nnagain at lists.bufferbloat.net
>>>>    https://lists.bufferbloat.net/listinfo/nnagain
>>>> 
>>>> 
>>>> 
>>>> -- 
>>>> Nathan Simington
>>>> cell: 305-793-6899
>>>> 
>>>> _______________________________________________
>>>> Starlink mailing list
>>>> Starlink at lists.bufferbloat.net
>>>> https://lists.bufferbloat.net/listinfo/starlink
>>> 
>>> For non-US country (France).  The issue here about the fiber deployment is the too numerous disconnections, because they keep adding new connections, by third parties contracted by the real operators (its' not the operators who install).  In a growing tele-work era that impacts a lot the economy.
>>> 
>>> That continuous disconnection is a growing issue since some months if not years now.  It is a public matter, with action from local regulatory body (ARCEP)  imposed on operators.
>>> 
>>> The reason of fiber disconnection is, I suspect, the 'tangled fiber' - they dont really know which fiber belongs to whom.  When they install a new fiber, they often impact, or outright disconnect, an existing fiber.  Re-installing takes time.
>>> 
>>> (this 'tangled wires' is not particular to just fiber, it can be witnessed in other cables for public use;)
>>> 
>>> On the positive side, the fiber installations they make (I saw it here) are somehow future proof.  The bring not just one fiber, but 4 or 5 to a same subscriber ; they light only one, equalling 1gbit/s.  It means that they could scale it up later to 4 or 5 gbit/s, without additional installation.  At the current rate of growth, it might mean 10 years, if it does not accelerate.
>>> 
>>> Thus, technically speaking, one would like the advantages of satcom such as starlink, to be at least 5gbit/s in 10 years time, to overcome the 'tangled fiber' problem.
>> Today er can push to hundreds of Gbps over a single strand of fiber,
> 
> Thanks, I did not know that.
> 
> I would like to clarify.
> 
> I am not sure what do you mean by 'strand'?  I know that at home there is a black 5mm-diameter cable which contains 4 or 5 transparent hair-like fibers; each is maybe 1mm or less in diameter.  Some people call a fiber that 5mm black cable, or call 'fiber' just one of these hairs.  Each of these hair-like fiber can be cut but before connecting it to another hair it must be aligned by a special handheld machine; it appears to me to be an electronic microscope.  In that way the fiber can be extended with least loss, rather than IP routing.
> 
> Is a 'strand' that 'hair'?

	[SM] Yes, with strand I wanted to tackle the same issue, that fiber cables typically contain more separate wave-guiding fibers, but comparing multiple fibers with a single satellite would have seemed obviously unhelpful.


> I suspect that it is that hair-like fiber that can carry 1gbit/s, because that's what I get at home.

	[SM] Multiple hundred Gbps actually... most european fiber ISPs seem to use passive optical networks (where multiple end users share the same fiber trunk from an optical splitter to the central office, there is an individual fiber fr each enduser conedcted to the splitter, but the traffic all needs to share the "trunk" fiber [I am sure this is not the correct nomenclature I am using, but I hope you understand]). These trunk fibers have capacities ranging from 2.5/1.25 Gbps (Down/Up) for GPON, over 10/10 Gbps for XGSPON (actually more like 8.5/8.5 when FEC is used), up rto 25/25 with 25GSPON or (still work in progress) 50/25 with 50GPON... Just as the downstream from a satelite is shared between starlink users in the same cell, so is the aggregate capacity in PONs.


> It can also be, that it is on that same hair-like fiber that it can be pushed even higher than 1gbit/s (you say hundreds of Gbps,

	[SM] Yes, that depends a bit on the exact fiber specifications, but I think you can buy optical tramsceuvers for single fibers (aka hairs) that allow 800 Gbps (at least that is what a quick look at fs.com revealed).


> and Gert said Fiber7.ch delivers 25 gbit/s;

	[SM] In Switzerland they opted for an active optical network (AON) and Init7 gets hence a darf fiber per customer and can light this up any way they want. They figured out that offering 25 instead of 10 is viable for them, so they went and did that. (I do note though that Init7 is not primarily and end user ISP, and offering really fast symmetric end-user links might positively affect their traffic mix, potentially opening up more opportunities for cheaper peerings due to more equal ingress/egress ratio, but that is pure speculation).


> a little bit like on copper lines they went from 2.4kbit/s up to 20mbit/s).  

