this doesn't make sense to me. The ISS can go as low as 360km before they 
get a boost back to a higher orbit, but the starlink satellites they are denying 
will all be lower than that (and worst case, they can force SpaceX to pay for a 
few additional reboost missions over the next 6 years before they deorbit it)

but they would avoid the thousands of satellites going up and down through the 
ISS orbit range to get to their ~550km orbit/

David Lang

On Wed, 13 Mar 2024, the keyboard of geoff goodfellow via Starlink wrote:

> Date: Wed, 13 Mar 2024 18:59:59 -0700
> From: the keyboard of geoff goodfellow via Starlink
>     <starlink@lists.bufferbloat.net>
> Reply-To: the keyboard of geoff goodfellow <geoff@iconia.com>
> To: Starlink <Starlink@lists.bufferbloat.net>
> Subject: [Starlink] FCC Denies Starlink Low-Orbit Bid for Lower Latency	(Mark
>     Harris)
> 
> *Agency says SpaceX craft could hinder International Space Station*
> EXCERPT:
>
> The FCC has once again rejected a Starlink plan to deploy thousands of
> internet satellites in very low earth orbits (VLEO) ranging from 340 to 360
> kilometers. In an order published last week, the FCC wrote: “SpaceX may not
> deploy any satellites designed for operational altitudes below the
> International Space Station,” whose orbit can range as low as 370
> kilometers.
>
> Starlink currently has nearly 6000 satellites orbiting at around 550
> kilometers that provide internet access to over 2.5 million customers
> around the world. But its service is currently slower than most terrestrial
> fiber networks, with average latencies (the time for data to travel between
> origin and destination) over 30 milliseconds at best, and double that at
> peak times.
>
> *“If you fill that region with tens of thousands of satellites, it would
> put an even bigger squeeze on them and really compromise your ability to
> service the space station.”*
>
> —HUGH LEWIS, UNIVERSITY OF SOUTHAMPTON, U.K.
>
>
> “The biggest single goal for Starlink from a technical standpoint is to get
> the mean latency below 20 milliseconds,” said Elon Musk at a SpaceX event
> in January. “For the quality of internet experience, this is actually a
> really big deal. If you play video games like I sometimes do, this is also
> important, otherwise you lose.”
>
> The easiest way to reduce latency is to simply shorten the distance the
> data have to travel. So in a February letter, SpaceX pleaded with the FCC
> to allow its VLEO constellation: “Operating at these lower altitudes will
> enable SpaceX to provide higher-quality, lower-latency satellite service
> for consumers, keeping pace with growing demand for real-time
> applications.” These now include the military use of Starlink for
> communications in warzones such as Ukraine.
>
> Starlink also argued that its VLEO satellites would have collision
> probabilities ten times lower than those in higher orbits, and be easier to
> deorbit at the end of their functional lives.
>
> But the FCC was having none of it. The agency had already deferred VLEO
> operations when it licensed Starlink operations in December 2022, and used
> very similar languages in its order last week: “SpaceX must communicate and
> collaborate with NASA to ensure that deployment and operation of its
> satellites does not unduly constrain deployment and operation of NASA
> assets and missions, supports safety of both SpaceX and NASA assets and
> missions, and preserves long-term sustainable space-based communications
> services.”
>
> Neither the FCC nor SpaceX replied to requests for comment, but the
> agency’s reasoning is probably quite simple, according to Hugh Lewis,
> professor of astronautics at the University of Southampton in the U.K. “We
> don’t understand enough about what the risks actually are, especially
> because the number of satellites that SpaceX is proposing is greater than
> the number they’ve already launched,” he says...
>
> [...]
> https://spectrum.ieee.org/starlink-vleo-below-iss
>
>