Copy of Data Shows Starlink Fails BEAD Eligibility

A Physics-Versus-Policy Story

Executive Summary

The Broadband Equity, Access, and Deployment (BEAD) program is not vague, aspirational policy; it is an engineering specification with teeth. A project can draw billions in federal and state dollars only if it can demonstrably satisfy three non‑negotiable performance promises:

1. Speed (Throughput) — every funded address must be able to obtain at least 100 Mbps downstream and 20 Mbps upstream whenever service is requested [1]. The requirement is per‑location, not a system‑wide average.
2. Latency (Responsiveness) — the one‑way trek from a homeowner’s laptop to the Internet and back must stay below 100 milliseconds round‑trip so video calls do not lag and cloud software remains interactive [1].
3. Staying Power — those first two metrics must remain in force for the entire 10‑year “period of performance” that BEAD assigns to Low‑Earth‑Orbit (LEO) projects [1]. Falling out of spec at any point in that decade triggers claw‑backs and penalties.

On its public website Starlink already lowers expectations: its “stated speeds… are not guaranteed” and “actual speeds may be lower … during times of high usage” [2]. The seven sections that follow unpack the physics and logistics behind that disclaimer—showing, in plain language, why Starlink fails BEAD’s tests today and why the gap will widen as the fleet rockets toward its 42 000-satellite constellation goal.

Latency: the Unbreakable Speed‑of‑Light Budget

Why the 100 ms limit matters: Above about 100 milliseconds humans start talking over one another in conference calls, cloud apps feel sticky, and gamers complain of “rubber‑banding.” Fiber and modern cable links routinely deliver 10–30 ms; BEAD already grants LEO networks a generous cushion by allowing them 100 ms.

• Geometry overhead is forever. Even at light‑speed a signal needs roughly 7 ms round‑trip just to climb 550 kilometres up to a Starlink satellite and fall back to Earth [3]. That is time no amount of engineering can eliminate.
• Hand‑off penalty every 15 seconds. Because LEO craft whip across the sky at 17,000 mph, a user terminal must “drop” one satellite and “grab” the next about every 15 seconds. Measurements by APNIC show each hand‑off injects 30–50 ms of extra delay and can spike total round‑trip time to ≈ 80 ms [3].
• Head‑room evaporates. With 80 ms already spent, only 20 ms remain for every router hop, firewall inspection, VPN tunnel, server response time, and congestion queuing on the terrestrial Internet—an impossible squeeze for many real‑world paths.

Plain‑English takeaway: Starlink starts each conversation nearly out of latency budget and bursts past the limit four times a minute during hand‑offs. The system cannot meet BEAD’s 100 ms ceiling on a sustained basis.

Throughput: Why a 500‑Mbps Pipe Cannot Fill Hundreds of Buckets

Starlink’s Beam Capacity By The Numbers

Each first‑ and second‑generation satellite can down‑link ≈ 20–25 gigabits per second, according to both SpaceX’s FCC payload tables and an independent 2024 throughput characterization by MIT Lincoln Laboratory. That pool is sliced into 48 steerable beams, leaving ≈ 500 megabits per second of usable capacity per beam after forward‑error‑correction and overhead [4][14].

Contention arithmetic you can do on a napkin

Since mid‑2023 new subscribers have arrived faster than new satellite capacity. APNIC’s audit (27 November 2024) observes that “as more users joined, this capacity had to be shared… and speed declined despite more satellites” [4]. Starlink’s own service notices echo the bottleneck, warning of “network congestion… speeds have dropped in many areas,” with many dinner‑hour speed tests registering under 10 Mbps [5].

Why “buffer‑and‑burst” tricks can’t fool NTIA NTIA’s draft Performance‑Measurement Notice requires providers to run 15‑second, multi‑stream TCP downloads twice every year for ten years. Eighty percent of the samples must score at least 80 Mbps—that is, 80 % of the BEAD tier [13]. A tiny cached file that finishes in a blink cannot satisfy a 15‑second sustained pull, and any deep buffer that tries to keep the radio pegged at 100 Mbps merely adds queueing delay—instantly breaking the 100 ms latency cap discussed above.

