Low Earth Orbit (LEO) Satellite Feasibility Report
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Summary
The Low Earth Orbit (LEO) Satellite Feasibility Report, a December 2023 report to the Legislature by the Washington State Broadband Office pursuant to Chapter 474, Laws of 2023, SB 5200, prepared for the Washington State Department of Commerce by the consultant Guidehouse. The executive summary states that the NTIA allocated Washington approximately $1.23 billion through the BEAD Program and that the cost of deploying fiber to all unserved and underserved locations exceeds that funding by at least $500 million. It reports per-location infrastructure estimates for Starlink's BEAD offering of $3,750 to $5,000, against fiber costs ranging from $3,234 to $31,486 depending on the county. The report notes that LEO is not considered a reliable broadband service in the BEAD NOFO and closes with Table 4, ranking counties by average cost per broadband serviceable location.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Low Earth Orbit (LEO) Satellite Feasibility Report.”
Original at app.leg.wa.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-commerce-reports-leo-satellite-report-final-e550d3eb-fc3b-4b1e-b4e4-60/
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Low Earth Orbit (LEO)
Satellite Feasibility Report
Pursuant to Chapter 474, Laws of 2023, SB 5200. Sec. 1037 (2023)
December 2023
THE WASHINGTON STATE
BROADBAND OFFICE (WSBO) Report to the Legislature
Director Mike Fong
v3.4
Acknowledgments
Washington State Department of Commerce
Mark K. Barkley, Assistant Director
Dave Pringle, Director of Government Affairs and
Policy
Buck Lucas, Policy and Communications
Washington State Broadband Office
Mark Vasconi, Director
Erika Henry, Deputy Director
Devin Proctor, Policy and Communications
Manager
Connie Rivera, Broadband Infrastructure and
Finance Manager
Jason Freeze, Broadband Infrastructure Programs
Manager
Chelsea Bagwell, Broadband Infrastructure
Specialist
Sean Ardussi, Strategic Planning Manager
Brittany Pouley, Digital Equity and Broadband
Planner
Jeff Rasmussen, Broadband Engagement
Coordinator
This study was prepared for the Washington State Department of
Commerce by Guidehouse, a third-party consultant under the direction
and oversight of the Washington State Department of Commerce-State
Broadband Office. The content and recommendations reflect the views
of the Washington State Department of Commerce and the State
Broadband Office.
1011 Plum St. SE
P.O. Box 42525
Olympia, WA 98504-2525
www.commerce.wa.gov
For people with disabilities, this report is available on
request in other formats. To submit a request, please
call 360-725-4000 (TTY 360-586-0772)
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 2
2.0
Table of Contents
Key terminology........................................................................................................................................... 4
Executive Summary ..................................................................................................................................... 5
Introduction ................................................................................................................................................. 8
Market analysis ......................................................................................................................................... 11
Cost comparison ....................................................................................................................................... 17
Areas for consideration.............................................................................................................................. 19
Appendix A: ............................................................................................................................................... 23
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 3
Key terminology
Broadband; Broadband Service: The term “broadband” or “broadband service” has the meaning given the
term “broadband internet access service” in Section 8.1(b) of title 47, Code of Federal Regulations,
meaning it is a mass-market retail service by wire or radio that provides the capability to transmit data to
and receive data from all or substantially all internet endpoints, including any capabilities that are incidental
to and enable the operation of the communications service, but excluding dial-up internet access service.
This term also encompasses any service that the Federal Communications Commission (FCC) finds to be
providing a functional equivalent of the service described in the previous sentence. 1
Broadband Serviceable Location (BSL): A business or residential location in the United States at which
fixed broadband internet access service is, or can be, installed. 2
Extremely High Cost per Location Threshold (EHCT): The extremely high-cost threshold is a Broadband,
Equity, Access, and Deployment (BEAD) Program subsidy cost per location to be established and utilized
during the program's subgrantee selection process. Although BEAD prioritizes projects designed to provide
fiber to the end user, the state may decline to select a proposal that exceeds the EHCT if using an
alternative technology that meets the BEAD Program's technical requirements would be less expensive. 3
High-Cost Area: As defined by the National Telecommunications and Information Administration (NTIA),
constitutes an unserved area in which the cost of building out broadband service is higher, as compared
with the average cost of building out broadband service in unserved areas in the United States,
incorporating factors that include: (1) the remote location; (2) the lack of population density; (3) the unique
topography; (4) a high rate of poverty; or (5) any other factor determined by the NTIA Assistant Secretary, in
consultation with the Federal Communications Commission (FCC), that contributes to the higher cost of
deploying broadband service in the area. 4
Low Earth Orbit (LEO) satellite: LEO satellites represent the next generation of satellite technology that
provides a low-latency (fast connection with minimal delay), high-speed connection, supporting real-time
communication. 5 They operate anywhere from 311 miles to 1,243 miles above the Earth's surface - much
lower than traditional geostationary (GEO) satellites or medium earth orbit (MEO) satellites. Like traditional
satellites, LEO satellites function by transmitting wireless signals using "bands" of spectrum (i.e., radio
frequencies) between a satellite in LEO and a dish positioned to pick up that signal. LEO satellite internet
does not rely on wired infrastructure to operate and requires only an electrical connection and Wi-Fi
modem. Today, the primary intention of LEO satellite is to serve communications markets. 6
Reliable Broadband Service: broadband service that the Broadband DATA Maps show is accessible to a
location via: (i) fiber-optic technology; (ii) cable modem/hybrid fiber-coaxial technology; (iii) digital
subscriber line (DSL) technology; or (iv) terrestrial fixed wireless technology utilizing entirely licensed
spectrum or using a hybrid of licensed and unlicensed spectrum. The list of technologies notably excludes
satellite service, including that delivered by LEO satellite technology. 7
1 Broadband Breakfast, "LEO Technology Could Connect the Unconnected, Although Capacity Questions Remain," (2022),
https://broadbandbreakfast.com/2022/12/leo-technology-could-connect-the-unconnected-although-capacity-questions-remain/
2 National Telecommunications and Information Administration, "Broadband Equity, Access, and Deployment Notice of Funding
Opportunity," (2022), https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf
3 NTIA (2022)
4 NTIA (2022)
5 SES, " GEO, MEO, and LEO - How orbital altitude impacts network performance in satellite data services," (2023),
https://www.satellitetoday.com/content-collection/ses-hub-geo-meo-and-leo/
6 NTIA (2022)
7 NTIA (2022)
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 4
Executive Summary
Overview
The National Telecommunications and Information Administration's (NTIA) allocated Washington
approximately $1.23 billion in federal broadband infrastructure funding through the Broadband, Equity, Access,
and Deployment (BEAD) Program. The intent of the BEAD program is to achieve universal broadband access
and equitable build-out of last-mile broadband infrastructure, prioritizing areas of the state that are currently
unserved or underserved. This is no easy task. Analysis by the Washington State Broadband Office (WSBO)
finds that the cost of deploying high-speed fiber technology to all unserved and underserved locations exceeds
available BEAD funding by at least $500 million. 8
NTIA's recently published National Broadband Availability Map (NBAM) high-cost threshold tool estimates that
the investment cost of deploying fiber to all unserved and underserved locations in Washington exceeds the
state's BEAD allocation by $624.1 million, an even bigger potential gap. In these areas, the high cost of
installing fiber infrastructure and low anticipated revenue are barriers to broadband deployment. In turn, these
high-cost locations may instead be better served by alternative broadband technologies, such as fixed wireless
or satellite, depending on the context.
