[Starlink] fcc NOI response due Dec 1

[Starlink] fcc NOI response due Dec 1

[Dave Taht]

We started work on a response to the FCC NOI requesting feedback as to
future broadband bandwidth requirements for the USA early this
morning.

I am unfamiliar with the processes by which Starlink was disqualified
from the RDOF?, and a little out of date as to current performance. It
is very clear they are aiming for 100/20 speedtest performance and
frequently achieving it.

A drafty draft is here, and some of the language is being toned down
by popular request. (the pre-readers were lucky! I cut the cuss-words
out) There is only one joke in the whole thing. I'm slipping!.

https://docs.google.com/document/d/19ADByjakzQXCj9Re_pUvrb5Qe5OK-QmhlYRLMBY4vH4/edit?usp=sharing

I have some starlink info contained in appendix B so far, but I would
prefer not to cite my own long term plot as I did, and  also cite
others that have a good latency measurement, I like the 15s irtt plots
I have seen gone by. If you have research about starlink you would
like me to cite in this context, please comment on the link above!

The NOI is the first link, and it helpe me, actually, to start with
the FCC commissioners' comments at the end, rather than read through
the whole thing. Not that I would not welcome more folk submitting
themselves to that...


-- 
:( My old R&D campus is up for sale: https://tinyurl.com/yurtlab
Dave Täht CSO, LibreQos

Re: [Starlink] fcc NOI response due Dec 1

[Frantisek Borsik]

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If I understand it correctly, FCC reasoning for it was that Starlink is
still kind of "risky" technology:
https://docs.fcc.gov/public/attachments/DOC-386140A1.pdf

All the best,

Frank

Frantisek (Frank) Borsik



https://www.linkedin.com/in/frantisekborsik

Signal, Telegram, WhatsApp: +421919416714

iMessage, mobile: +420775230885

Skype: casioa5302ca

frantisek.borsik@gmail.com


On Mon, Nov 27, 2023 at 4:53 PM Dave Taht via Starlink <
starlink@lists.bufferbloat.net> wrote:

> We started work on a response to the FCC NOI requesting feedback as to
> future broadband bandwidth requirements for the USA early this
> morning.
>
> I am unfamiliar with the processes by which Starlink was disqualified
> from the RDOF?, and a little out of date as to current performance. It
> is very clear they are aiming for 100/20 speedtest performance and
> frequently achieving it.
>
> A drafty draft is here, and some of the language is being toned down
> by popular request. (the pre-readers were lucky! I cut the cuss-words
> out) There is only one joke in the whole thing. I'm slipping!.
>
>
> https://docs.google.com/document/d/19ADByjakzQXCj9Re_pUvrb5Qe5OK-QmhlYRLMBY4vH4/edit?usp=sharing
>
> I have some starlink info contained in appendix B so far, but I would
> prefer not to cite my own long term plot as I did, and  also cite
> others that have a good latency measurement, I like the 15s irtt plots
> I have seen gone by. If you have research about starlink you would
> like me to cite in this context, please comment on the link above!
>
> The NOI is the first link, and it helpe me, actually, to start with
> the FCC commissioners' comments at the end, rather than read through
> the whole thing. Not that I would not welcome more folk submitting
> themselves to that...
>
>
> --
> :( My old R&D campus is up for sale: https://tinyurl.com/yurtlab
> Dave Täht CSO, LibreQos
> _______________________________________________
> Starlink mailing list
> Starlink@lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/starlink
>

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Re: [Starlink] fcc NOI response due Dec 1

[J Pan]

to be fair, starlink has made great improvement in the last few months
as shown in https://www.reddit.com/user/panuvic/ but a bit more
openness will help starlink improve further as well
--
J Pan, UVic CSc, ECS566, 250-472-5796 (NO VM), Pan@UVic.CA, Web.UVic.CA/~pan

On Mon, Nov 27, 2023 at 7:53 AM Dave Taht via Starlink
<starlink@lists.bufferbloat.net> wrote:
>
> We started work on a response to the FCC NOI requesting feedback as to
> future broadband bandwidth requirements for the USA early this
> morning.
>
> I am unfamiliar with the processes by which Starlink was disqualified
> from the RDOF?, and a little out of date as to current performance. It
> is very clear they are aiming for 100/20 speedtest performance and
> frequently achieving it.
>
> A drafty draft is here, and some of the language is being toned down
> by popular request. (the pre-readers were lucky! I cut the cuss-words
> out) There is only one joke in the whole thing. I'm slipping!.
>
> https://docs.google.com/document/d/19ADByjakzQXCj9Re_pUvrb5Qe5OK-QmhlYRLMBY4vH4/edit?usp=sharing
>
> I have some starlink info contained in appendix B so far, but I would
> prefer not to cite my own long term plot as I did, and  also cite
> others that have a good latency measurement, I like the 15s irtt plots
> I have seen gone by. If you have research about starlink you would
> like me to cite in this context, please comment on the link above!
>
> The NOI is the first link, and it helpe me, actually, to start with
> the FCC commissioners' comments at the end, rather than read through
> the whole thing. Not that I would not welcome more folk submitting
> themselves to that...
>
>
> --
> :( My old R&D campus is up for sale: https://tinyurl.com/yurtlab
> Dave Täht CSO, LibreQos
> _______________________________________________
> Starlink mailing list
> Starlink@lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/starlink