	[SM] I think the limit on telephony copper is around 200-300 Mbps (and that is an economic limit, there are techniques for short reached like G.fast that reach up to 1000 Mbps that are just not deployable en masse due ot cable length being too long).


> Or maybe the fiber hundreds of gbit/s can be obtained from multiple such hairs, or maybe even multiple 5mm black cables.

	[SM] Yes, you can always add more waveguides to increase the throughput linearly, but for end-user links that is rather unlikely, there typically will be a fixed number of fibers...


> I also heard of 'hollow' fibers talked about in the sat-int email list at ietf.  I never saw it in practice but many people talk about it and its potential.

	[SM] The promise of hollow fibers is that they allow faster signal propagation than the typical 2/3 of the speed of light inside glass fibers. I am not sure whether these are actually viable for PONs and even if, if they make much sense, after all the largest access delay in PONs comes from the typical request grant cycle and not from signal propagation/serialisation delay.


> From another analsys I concluded that by year 2031 the optical lines (fiber) might feature up to 1 petabit/s. (from a presentation titled 'optical cables roadmap' of January 2023).

	[SM] I think such numbers are mostly relevant for backbone networks and especially sub-sea cables, for home links I do not expect these to show up in the 2030s ;)


>>  that is completely unrealistic to match from space.
> 
> Well, indeed it might appear so.  One might hardly think of an individual wireless radio link to an end user at 1 petabit/s in year 2031 from a constellation of sats.
> 
> But, I would like to clarify.
> 
> One is the electronics advancements, leading to transistors working ok at hundreds of GHz spectrum, or even more.  This translates in these channel widths in the order of tens of GHz at this 140GHz range.
> 
> Another clarification is that of access: the fiber used to access (end user link) should be compared to the end user links of sats. The fiber used for 'metro'(politan) links should be compared to sat-to-sat links.  The year should be specified.
> 
> The evolution of power of computers and their energy efficiency (onboard sats) as well as of the efficiency of energy sources, should be considered as well.
> 
> Given that, I think it can still be imagined that a satcom access link to be required to deliver same fiber access link bandwidth at a same year.  Maybe that year is not in the immediate.

	[SM] I see this only happen if the fiber side stops any further development while the satellite side continues, and even then... for single links free space laser lins between base statin and satelliltes might approach fiber like speeds, but that does not sound like a desirable outcome...


> 
>>  If the problem is wiring and cable organisation, that seems considerably easier and economic to fix than pushing all traffic via satellites.
> 
> It is a good consideration.
> 
> I think the wiring is not as easy to fix.

	[SM] Not easier to fix than setting up a LEO space program where satellites have to be replaces continuously? I am pretty sure this is not a matter of capabilities and more of priorities ;)


>  There are many organisational problems.  Even a regulator cant impose that fixing, it does not work.  They gave us now an URL to tell the regulator whenever we have another fiber disconnection (click on an URL when no connection, hmm...).  I dont bother calling the regulator.  I do bother calling the ISP to fix it, once again.  I dont know for how long will I still bother calling them about this.
> 
> I would say that it is as easy to fix these fiber wires as it is easy to fix the decomissioning of sats, or the organisation of space overall.

	[SM] I am less optimistic here... it seems rather simple to hand over all access fibers to a single entity and have these to one thing and do it well, deploy and maintain fibers in the access network, that should solve the disconnect problem relatively efficiently. And I am sure the french state would have zero problems managing something like that.


> 
>>  Don't get me wrong networking via LEO satellites is pretty cool and in some situations extremely valuable, but not a reasonable alternative for a FTTH network for most cases.
> 
> I do agree in large part.  It is common sense.
> 
> It might be that my views wont happen.  It's just forecasting.

	[SM] Fair enough, let's see how things develop, after all users typically are fine with "enough" capacity, and maybe LEO will end up delivering exactly that enough capacity so people stop caring. ATM we lack "killer-application" for high capacity links already (that is desirable applications that strictly require high capacity links to work at all), no wonder even the access network industry started looking at latency as the next thing to address that might be valuable enough for users to invest into. (Wich also happens to be where LEO clearly beats GEO, delivering base latencies that make special case PePs avoidable).

Regards
	Sebastian


> 
> Alex
> 
>> 
>> Regards
>> 	Sebastian
>> 
>> 
>>> Alex
>>> 
>>> _______________________________________________
>>> Starlink mailing list
>>> Starlink at lists.bufferbloat.net
>>> https://lists.bufferbloat.net/listinfo/starlink



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