This report explores the feasibility of one such alternative deployment option, Low Earth Orbit (LEO) satellite
technology, as a potential solution to provide high-speed broadband access for residents living in these areas.
What is Low Earth Orbit (LEO) satellite technology?
LEO satellites are an emerging technology that offers higher speeds and faster response times (lower latency)
than traditional geostationary (GEO) satellites. LEO satellites operate at much lower altitudes than GEO ones,
requiring more satellites to form a "constellation" and provide global coverage. 9 SpaceX activated Starlink
service in the United States in October 2020 and now operates internationally. It is currently the only LEO
broadband service provider in the U.S. and operates in Washington. Amazon's Project Kuiper recently launched
their prototype satellites to start building their network, but it is not operational yet. 10 LEO offers key
advantages to GEO satellites or fixed terrestrial broadband technology in remote areas with low density and
challenging topography. It can be quickly and flexibly deployed to areas of the state that lack connectivity and
can support network resilience in emergency management contexts.
Key findings impacting Washington broadband infrastructure plans:
Applicability of LEO within BEAD implementation
LEO satellite technology has made significant advances in recent years, and there are promising examples
of its use in Washington. This technology should be considered in conjunction with other broadband
access technologies as part of the state's strategy to achieve universal broadband access.
LEO satellite technology is presently not considered a reliable broadband service in the BEAD Notice of
Funding Opportunity (NOFO).
8 Department of Commerce, "Internet for All in Washington - Five Year Action Plan for Broadband Equity, Access, and Deployment,"
(2023), https://deptofcommerce.app.box.com/s/yr03ll1kw1rpd7x4w4wk0z5g6gdah90n
9 TLGS Consulting Group, " LEO-Satellite Constellations: The Future of High Speed Comms?" (2023),
https://tlgs.consulting/2023/07/19/leo-satellite-constellations-the-future-of-high-speed-comms/
10 The FCC approved Amazon's network in 2020 and gave the company a deadline to launch and operate 50% of its satellites no later
than July 30, 2026. More information can be found at: https://docs.fcc.gov/public/attachments/FCC-20-102A1_Rcd.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 5
Therefore, LEO satellite BEAD applications will only be considered after applications from reliable
alternative technologies (such as licensed, fixed wireless) are reviewed. The WSBO will be able to select
alternative technologies to fiber for any location where proposals exceed the Extremely High Cost Per
Location Threshold (EHCT). The WSBO will set the EHCT after receiving BEAD applications in mid to late
2024.
Cost comparison of fiber and LEO deployment
The current advertised price point does not reflect the network infrastructure cost of expanding LEO
service. Current per-location infrastructure cost estimates for Starlink's BEAD offering range from $3,750 to
$5,000. 11 While this remains lower than what many end-to-end fiber costs per location will be, it is still
much higher than the $600 initial capital costs that households may be familiar with. 12
Analysis of the latest NBAM data indicates that the cost per location of deploying fiber ranges from $3,234
to $31,486, depending on the county. A Benton Institute report on deploying licensed fixed wireless
indicates that network infrastructure costs can range from $465 to $3,950 depending on rurality. 13
However, it is necessary to consider factors such as the maintenance and total cost of ownership of each
technology option as part of investment decision-making. Figure 2 illustrates this cost comparison.
In certain areas of the state where it is not cost-effective or feasible to deploy fiber, fixed wireless, or other
technologies, LEO might have a part to play in servicing high-cost locations. Figure 1 highlights preliminary
high-cost areas by county, indicated in the NBAM data, many of which are located in counties where the
average cost of fiber deployment per broadband serviceable location (BSL) exceeds $20,000.
Therefore, Washington should encourage applications from LEO providers as part of the BEAD process
and apply the EHCT as a way to stretch BEAD funds for each eligible location.
11 Starlink, "Starlink BEAD Offering to Washington," (presentation delivered 8/25/23; not published)
12 Starlink, "Order Starlink," (2023), https://www.starlink.com/
13 Benton, "Fixed Wireless Technologies and Their Suitability for Broadband," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 6
Figure 1: Average cost per broadband serviceable location, by county14 15
How these findings might evolve as Washington enters the next
phase of the BEAD process
LEO satellites will continue to be a part of the state's broadband ecosystem; however, unless its designation as an
unreliable technology is changed, its inclusion in the state's BEAD plans will be limited to special, high-cost
circumstances.