Re: [Starlink] fcc NOI response due Dec 1

[Livingood, Jason]

> I am unfamiliar with the processes by which Starlink was disqualified
from the RDOF?

RDOF Phase 1 was in 2020 and IIRC Starlink had only launched initial service in 2019 - so not much track record and probably at that time they could not have provided very dense coverage in unserved areas given the # of satellites then in orbit. 

JL 

Re: [Starlink] fcc NOI response due Dec 1

[Dave Taht]

Thank you. I think they have a pretty substantial track record now!

Vs a vs the seeming silence from many other RDOF "winners"...

On Tue, Nov 28, 2023 at 10:42 AM Livingood, Jason
<jason_livingood@comcast.com> wrote:
>
> > I am unfamiliar with the processes by which Starlink was disqualified
> from the RDOF?
>
> RDOF Phase 1 was in 2020 and IIRC Starlink had only launched initial service in 2019 - so not much track record and probably at that time they could not have provided very dense coverage in unserved areas given the # of satellites then in orbit.
>
> JL
>
>


-- 
:( My old R&D campus is up for sale: https://tinyurl.com/yurtlab
Dave Täht CSO, LibreQos

Re: [Starlink] fcc NOI response due Dec 1

[Alexandre Petrescu]

Thank you for having prepared this response.

It is a US-centric context, but it might apply everywhere else where 
fiber and satcom access are considered in competition.  Besides, the 
latency reduction priming over bandwidth increase, might be discussed in 
a 6G context as well, be that with NTN or without.

Now that the we are past the deadline, I would like to mention two other 
aspects:

- all access kinds in recent years have witnessed combined improvement 
of bandwidhts and latencies.  Within a same access kind (e.g. within 
WiFi, within Ethernet, within cellular) each increase of bandwidth was 
accompanied by a decrease of latency.  As such, it might look surprising 
to argue in favor of latency decrease at the expense of a constant 
bandwidth.  It might not happen, because traditionnaly they are combined.

- a strong argument could be made in favor of satcom over fiber in 
remote areas: satcom avoids the tangled fibers and satcom might pollute 
less than fiber; but at two conditions: satcom should have a sat exit 
strategy (more than just burning upon re-entry, maybe more recover and 
reuse, less visual pollution with maybe more paintings) and (2) satcom 
should aim at a same kind of... latency (yes, that!) that fiber aims 
at.  The 10ms that starlink aims at is way too high compared to what 
fiber access latency aims at.  IT is possible to aim at lower.

Alex

Le 27/11/2023 à 16:53, Dave Taht via Starlink a écrit :
> We started work on a response to the FCC NOI requesting feedback as to
> future broadband bandwidth requirements for the USA early this
> morning.
>
> I am unfamiliar with the processes by which Starlink was disqualified
> from the RDOF?, and a little out of date as to current performance. It
> is very clear they are aiming for 100/20 speedtest performance and
> frequently achieving it.
>
> A drafty draft is here, and some of the language is being toned down
> by popular request. (the pre-readers were lucky! I cut the cuss-words
> out) There is only one joke in the whole thing. I'm slipping!.
>
> https://docs.google.com/document/d/19ADByjakzQXCj9Re_pUvrb5Qe5OK-QmhlYRLMBY4vH4/edit?usp=sharing
>
> I have some starlink info contained in appendix B so far, but I would
> prefer not to cite my own long term plot as I did, and  also cite
> others that have a good latency measurement, I like the 15s irtt plots
> I have seen gone by. If you have research about starlink you would
> like me to cite in this context, please comment on the link above!
>
> The NOI is the first link, and it helpe me, actually, to start with
> the FCC commissioners' comments at the end, rather than read through
> the whole thing. Not that I would not welcome more folk submitting
> themselves to that...
>
>

Re: [Starlink] fcc NOI response due Dec 1

[Sebastian Moeller]