Final note: Because the Starship launch vehicle is not ready for production use, the more capable V3 version of Starlink satellites cannot be considered by BEAD.  When it becomes viable, it is expected to displace current satellites on a normal replacement schedule (i.e., 5 year service interval) so the improvement to performance will be seen across service areas gradually.

Plain‑English takeaway: A beam that tops out at 500 Mbps simply does not contain enough bits to hand every household a 100 Mbps slice during busy hours, no matter how clever the scheduler or cache.

Reliability & Jitter: Why Handoffs and Deep Buffers Wreck Live Apps

APNIC packet traces reveal a spike of packet loss at every 15‑second hand‑off and “deep buffers” that inject tens of milliseconds of jitter even between hand‑offs [3]. People do not complain about a raw millisecond count; they complain about experience—frozen video frames, choppy phone audio, and webpages that stop halfway. BEAD’s mandate for a “reliable, high‑quality” service exists precisely to exclude such unpredictable performance.  Starlink fails this metric.

Weather Resilience: Ku‑Band Signals Are Water Magnets

Starlink’s down‑links occupy Ku‑band frequencies. That band is famous for two things: plenty of spectrum and strong absorption by water. A May 2025 field campaign in Oulu, Finland measured 52 percent upload degradation and 38 percent download degradation during moderate rain; a heavy overcast alone shaved double‑digit percentages [6].

Why that matters: Storms and snow squalls are exactly when families depend on broadband for weather alerts, telemedicine, and remote work. Fiber strands and coaxial cables shrug off rain; Starlink’s sky‑path cannot dodge the droplets.

Life‑Cycle Math: 5‑Year Satellites vs. a 10‑Year BEAD Clock

The June 2025 BEAD Restructuring Notice pegs LEO projects to a ten‑year period of performance [1]. Starlink’s public technical sheet, however, gives each satellite a ≈ five‑year design life due to solar‑panel wear, radiation damage, and atmospheric drag [7]. Even if everything else went perfectly, a BEAD‑funded Starlink build would have to bankroll at least one full constellation refresh—rockets, launches, insurance, and licensing—halfway through its grant term.

Despite the fact that “useful life” was cleverly removed from NTIA scoring guidance, terrestrial fiber by contrast, is amortized over 20–30 years and upgrades only the endpoints.  This alone, drastically reducing TCO as compared to LEO technology and making fiber-based broadband deployment the lowest cost technology over useful life which is even higher (50+ years).

Orbital Congestion: The Cost of a 42 000‑Satellite Swarm

• Stated goal. SpaceX’s Gen‑2 FCC application seeks permission for the “deployment of up to 42 000 satellites in numerous orbital shells.” [8]
• Current traffic load. With roughly 7,500 craft already aloft, Starlink executed 24 410 collision‑avoidance burns in six months—about six corrections per satellite [9]. Each burn consumes propellant and shortens life.
• Regulatory alarm bells. A United Nations panel on space sustainability warned in December 2024 that “we will soon push the bearing capacity of prime orbits” if current launch rates continue [10].
• Built‑in attrition. In February 2024 SpaceX announced it would de‑orbit 100 aging satellites after finding a hardware vulnerability that could lead to in‑orbit failures [11].

Why BEAD should care: More satellites equal more burns, higher insurance premiums, faster replacement cadence, and a rising debris‑cascade risk that threatens all LEO assets—not just Starlink.

Space‑Weather Threats: Solar Storms Add Drag and Outages

NOAA calls the 2025 solar maximum “the most intense in two decades,” advising constellation operators to expect increased atmospheric drag, more attitude burns, and potential signal outages [12]. Starlink already lost 40 satellites to a modest geomagnetic storm in 2022 and is “pre‑emptively lowering some orbits and reserving propellant” to ride out the coming peak [12]. Every drag‑recovery burn diverts propellant from collision avoidance and accelerates end‑of‑life.