The WSBO is presently in the Initial Proposal phase of the BEAD program, which describes the competitive process the
state proposes to use to select subgrantees. The WSBO will continue to monitor reliability determinations from the NTIA
and encourage applications from all types of internet service providers when it opens its subgrantee selection process in
2024. By allowing and encouraging applications in addition to fiber, the state will give itself more options to achieve
universal access for all unserved and underserved locations with the allocated funding.
14 The National Broadband Availability Map, "WA_BSL_ProjArea," (2023)
https://experience.arcgis.com/experience/634f354d7004487a9bc6617efcde6646
15 Note: The Subgrantee Selection Tool provided in the Eligible Entity Planning toolkit offers investment cost data for unserved and
underserved BSLs in Washington. After deduplication analysis, NBAM reports 236,136 unserved and 85,433 underserved BSLs. The
Subgrantee Selection toolkit has investment cost information for only 206,101 unserved and 83,379 underserved BSLs.
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 7
Introduction
In November 2021, President Biden signed the Bipartisan Infrastructure Law (BIL), or Infrastructure Investment
and Jobs Act, into law. The BIL established more than $42 billion for broadband infrastructure investment
nationwide through the Broadband Equity, Access and Deployment (BEAD) Program. Washington's allocation
is $1.23 billion with the goal to bring high-speed broadband service to all unserved and underserved areas
statewide. Similarly, Washington has a 2028 goal to provide universal high-speed access to all homes and
businesses. However, preliminary state and federal estimates project Washington will require $500 to $600
million more to fulfill our shared goals for universal high-speed access.
The 2023 Washington State Legislature 16 required the Washington State Broadband Office (WSBO) to
undertake a feasibility study on how Low Earth Orbit satellite (LEO) may add to the state's broadband
deployment capabilities, including its intersection, if any, with BEAD. Specifically:
[The] state broadband office to study and report on the feasibility of increasing broadband access in unserved and
underserved areas of the state through low-orbit satellite networks. The study must evaluate factors such as unique
topography, lack of population density, remote location, and other considerations related to cost-effective broadband
service delivery. The study must include, at a minimum:
(a) A comparison of the estimated costs of satellite network build-out with the design and construction costs of
other broadband service infrastructure types such as fiber optic and wireless technologies in unique geographic
areas; and
(b) Identification of areas not prioritized for federal support in the five-year action plan submitted by the office in
accordance with the broadband equity, access, and deployment program funded under P.L. 117-58 (infrastructure
investment and jobs act) and recommendations for how to improve broadband service in those areas.
(2) The office must report findings and recommendations resulting from the study to the governor and the
appropriate committees of the legislature by December 1, 2023.
As part of this research, the WSBO's report explores factors that impact the cost-effectiveness of broadband
service delivery, such as topography, remoteness, and population density. The final report and analysis
conducted by the WSBO are informed by a combination of research, interviews, and quantitative analysis.
Current research on Low Earth Orbit (LEO) satellite technology and its applications is derived from academic
research papers, government reports, news articles, and industry and service providers. Representatives from
SpaceX (Starlink) and Amazon (Project Kuiper) were interviewed to understand better current and forthcoming
LEO service offerings in Washington and perspectives on how LEO service might fit into the state's broadband
infrastructure portfolio. Additionally, leaders from the Hoh Tribe in western Washington were interviewed to
learn about their experience using Starlink service. Together, this information helped to provide a baseline
assessment of LEO technology.
Additionally, this report relies on the latest Federal Communications Commission (FCC) Broadband Data
Collection (BDC) data and National Broadband Availability Map (NBAM) to assess the cost of deploying last-
mile fiber service to unserved and underserved locations in Washington. This data is supplemented by LEO
provider infrastructure cost data, when available, to conduct a comparative assessment of the costs of
alternative deployment options. This can help identify areas of the state where LEO satellite service may be
explored as a broadband access solution.
16 Chapter 474, Laws of 2023
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 8
Current state of LEO technology and applications
LEO satellite broadband technology may hold promise for further addressing internet availability gaps in
Washington, especially in remote or rural areas. With the introduction of LEO satellites, there is potential for
satellite broadband to deliver speeds closer to those that can be achieved by technologies like fixed wireless
or cable, as well as shorter response times (lower latency) than traditional GEO satellites.
However, given that commercial LEO technology development, testing, and deployment for
telecommunications is still in relatively early stages, it may not be as reliable or resilient as other broadband
technologies such as fiber. 17 Companies seek to refine LEO technology to deliver higher speeds, lower latency,
and expanded coverage. There remains much to discover and improve with LEO technology. As the state
explores the provision of broadband internet through LEO satellites, it can consider key questions facing this
new era of satellite communications. For example, will user terminals and service plan costs be competitive
with other broadband technologies' equipment and service plans, and will LEO satellite providers meet
broadband service expectations and attract many end-users
Satellite infrastructure 18
What is satellite broadband and how does it work?
Satellite internet service is provided by geostationary orbit (GEO), medium Earth orbit (MEO), or low Earth orbit
(LEO) using specific bands of radio spectrum. Not all satellite technologies can currently deliver target
minimum broadband level speeds and latency as established in the BEAD Notice of Funding Opportunity
(NOFO) -- a minimum of 100 Mbps download and 20 Mbps upload with no more than 100 milliseconds latency.
The satellite classifications are based on their orbital characteristics -- described in greater detail below.
Satellites use specific segments or "bands" of the spectrum, which are radio frequencies that transmit signals
wirelessly from one facility or device to another. 19 It works like this, "the process begins with Internet Service
Providers (ISPs) sending satellites into space to orbit around the earth. That ISP then relies on a signal routed
through one of those satellites in low- or high-Earth orbit and a receiver dish that picks up that signal. The
receiver is typically placed on one's home or business in a spot with as unobstructed access to the sky as
possible." 20 Connecting a modem to that dish will translate the incoming signal into a workable internet
connection. Electricity is also required to power the receiver dish. Unlike fixed terrestrial broadband
infrastructure, satellite internet is not dependent on cable wire infrastructure.
