On May 13, 2026, SpaceX filed a letter with the Federal Communications Commission making a sweeping claim: that connectivity challenges for rural broadband have been effectively solved by Starlink, and that the FCC's High Cost program should be redirected or eliminated entirely.
SpaceX's letter states that "satellite broadband already delivers comparable performance to terrestrial broadband at competitive rates in line with the objectives of the High-Cost Program, and it will only become more capable over time."
That is a significant claim. It deserves a serious and specific examination before the FCC acts on it.
My intent here is not to dismiss satellite broadband as a technology. Starlink has demonstrated real capability and plays a genuinely important role in connecting locations where terrestrial infrastructure is difficult or impossible to deploy. But the claim that the rural connectivity problem has been effectively solved — and that $4.5 billion in annual support for terrestrial telecommunications infrastructure is therefore no longer needed — rests on assumptions that the operational record does not fully support.
Weather Performance and Operational Reliability
LEO satellite performance has historically degraded during adverse weather conditions. Heavy precipitation, high winds, and severe atmospheric events introduce signal interference that affects reliability in ways that terrestrial fiber infrastructure does not experience.
This matters more in rural America than the aggregate performance data suggests. Tornadoes, ice storms, hurricanes, wildfires, and flooding are not edge cases in rural communities. They are recurring events. And they are the conditions under which rural communities most depend on reliable communications infrastructure for emergency coordination, for public safety, for business continuity, and for the basic connectivity that keeps communities functioning when conditions are at their worst.
To be fair, Starlink has demonstrated genuine value as a recovery tool after major weather events, restoring connectivity quickly in areas where terrestrial infrastructure has been physically damaged. That capability is real and it matters. But there is a meaningful operational difference between a technology that excels at post-storm recovery and one that maintains carrier-grade performance during the storm itself.
Like all carriers, satellite providers include force majeure provisions in their service agreements. The relevant question is not contractual. It is operational. Does LEO satellite technology in its current state maintain the performance levels that rural communities depend on during the severe weather events that define the operational environment in much of rural America? The performance record suggests that question has not been fully answered.
What the SLA Actually Guarantees
Starlink's Priority plan offers a 99.9% uptime commitment. That figure sounds robust until you examine what the remedy actually is.
The credit for missing the 99.9% threshold is a fixed 20% of monthly service fees regardless of how significant or prolonged the outage is. Whether downtime barely exceeds the threshold or runs significantly longer, the remedy is the same. Weather-related outages carry additional exclusions.
A terrestrial carrier operating under tariffed obligations faces a fundamentally different accountability standard. Tariffed services carry enforceable performance requirements, complaint processes, and regulatory oversight mechanisms that have been developed over decades to protect the customers and communities that depend on them. The FCC's Section 208 complaint process, state commission oversight, and the broader Title II framework provide accountability mechanisms that no commercially offered satellite service currently operates under.
These are not comparable accountability frameworks. Treating them as equivalent for the purposes of eliminating the High Cost program would be a significant policy assumption.
The Accountability Gap
Supported terrestrial operators carry enforceable service obligations. They must respond to reasonable service requests within defined timeframes. They are subject to build mandates that require them to extend service to locations within their service territory. They cannot exit a market without regulatory process. They are accountable to the communities they serve in ways that a commercial satellite provider operating outside the regulated carrier framework simply is not.
That accountability gap is not theoretical. It is documented in public filings.
Between 2024 and 2025, Starlink Services LLC, the SpaceX subsidiary that holds carrier certifications, filed to relinquish its Eligible Telecommunications Carrier designation in multiple states including Massachusetts, Kentucky, Pennsylvania, and Utah. These are not obscure regulatory technicalities. ETC designation is what comes with universal service obligations. It is the regulatory status that requires a carrier to serve customers in its designated area, to respond to reasonable service requests, and to maintain the accountability framework that the High Cost program was designed to support.
Starlink obtained ETC designations in these states to qualify for Rural Digital Opportunity Fund support following the 2020 RDOF auction. It subsequently defaulted on its deployment commitments, had its funding authorization revoked, and then surrendered the ETC obligations that come with carrier status. The Massachusetts filing is particularly instructive, it acknowledged that Starlink had never provided any broadband, voice, or telecommunications services in that state despite holding the designation.
The pattern is clear. Starlink obtained the regulatory status needed to access federal funding, was unable to meet the deployment commitments that funding required and relinquished the service obligations when they were no longer useful.