Conclusion: Adding It Up

These shortfalls arise from immutable physics—the speed of light, Ku‑band absorption, orbital mechanics—and from the mega‑constellation business model.

Starlink therefore fails every mandatory BEAD performance metric and is categorically ineligible for funding under the program as written.

 How Big Bang Broadband Can Help

State broadband offices may receive Starlink‑based grant requests just days before federal submission deadlines. Big Bang Broadband (BBB) can compress the due‑diligence cycle without sacrificing rigor:

• Rapid Technical Triage (48‑hour turnaround) — BBB benchmarks the applicant’s claimed speed, latency, and capacity against published Starlink beam budgets and NTIA’s test protocol, flagging any claim that cannot pass the 100/20/100‑ms rule of thumb.
• Risk Scoring Dashboard — We convert orbital‑mechanics, weather, and life‑cycle risks into an easy‑to‑read scorecard that aligns with BEAD’s evaluation rubric, allowing staff to defend decisions in public meetings.
• Scenario Modeling — Using real subscriber‑density data, BBB projects contention ratios five years forward, showing when and where a project will fall out of spec.
• Draft Denial & Clarification Language — We supply template language keyed to BEAD statutes and NTIA policy notices, saving legal counsel days of markup time.
• Public‑Facing FAQs — Clear, jargon‑free talking points help state offices explain denials to applicants, legislators, and local press.

Bottom line: BBB is prepared to act as a “technical SWAT team,” letting state evaluators document a Starlink proposal’s shortcomings within an estimated 48 hours per proposal.

About the Author

David J. Malfara, Sr. is CEO of Big Bang Broadband LLC and a 45‑year veteran of telecommunications engineering, network economics, and public‑interest broadband policy. He has testified as an expert witness in U.S. federal court and has served on Florida’s Local Technology Planning Team for Marion County. His prior roles include COO of TWN Communications and founder of five broadband operating companies. He is a senior member of IEEE and an active contributor to the Open XR Optics Forum.

References

1. NTIA. BEAD Restructuring Policy Notice, Appendix B (“Period of Performance”), 6 Jun 2025.

2. Starlink. Specifications — Performance (DOC‑1470‑99699‑90), accessed 14 Jun 2025.

3. Huston, G. “A Transport Protocol’s View of Starlink.” APNIC Blog, 17 May 2024.

4. Speidel, U. “Gigabit Data Rates on Starlink — What’s the Catch?” APNIC Blog, 27 Nov 2024.

5. Heming, D. “Starlink Waitlists Return, Network Congestion on the Rise.” Mobile Internet Resource Center, 21 Nov 2024.

6. Ullah, M. A. et al. “Impact of Weather on Satellite Communication: Evaluating Starlink Resilience.” arXiv 2505.04772, 7 May 2025.

7. Pultarova, T. “Starlink Satellites: Facts, Tracking and Impact on Astronomy.” Space.com, updated 4 Jun 2025.

8. SpaceX. “Application for Ku/Ka‑band NGSO License: Deployment of up to 42,000 Satellites in Numerous Orbital Shells.” FCC File No. SAT‑LOA‑20191108‑00120, Public Notice DA 19‑1493, 15 Dec 2019.

9. Pultarova, T. “Starlink Close Encounters Decrease Despite Ever‑Growing Number of Satellites.” Space.com, 15 Jan 2024.

10. Bhattacharjee, N. “Global Push for Cooperation as Space Traffic Crowds Earth Orbit.” Reuters, 2 Dec 2024.

11. Foust, J. “SpaceX to Deorbit 100 Older Starlink Satellites.” SpaceNews, 13 Feb 2024.

12. NOAA SWPC. “Cycle 25 Outlook for Satellite Operators,” press briefing & FCC ex‑parte filing, 18 Mar 2024.

13. NTIA. Draft BEAD Performance‑Measurement Policy Notice, 20 Dec 2024.

14. MIT Lincoln Laboratory. “Characterizing Throughput and Capacity in LEO Broadband Constellations.” Technical Report LL‑2024‑02, April 2024.