Geostationary satellites
"GEO satellites orbit the Earth above the equator at an altitude of 22,236 miles so that their orbital motion
exactly matches Earth's rotation." A satellite orbiting over the equator will remain above the same ground
location throughout its orbit, which is referred to as a geostationary orbit. As a result, they stay in the same
position relative to points on the earth's surface -- a useful feature for applications such as weather monitoring,
17 Congressional Research Service, "Low Earth Orbit Satellites: Potential to Address the Broadband Digital Divide," (2022),
https://crsreports.congress.gov/product/pdf/R/R46896
18 Congressional Research Service, "Low Earth Orbit Satellites: Potential to Address the Broadband Digital Divide," (2022),
https://crsreports.congress.gov/product/pdf/R/R46896
19 CTIA, "What is Spectrum? A Brief Explainer," (2018), https://www.ctia.org/news/what-is-spectrum-a-brief-explainer
20 CNET, "Wondering How Satellite Internet Works? CNET Explains," (2022), https://www.cnet.com/home/internet/satellite-internet-
explained/
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 9
communications, and surveillance. According to the FCC, broadband service from GEO satellites can offer
speeds of 25/3 Mbps to nearly the entire U.S. population." 21
Based on coverage, the top two GEO satellite providers in the U.S. and Washington are Viasat and HughesNet.
HughesNet has service plans that range in advertised download speeds from 15 Mbps to 50 Mbps and data
caps ranging from 15 GB to 200 GB. Viasat offers plans with download speeds ranging from 25 Mbps to 100
Mbps and data caps ranging from 60 GB to 500 GB. Higher speed plans are not universally available and are
priced higher than Starlink on a per Mbps basis (see Appendix Table 3 for plan information). 22
Other GEO operators include Eutelsat, Inmarsat, and Intersat. GEO satellites are typically the size of a bus. They
are large and expensive to build, but because they are more than 22,000 miles above earth, they can provide
global coverage with just a few satellites. Configuring their antennas is also relatively straightforward because
geostationary satellites move in the same direction as the earth rotates and always appear in the same
location in the sky. 23
Medium Earth orbit (MEO) satellites
Medium Earth orbit (MEO) satellites operate at altitudes between 1,242 miles to 22,236 miles, but most
satellites range between 11,200 miles to 14,900 miles above the earth's surface. 24 For example, the Global
Positioning System (GPS) constellation orbits at 12,550 miles.
Low Earth orbit (LEO) satellites
LEO satellites operate from approximately 311 miles to 1,243 miles above the earth's surface -- much lower
than GEO satellites. Because transmitted data does not have to travel as far to reach the satellite and return to
Earth, LEO satellite companies advertise and provide faster broadband speeds and lower latency than GEO
satellite service. 25 Standard Starlink plans offer speeds of 25 Mbps to 100 Mbps; priority plans offer speeds of
40 Mbps to 220 Mbps. Unlike GEO satellites, LEO satellites are constantly moving across the sky as seen from
the ground and each individual satellite is only within line-of-sight of a fixed point on earth for a period of time.
This requires hundreds or thousands of satellites to maintain coverage but may mitigate loss of coverage due
to weather or obstructions. 26 While individual LEO satellites cost less than GEO satellites, thousands are
required to provide global coverage because their beams are smaller. Therefore, the total cost of a LEO
satellite constellation is quite substantial. The typical lifespan of a LEO satellite is 7–10 years due to factors
such as atmospheric drag, the atmospheric force acting opposite to the relative motion of an object. 27
21 Congressional Research Service, "Low Earth Orbit Satellites: Potential to Address the Broadband Digital Divide," (2022),
https://crsreports.congress.gov/product/pdf/R/R46896
22 FCC, National Broadband Map, 2023, https://broadbandmap.fcc.gov/home; Viasat, Home Internet Plans,
https://www.viasat.com/satellite-internet/plans/ (accessed August 2023); HughesNet, Home Internet Plans,
https://www.hughesnet.com/get-started (accessed August 2023)
23 Internet Society, "Perspectives on LEO satellites," (2022), Perspectives on LEO Satellites - Using Low Earth Orbit Satellites for Internet
Access (internetsociety.org)
24 U.S. Space Systems Command, "LEO, MEO or GEO? Diversifying orbits is not a one-size-fits-all mission (Part 2 of 3)
25 Ookla, "New Speedtest Data Shows Starlink Users Love Their Provider," (2023), https://www.ookla.com/articles/starlink-hughesnet-
viasat-performance-q1-2023; Starlink, HughesNet, and Viasat provider websites (see Appendix Table)
26 Internet Society, "Perspectives on LEO satellites," (2022), Perspectives on LEO Satellites - Using Low Earth Orbit Satellites for Internet
Access (internetsociety.org)
27 Master Class, "What Is Atmospheric Drag? Learn How Atmospheric Drag Works and Its Impact on Space Missions," (2021),
https://www.masterclass.com/articles/what-is-atmospheric-drag
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 10
There are three primary components of a LEO system: satellites, user terminals, and ground stations. All three
components communicate with each other using federally licensed spectrum frequencies. A description of
each LEO system component is provided below:
Satellite constellation: Satellites that are launched into orbit and typically arranged into different
arrangements at different altitudes.
User terminal: Sometimes referred to as a ground terminal or simply an antenna or dish, this component
allows users to receive data from and transmit data to the satellites. LEO companies selling to consumers
may also package additional equipment with the terminal, such as a Wi-Fi router. LEO ground terminals
must be able to track and work with multiple LEO satellites within the LEO constellation.