A company that followed that path in multiple states is now recommending that the FCC eliminate the $4.5 billion program that funds the operators who obtained ETC status, met their deployment commitments, and maintained their service obligations throughout.
That context matters when evaluating the recommendation.
Broadband Is Not Communications Infrastructure
This may be the most important distinction in the entire discussion and it is the one most conspicuously absent from SpaceX's letter.
Broadband and communications infrastructure are not interchangeable terms.
A broadband connection delivers internet access. Communications infrastructure delivers something considerably broader. Voice services with carrier-grade quality and E911 compliance. Layer 2 WAN connectivity that connects business locations, healthcare facilities, schools, and government operations over private managed networks with defined performance guarantees. Metro Ethernet services that rural enterprises depend on for reliable, low-latency business operations. Private VLAN configurations that support secure multi-site connectivity for organizations that cannot operate over shared public internet infrastructure. Carrier-grade interconnection that underpins how rural telecommunications networks connect to the broader national communications system.
Consider what rural institutional customers actually depend on. A rural hospital connecting its facilities over a managed WAN needs deterministic latency, defined uptime guarantees, and a provider that is contractually accountable for performance. A school district running its network infrastructure needs carrier-grade reliability and the security configurations that managed network services provide. A rural business operating across multiple locations needs private, secure connectivity that a shared broadband service cannot replicate. A public safety answering point needs E911 infrastructure that meets federal compliance requirements.
Starlink delivers broadband. It does not deliver these services. The managed, carrier-grade business and institutional services that rural communities depend on require service levels, latency guarantees, security configurations, and accountability frameworks that consumer and business broadband tiers — satellite or otherwise — do not provide.
SpaceX's letter frames the High Cost program's purpose as solving a broadband connectivity problem. If that framing is accepted, satellite broadband may look like a reasonable substitute. But if the High Cost program's purpose is sustaining the full communications infrastructure that rural communities depend on, the equivalence claim in SpaceX's letter does not hold.
The question worth asking before the FCC acts on SpaceX's recommendation is a foundational one: was the High Cost program designed to fund broadband connectivity or communications infrastructure? The answer shapes everything about how its replacement should be evaluated.
The Commercial Interest Question
SpaceX is not a disinterested party in this proceeding. The company has a direct commercial interest in the elimination of the High Cost program. Removing $4.5 billion in annual support for terrestrial telecommunications operators changes the competitive landscape in rural markets where Starlink operates. Operators who are no longer financially viable because their support has been eliminated are operators whose customers become available to a satellite provider.
That does not make SpaceX's letter wrong. Commercial interests and good policy can align. But it does mean the FCC should evaluate the recommendation with full awareness of who is making it and why and should ensure that the operational record, not just the advocacy, drives the analysis.
Questions the FCC Should Be Asking
Rather than acting on SpaceX's recommendation directly, the FCC's High Cost proceeding would be better served by answering a series of operational questions that SpaceX's letter does not address.
Does LEO satellite technology maintain carrier-grade performance during the severe weather events that define the operational environment in rural America? What is the documented performance record during tornadoes, ice storms, hurricanes, and flooding, not under normal conditions but under the conditions that matter most?
Can satellite broadband replicate the full suite of communications infrastructure services that rural businesses, healthcare facilities, schools, and government operations depend on, including carrier-grade voice, E911 compliance, Layer 2 WAN, Metro Ethernet, and private managed network services?
What accountability framework governs satellite providers in rural markets? If a satellite provider raises prices, reduces coverage, or exits a market, what regulatory mechanism protects the rural communities that have come to depend on it? What is the enforcement path when performance falls short?
What does the ETC relinquishment pattern in multiple states tell us about the reliability of satellite providers as long-term carriers of last resort in rural markets?
And most fundamentally, if the High Cost program is eliminated or significantly reduced based on the assumption that satellite broadband is an adequate substitute, and that assumption proves incorrect, what is the path back for rural communities that have lost their terrestrial infrastructure in the interim?
What You Can Do
The FCC's High Cost NPRM is an active proceeding. The comment window is open. The record being built in this proceeding will shape rural telecommunications policy for years.
NTCA and WTA are actively engaged and filing comments on behalf of rural operators. If you are a rural broadband provider, contact your association and make sure your operational experience is part of the record.
If you represent or serve rural communities, contact your congressional representatives. The decisions being made in this proceeding affect the communities they represent.
And if you are a policymaker or industry participant following this proceeding — the questions raised here deserve answers grounded in the operational record, not in the claims of a party with a direct commercial interest in the outcome.
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