Hi Alexandre,

> On Dec 7, 2023, at 12:49, Alexandre Petrescu via Starlink <starlink@lists.bufferbloat.net> wrote:
> 
> Thank you for having prepared this response.
> 
> It is a US-centric context, but it might apply everywhere else where fiber and satcom access are considered in competition.  Besides, the latency reduction priming over bandwidth increase, might be discussed in a 6G context as well, be that with NTN or without.
> 
> Now that the we are past the deadline, I would like to mention two other aspects:
> 
> - all access kinds in recent years have witnessed combined improvement of bandwidhts and latencies.  Within a same access kind (e.g. within WiFi, within Ethernet, within cellular) each increase of bandwidth was accompanied by a decrease of latency.  As such, it might look surprising to argue in favor of latency decrease at the expense of a constant bandwidth.  It might not happen, because traditionnaly they are combined.

	[SM] Except where they are not... looking at access networks sure coming from acoustic couplers in double/triple digit Baud range over analog modems in the 56Kbps range and ISDN and DSL access latency generally decreased, but DSL already allows sub-millisecond access networks to be built (typically that was not done as interleaving resulted in considerably more robust networks). And with the roll ouf of G.INP retransmissions noticeable interleaving essentially was removed, but this resulted in downstream access speeds ranging from (to cite local numbers) 16, over 100 and 250 Mbps all operating with the same access latency (based on DSL's 4KHz "clock")... Similarly DOCSIS networks have been ramping up from single digit Mbps numbers to well beyond 1000 Mbps all with similar ~2-4ms request-grant latencies (I might be wrong here and this might only apply for DOCSIS >= 3.0, I am sure we have real experts on list that will correct anf misconception). And IMHO the same holds for GPON/XGSPON where the 8KHz request-grant clocking results in similar ~2ms access delays (in upload direction).
	So if looking from far above, sure in the course of the last 30-40 years both throughput increased and latency decreased, but once we look closer there does not really seem to be an automatic inverse proportionality between these two measures... To give an example loading a semi-trailer in NYC to the bring with harddisks and drving these to say LA will have atrocious latency but the throughput will still be decent...


> - a strong argument could be made in favor of satcom over fiber in remote areas: satcom avoids the tangled fibers and satcom might pollute less than fiber; but at two conditions: satcom should have a sat exit strategy (more than just burning upon re-entry, maybe more recover and reuse, less visual pollution with maybe more paintings) and (2) satcom should aim at a same kind of... latency (yes, that!) that fiber aims at.  The 10ms that starlink aims at is way too high compared to what fiber access latency aims at.  IT is possible to aim at lower.

	[SM] End-user fiber access is typically implemented as shared passive optical network (PON) for cost/profitability reasons and these are not orders of magnitude better than 10ms, so at 10ms satellite based-internet access will well be competitive. However personally I think we should strive for all fiber everywhere and use things like satellite internet as bridge technologies and/or emergency systems or mobile access in remote areas.  Not because going via space is not inherently impressive (and might I say cool?) but more because I assume the internet is here to stay and we are talkning about infrastructure that will be in use hopefully for decades.

Regards
	Sebastian



> 
> Alex
> 
> Le 27/11/2023 à 16:53, Dave Taht via Starlink a écrit :
>> We started work on a response to the FCC NOI requesting feedback as to
>> future broadband bandwidth requirements for the USA early this
>> morning.
>> 
>> I am unfamiliar with the processes by which Starlink was disqualified
>> from the RDOF?, and a little out of date as to current performance. It
>> is very clear they are aiming for 100/20 speedtest performance and
>> frequently achieving it.
>> 
>> A drafty draft is here, and some of the language is being toned down
>> by popular request. (the pre-readers were lucky! I cut the cuss-words
>> out) There is only one joke in the whole thing. I'm slipping!.
>> 
>> https://docs.google.com/document/d/19ADByjakzQXCj9Re_pUvrb5Qe5OK-QmhlYRLMBY4vH4/edit?usp=sharing
>> 
>> I have some starlink info contained in appendix B so far, but I would
>> prefer not to cite my own long term plot as I did, and  also cite
>> others that have a good latency measurement, I like the 15s irtt plots
>> I have seen gone by. If you have research about starlink you would
>> like me to cite in this context, please comment on the link above!
>> 
>> The NOI is the first link, and it helpe me, actually, to start with
>> the FCC commissioners' comments at the end, rather than read through
>> the whole thing. Not that I would not welcome more folk submitting
>> themselves to that...
>> 
>> 
> _______________________________________________
> Starlink mailing list
> Starlink@lists.bufferbloat.net
> https://lists.bufferbloat.net/listinfo/starlink