Ground stations: Sometimes called gateways, these terrestrial radio stations connect the satellites to the
rest of the internet. LEO satellites typically need to be within range of a ground station to send or receive
data. This can limit the availability of a LEO system in a region with no ground station available. Inter-
satellite links can help to mitigate this issue. 28
Market analysis
GEO satellites have provided satellite broadband service for decades, while LEO satellite systems currently
constitute a small segment of the satellite broadband market share and an even smaller segment of the overall
broadband market. Companies such as SpaceX's Starlink, Viasat, Amazon's Project Kuiper, and EchoStar's
HughesNet are growing the LEO satellite services market and connecting new households. At the forefront of
the LEO expansion is Starlink. . According to one estimate, 50% to 70% of Starlink's base is from growing the
satellite internet market rather than taking market share from other satellite providers. 29 The 2022 American
Community Survey 5-Year Summary provides that 6% of Washington residents (183,322) currently rely on
satellite internet, an almost 10% increase since 2018. 30 There is currently no available data to determine what
percentage of that is LEO satellite service; however, based on trends, LEO satellite systems are expanding their
share. This represents a significant market opportunity given the projected growth of the satellite internet
market at a compound annual growth rate (CAGR) of 33.7% between 2023 to 2028. 31 At present, Starlink
reportedly serves more than 2 million subscribers across 60 countries. 32
Starlink is currently the only LEO operator providing residential broadband service in the U.S. This is expected
to change with the introduction of Amazon's Project Kuiper in the coming years. In 2018, the FCC approved
SpaceX’s application to use certain radio frequencies to deploy and operate 4,425 communications satellites
for Starlink. 33 In 2019, SpaceX launched the first batch of 60 functional LEO satellites and activated its beta
28 Internet Society, "Perspectives on LEO satellites," (2022), Perspectives on LEO Satellites - Using Low Earth Orbit Satellites for Internet
Access (internetsociety.org)
29 CNBC, "Investing in Space: Is SpaceX’s Starlink growing satellite internet market share, or taking it?" (2023), Investing in Space: Where
SpaceX's Starlink is growing market share (cnbc.com)
30 U.S. Census, American Community Survey 2022 and 2018 5-Year Summary Estimates, S2801 Types of Computers and Internet
Subscriptions, "Percentage of households with satellite internet service,"
https://data.census.gov/table?q=broadband&g=040XX00US53
31 Markets and Markets, "Satellite Internet Market by Orbit," (2022), https://www.marketsandmarkets.com/Market-Reports/satellite-
internet-market-139239513.html
32 Starlink, "Starlink Overview," (presentation delivered 8/25/23; not published)
33 FCC, "FCC Authorizes SpaceX to Provide Broadband Satellite Services," (2022), https://docs.fcc.gov/public/attachments/FCC-18-
38A1_Rcd.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 11
service in October 2020. 34 Amazon received approval from the FCC in 2020 to deploy 3,236 satellites for
Project Kuiper by July 2026. 35 Amazon intends to start providing beta service by the end of 2024.36
Availability
Traditional GEO satellite service is the most widely available service offering throughout the state. In terms of
coverage in Washington, FCC BDC data indicates that Viasat service is available at 99.65% of broadband
serviceable locations, HughesNet service is available at 100% of broadband serviceable locations (BSLs), and
Starlink service is available at 99.98% of locations. Despite widespread coverage, satellite represents a
relatively low broadband market share. Most (80.8%) of broadband internet subscribers in Washington are
connected via wireline technologies such as cable or fiber. 37
Affordability
Affordability of service is also a factor to consider in determining whether LEO satellite service is a sustainable
solution to bridge the digital divide. The current monthly price of LEO satellite service (such as, Starlink)
exceeds the cost of most fiber and fixed wireless plans offering comparable speeds, data, and latency.
Residential Starlink service currently ranges from $110 to $120 per month plus a one-time $600 hardware
fee.38 Although Starlink has higher startup and monthly service costs, there is no contract commitment. See
Appendix Table 3 for more details. In comparison, the price of fiber service plans ranges from $55 to $75, and
the price of fixed wireless service plans ranges from $50 to $90.39 The price of the Wi-Fi equipment is included
in the monthly service fee in most cases. This demonstrates that despite various technical advantages,
affordability may represent a concern related to LEO broadband services.
Competition
Starlink is currently the only LEO satellite provider offering residential broadband service in the U.S. market. Its
primary consumer base is residential users accessing everyday internet applications. It is available to remote
and rural locations, representing key focus areas for the BEAD Program. The features distinguishing Starlink's
LEO service from GEO satellites include lower latency, higher overall network capacity, and higher bandwidths.
In comparison, HughesNet has a lower monthly cost ($64.99–$149.99) but requires a 24-month commitment
while giving the option to rent or purchase the equipment. 40 Another distinction is that HughesNet offers the
minimum broadband level speeds for upload and download, which may dip below advertised speeds at peak
hours of usage. The number of competitors in the LEO satellite market may ultimately depend on factors such
as U.S. and foreign regulations and federal subsidies.
34 Starlink, "Starlink Overview," (presentation delivered 8/25/23; not published)
35 FCC, "FCC Authorizes Kuiper Satellite Constellation," (2020), https://docs.fcc.gov/public/attachments/FCC-20-102A1_Rcd.pdf
36 Amazon, "How Amazon's Project Kuiper is preparing for its first satellite test mission, and what we hope to learn," (2023),
https://www.aboutamazon.com/news/innovation-at-amazon/project-kuiper-prototype-satellite-test-mission
37 U.S. Census, American Community Survey 2022 and 2018 5-Year Summary Estimates, S2801 Types of Computers and Internet
Subscriptions, "Percentage of households with broadband such as cable, fiber, or DSL,"
https://data.census.gov/table?q=broadband&g=040XX00US53
38 Starlink, "Order Starlink," (2023), https://www.starlink.com/
39 Verizon, T-Mobile, CenturyLink
40 estNet, "Home Internet Plans", (2023) https://www.hughesnet.com/get-started
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 12
Example alternative applications
Beyond the provision of direct residential internet service, LEO satellites have additional applications in
multiple domains, including but not limited to disaster response, agriculture, and rural health care. Satellites
are gaining traction in Internet of Things41 (IoT) applications, such as detecting and responding to earthquakes,
fires, and floods. 42 They play a pivotal role in areas difficult to reach or evacuate quickly. Beyond disaster
response, LEO satellite-enabled sensors have additional applications for climate change research, water
management, drone surveillance, and wildlife monitoring. 43
LEO satellites also support access to everyday resources and opportunities. They are increasingly used to
provide connectivity and telemedicine services in remote areas. Unlike their GEO counterparts, LEO satellites
offer lower-latency and higher-speed communication channels, which can better facilitate the transmission of
medical data. 44 This can support improved access to healthcare, particularly for rural individuals who currently
must travel long distances to access critical medical advice or specialty consultations.
