Last week, SpaceX filed paperwork with the Federal Communications Commission (FCC) to have its Starlink LEO broadband satellite service to be designed as an “Eligible Telecommunications Carrier” (ETC)– i.e. a phone company. Starlink needs to be a federally blessed ETC in order to collect on FCC Rural Digital Opportunities Fund (RDOF) monies in at least seven states. Being designed a “common carrier” is no small thing and will enable Starlink to operate a value-added voice telephone service and open avenues for collecting FCC subsidies for low-income consumers.
SpaceX Starlink wanted to be designed as an ETC in Alabama, Connecticut, New Hampshire, New York, Tennessee, Virginia and West Virginia, with the potential to request status in Florida, Maryland and other states as needed, depending on the regulatory environment. The initial set of states listed are disclaiming jurisdiction over Starlink, essentially punting regulatory issues to the federal level.
Big money is at stake. SpaceX was awarded $885 million out of the $9.23 billion RDOF Phase 1 auction, with the funds distributed on a quarterly basis over 10 years. The award has caused consternation among rural broadband advocates, believing the FCC is taking too much of a risk on the Starlink satellite network and fixed wireless carriers without an established technical or business track record.
SpaceX was able to win a large chunk of the RDOF Phase 1 option by asserting it could delivery broadband speeds greater than 100 Mbps and at latencies under 30 milliseconds. The company says it has over 10,000 users participating in its beta test and has entered into service agreements with “underserved indigenous communities, first responders and schools,” with hundreds of thousands of individuals across all 50 states registering their interest on the Starlink.com website.
For telco wonks, Starlink is offering services on a common carrier basis, and asserts it is a facilities-based satellite provider, with its own fleet of satellites, “several dozen” earth stations, gateways, switching facilities, and other associated facilities. Under its FCC filing, SpaceX says it will offer voice-grade access to the public switched telephone network (PSTN) with minutes of use for local service with no additional charge to end users, access to emergency service — meaning a connection to 911 public safety access point (PSAP) dispatch center – and low-cost toll limitation services to qualified low-income customers.
Starlink voice services will be priced on a “standalone basis at rates that are reasonably comparable to urban rates.” The company is currently exploring options to the PSTN, including a white-label managed service provider (MSP). Starlink would initially use a MSP, providing connectivity to the third-party cloud service using its satellite broadband capability, with consumers having the option of using either a SIP-standard analog phone adopter or a native IP phone selected “from a list of certified models.”
Longer term, Starlink will continue to assess alternatives, including other third-party providers or “possibility developing its own proprietary solution.” The company is keeping the door open between an in-house solution that would provide a “superior” experience or offer multiple third-party solutions to introduce competition and redundancy.
Providing dial-tone during a power outage will be an interesting challenge. SpaceX says Starlink will offer a 24-hour battery backup for user equipment that will provide to make phone calls in the event of a power outage. The SpaceX Starlink satellite antenna draws a significant amount of power when delivering broadband services, so presumably the antenna would shift into an energy-conservation minimal power mode to support lifeline 64Kbps voice services plus the router and IP phone equipment through a sufficient-sized battery. Such a minimal power mode may interfere with the dish’s ability to perform self-deicing during adverse cold conditions.
One other footnote – SpaceX Starlink was/is looking for a CALEA engineer, indicating the company is/will be complying with U.S. government lawful intercept requirements.