Satellite solutions can also play a key role in the agriculture industry. Given the remote nature of most
agricultural operations, satellites can represent a connectivity solution for farmers due to the portability and
longevity of associated equipment.45 More specifically, LEO satellites allow terminals with a long battery life
and portable design. This can allow for more efficient tracking of equipment and livestock using small tracking
devices, which previously may have been much more costly and required additional heavy equipment to
monitor.
Policy and regulatory landscape
Given the rise of internet adoption, e-commerce, and social media activity, modern society's bandwidth needs
and applications are vastly different from those of the recent past. The expanding market for LEO satellite
systems may address many of these modern applications and the general increase in demand for connectivity.
However, the widespread expansion of broadband internet offered through LEO hinges upon an ever-expanding
constellation of space services. These rely on radio frequency spectrum and satellite orbits—limited natural
resources increasingly in demand as radio communication services expand worldwide.46 The "space in space"
needs to be well managed to allow for its sustainability. 47
United States Federal regulations
To deploy a satellite constellation, a LEO operator, first and foremost, needs to obtain spectrum rights. The use
of spectrum (radio frequencies) is regulated to avoid interference among users. In the U.S., the FCC and the
41 "The networking capability that allows information to be sent to and received from objects and devices (such as fixtures and kitchen
appliances) using the Internet." Merriam-Webster.com Dictionary, s.v. “Internet of Things,” accessed November 21, 2023,
https://www.merriam-webster.com/dictionary/Internet%20of%20Things.
42 TS2, "The Role of LEO Satellites in Disaster Management and Emergency Response," (2023), https://ts2.space/en/the-role-of-leo-
satellites-in-disaster-management-and-emergency-response/
43 Dragonfly Aerospace, "What are Some Applications of a LEO Satellite," (2022), https://dragonflyaerospace.com/what-are-some-
applications-of-a-leo-satellite/
44 IP Access International, "LEO Satellites--Bridging Healthcare Gaps," (2023), https://www.ipinternational.net/how-satellite-
telemedicine-saves-lives/
45 Eutelsat Group, "A Revolution in IOT for Farmers," (2023), https://www.eutelsat.com/en/blog/revolution-in-iot-for-agriculture.html
46 The UN Specialized Agency for ICTs, " WRS-22: Regulation of satellites in Earth’s orbit," (2022),
https://www.itu.int/hub/2023/01/satellite-regulation-leo-geo-wrs/
47 Note: Another policy topic that is often brought up related to LEO satellite expansion is space debris. In fact, the FCC recently
adopted a new 5-Year Rule for Deorbiting Satellites in September 2022. This new rule shortens the timeframe required for satellite post-
mission disposal from 25 to 5 years. The previous rule recommended that operators with satellites in low Earth orbit ensure their
spacecraft will re-enter Earth's atmosphere within 25 years following the completion of their mission.
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 13
NTIA regulate and manage spectrum use. The FCC manages non-federal use (e.g., commercial, state, and local
government), while the NTIA manages federal use. Space services' increasing demand and complexity have
prompted the FCC to revisit current policies. Earlier this year, FCC Chairwoman Jessica Rosenworcel indicated
that the FCC will vote on new rules to "…expedite the processing of space and earth station applications
[which] will promote competition and innovation by making it easier for new companies to enter the market." 48
Funding landscape
The growth and sustainability of the LEO satellite market depends in part on the availability of public funding to
subsidize the high upfront capital investment. However, LEO satellite solutions have been excluded from
recent federal funding opportunities. This included the recent decision of the FCC to withdraw its $885 million
grant in Rural Digital Opportunity Fund (RDOF) funding to Starlink. The FCC argued that its initial decision was
"flawed as a matter of both law and policy." Although Starlink filed an Application for Review with the
Commission, its bid to connect more than 640,000 unserved locations across 35 states was rejected. 49 "The
Commission determined that these applications failed to demonstrate that the providers could deliver the
promised service. Funding these vast proposed networks would not be the best use of Universal Service Fund
dollars." The Chairwoman commented, "Starlink's technology has real promise…. But the question before us
was whether to publicly subsidize its still developing technology for consumer broadband."50
Broadband, Equity, Access, and Deployment (BEAD) Program
The BEAD program, a $42.45 billion broadband infrastructure grant program, of which Washington has been
allocated nearly $1.23 billion, funded by the Bipartisan Infrastructure Law (BIL), does not recognize LEO
internet service as 'Reliable Broadband Service', rendering it lower in priority for federal funds. The BEAD NOFO
states that for the BEAD Program, locations served exclusively by satellite services using entirely licensed
spectrum or a technology not specified by the FCC for purposes of the Broadband DATA Maps do not meet the
criteria for Reliable Broadband Service and will be considered "unserved." 51
Acknowledging that some locations may be cost-prohibitive to serve with fiber, the BEAD NOFO stipulates that
states may establish an "Extremely High Cost Per Location Threshold above which an Eligible Entity may
decline to select a proposal if use of an alternative technology meeting the BEAD Program's technical
requirements would be less expensive." 52 In these circumstances, the state can select applications for
alternative technologies deemed reliable, such as licensed fixed wireless. However, where it may not be
feasible to deploy such technologies, LEO satellite broadband services may represent a viable alternative. In
conjunction to the Extremely High Cost Per Location Threshold, High-Cost Areas, as defined by the NTIA, may
have implications on broadband technology determinations within applicable areas. The NTIA defines an area
48 Federal Communications Commission, " Chairwoman Rosenworcel Remarks to the Global Aerospace Summit," (2023), Chairwoman
Rosenworcel Remarks to the Global Aerospace Summit | Federal Communications Commission (fcc.gov)
49 Fierce Telecom, "Starlink appeals FCC denial of $885M RDOF subsidy," (2022), https://www.fiercetelecom.com/telecom/starlink-
appeals-fcc-denial-885m-rdof-
subsidy#:~:text=Last%20month%2C%20the%20FCC%20rejected,unserved%20locations%20in%2035%20states.
50 Federal Communications Commission, " FCC Rejects Applications of LTD Broadband and Starlink for Rural Digital Opportunity Fund
Subsidies," (2022), https://docs.fcc.gov/public/attachments/DOC-386140A1.pdf
51 National Telecommunications and Information Administration, "Broadband Equity, Access, and Deployment Notice of Funding
Opportunity," (2022), https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf
52 National Telecommunications and Information Administration, "Broadband Equity, Access, and Deployment Notice of Funding
Opportunity," (2022), https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 14
as "high-cost" if the cost of building out broadband service is higher than the national average cost of building
out broadband service in unserved areas. 53
As the state evaluates opportunities to use LEO satellite systems for broadband service, it is important to
consider when LEO satellites represent the optimal solution for connectivity gaps. LEO satellite technology
might be beneficial for locations where it may be difficult to install fiber or fixed wireless technologies due to
extremely high costs. Topography may also play a factor when it is challenging for a fixed wireless application
to have line-of-sight to a location. This may not be feasible in parts of the state that are bisected by mountains,
forests, or other unique, challenging terrain.
Beyond feasibility considerations, it is imperative also to consider the speed of deployment and service quality
of the internet offered through LEO satellites compared to that of alternative technologies. Regarding capacity,
fiber remains the optimal solution, as this technology type is not affected by the same capacity issues as fixed
wireless or satellite service. A benefit of deploying LEO satellite service is that residents will likely be able to
receive service relatively quickly. In comparison, fiber solutions may take years to deploy. In the interim,
satellite service may represent a stop-gap solution.
From a technical standpoint, LEO satellite solutions could be a good fit for the BEAD Program as an alternative
technology option. Current LEO technologies can meet the parameters of speed, cost, and deployment
timeline. However, the NTIA is prioritizing fiber connectivity and it is still unclear whether the federal
government will deem LEO broadband providers reliable, particularly after the recent reversal of the RDOF
subsidy for Starlink. 54
Washington case studies
Two case study applications of LEO satellite service highlight the positive impact of this technology on
delivering connections to unserved areas, especially during and after a natural disaster event.
Case Study: Malden, Washington 55
After a wildfire event destroyed most broadband infrastructure, seven Starlink satellite terminals were installed
to enable connectivity to this rural Washington town in September 2020. Firefighters utilized the terminals in
their incident command vehicles to request resources, organize daily activities and make decisions, such as
ordering helicopters for wildfire fighting activities. Residents were able to utilize terminals too.
Case Study: Hoh Indian Reservation 56
The Hoh Indian Reservation is situated in the western part of the state, approximately 23 miles south of Forks.
Broadband infrastructure availability is the primary constraint to internet access and digital equity for the tribe.
The tribe is about 70 miles away from the closest middle-mile fiber infrastructure. Since September 2020,
53 Note: Other factors include: (1) the remote location; (2) the lack of population density; (3) the unique topography; (4) a high rate of
poverty; or (5) any other factor determined by the NTIA Assistant Secretary, in consultation with the Federal Communications
Commission (Commission), which contributes to the higher cost of deploying broadband service in the area.
54 Kratos Defense, " US to Spend $42B on Broadband Equity: Will Satellite Be Included?," (2023),
https://www.kratosdefense.com/constellations/articles/us-to-spend-42b-on-broadband-equity-will-satellite-be-included
55 Government Technology, " SpaceX Connects Rural Washington Communities Via Satellite," (2020), SpaceX Connects Rural
Washington Communities Via Satellite (govtech.com)
56 Community Networks, " Starlink’s Beta Program Connects the Remote Hoh Tribe in Washington State," (2020), Starlink’s Beta
Program Connects the Remote Hoh Tribe in Washington State | Welcome to Community Networks (communitynets.org)
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 15
through a connection facilitated by the WSBO, the tribe has utilized Starlink, with no other ISPs currently
servicing the reservation.
In 2020, the Hoh Indian Reservation received LEO satellite service for reservation residents in a three-year
contract. Starlink Beta service offered a quick solution to address the broadband service gap, and the
reservation was well positioned to the satellites that Starlink had in orbit at the time. It took approximately a
month to set up the terminals. Subsequently, Starlink hosted virtual meetings to provide an overview of the
technology, set-up process, and service. Eighteen of 23 community members signed up for Starlink's Beta trial
service. The set-up process was simple and efficient, according to a Hoh Tribe representative. Funding for
Starlink's service was allocated from COVID-19 relief funding; however, exact pricing information is not
available.
The installation of Starlink terminals on the reservation has been a lifeline for residents, particularly students
and adults learning and working from home during the pandemic. In the first few weeks of service, household
speed tests indicated service levels between 58 and 65 Mbps for each household. One article stated that the
most recent speeds have achieved 179 Mbps. A stakeholder noted that Starlink was extremely helpful for her
family, especially for remote learning and work during the pandemic. Individuals depended on Starlink during
the pandemic for telehealth as well. 57
Councilmembers have indicated that they expect most residents will continue paying for the service upon
contract expiration this year. However, for low-income, unemployed and underemployed residents, the $120
monthly subscription fee may be cost prohibitive.
57 Interview with Hoh Tribe member conducted September 13, 2023.
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 16
Cost comparison
A motivation for this analysis is to help inform how the state can optimally allocate nearly $1.23 billion in BEAD
funding to achieve universal broadband service. The cost analysis included as part of Washington's BEAD Five-
Year Action Plan revealed that the cost of serving every location with fiber would exceed the state's allocation
by nearly $500 million. Similarly, the NTIA's National Broadband Availability Map (NBAM) high-cost threshold
tool estimates that the investment cost of deploying fiber to all unserved and underserved locations in
Washington exceeds the state's BEAD allocation by $624.1 million. Therefore, the state will need to determine
how to distribute funding to maximize the number of locations served by fiber while retaining enough funding
to provide service to every remaining location. The final mix of technologies may include fixed wireless and
alternative technology solutions, such as LEO satellite service.
Although costs to serve the unserved and underserved locations will ultimately be determined in 2024 during
the subgrantee selection process by internet service provider applicants, the state can begin understanding
preliminary cost estimates. The NBAM tool, while imperfect, is one of the primary analysis tools offered by the
NTIA and provides estimates for end-to-end fiber. The average estimated costs per passing, or potential end-
user connection, for each county ranges from $3,134 in Snohomish to $31,486 in Garfield (see Appendix Table
4). The WSBO anticipates some locations will require even higher amounts for end-to-end fiber; however, this
provides a starting point for the work. Fixed wireless will be a common technology that is considered if end-to-
end fiber is deemed cost-prohibitive for the location. The estimated cost per passing for fixed wireless is lower
than fiber at $465 in small towns to $3,950 in very rural areas (areas with greater density than small towns are
assumed to be even more cost-effective per passing).58 LEO satellite presents a potential alternative to fixed
wireless when fixed wireless is not technically or financially feasible. While residential pricing packages are
$600 for startups, this cost per passing is expected to increase to $3,750–$5,000 per passing due to the need
for additional infrastructure investment. 59 These are still estimates and are subject to change depending on
actual applications received during the subgrantee selection phase of the BEAD Program.
58 Benton, "Fixed Wireless Technologies and their Sustainability for Broadband Deliver," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf
59 Starlink, "Starlink Overview," (presentation delivered 8/25/23; not published)
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 17
Figure 2: Estimated cost per passing range for fiber, fixed wireless, and LEO Satellite
$40,000
$35,000 $31,486
$30,000
$25,000
Cost per passing
$20,000
$15,000
$10,000 $5,000
$3,950
$5,000
$3,750
$3,134 $465
$0
Fiber Fixed wireless LEO satellite
Technology
Ongoing costs and total cost of ownership
Ongoing operational and maintenance costs and the technological lifetime of broadband infrastructure
networks is an additional consideration when making broadband solution determinations. Although fiber has
the highest upfront capital cost, the expected typical lifetime of fiber network ranges from 20–40 years. 60 Fiber
is also future-proof, as a fiber network can easily scale speeds over time to meet the evolving connectivity
needs of households and businesses and support the deployment of new technologies. 61 In comparison, the
typical lifetime of fixed wireless networks is 10 years and the expected typical operating lifetime of a LEO
satellite is 7–10 years. 62 The operational costs for fixed wireless are greater than fiber because of the need to
replace wireless equipment. A Benton Institute report estimates that 40–80% of a fixed wireless network's
capital costs must be replaced every five years; whereas 1–10% of the capital cost of a fiber network needs to
be replaced every 10 years. 63 The annual operational and maintenance costs considered in Benton Institute's
analysis include staff, replacement, maintenance, leases, and wholesale internet for fiber and fixed wireless
networks. While the costs of leases and wholesale internet per location for fiber is uniform across density
categories, the cost of staff, replacement, and maintenance is markedly higher than fixed wireless. For
example, replacing fiber is more costly in rural areas because of the longer mileage to the premises. For fixed
wireless, the cost of replacing the equipment demonstrates the greatest variation by density category.
Table 1 compares the estimated maintenance and operational costs for a fiber and a fixed wireless network.
60 Benton, "Fixed Wireless Technologies and their Sustainability for Broadband Deliver," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf; The Fiber Optic Association, Inc., "Q&A from FOA Readers," (2023), Fiber
FAQs - Frequently Asked Questions - The Fiber Optic Association (thefoa.org)
61 National Telecommunications and Information Administration, "Broadband Equity, Access, and Deployment Notice of Funding
Opportunity," (2022), https://broadbandusa.ntia.doc.gov/sites/default/files/2022-05/BEAD%20NOFO.pdf
62 Congressional Budget Office, " Large Constellations of Low-Altitude Satellites: A Primer," (2023),
https://www.cbo.gov/publication/59175
63 Benton, "Fixed Wireless Technologies and Their Sustainability for Broadband Delivery," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 18
Table 1: Annual operations and maintenance cost comparison (ongoing cost per
location)64 65
Density Fiber Fixed wireless
Very low density rural $710 to $1690 $955 to $1,440
Low density rural $710 to 1690 $655 to $1,140
Medium density rural $44 to $880 $510 to $1,000
Small town $240 to $570 $170 to $495
There is minimal information available related to the operational costs of a LEO satellite constellation.
Operating a satellite constellation includes the cost of the software used to control and monitor the satellite
constellation. One estimate suggests that this cost ranges from $500,000–$1 million per satellite per year. 66
The per-unit operational cost may decline as more efficient constellation management systems are developed.
Areas for consideration
This analysis explores the areas of the state where it may not be economically conducive to building fiber
networks due to geographic remoteness or low population density. In these areas, alternative technologies
such as LEO satellite service or fixed wireless may be more cost-effective to deploy. This analysis may need to
be refined after the challenge and subgrantee selection processes of the BEAD program are completed, as the
number of eligible unserved and underserved locations will likely be updated.
The NTIA NBAM indicates that there are more than 320,000 (230,000+ unserved and 85,000+ underserved)
unserved and underserved locations in Washington (FCC BDC data as of 9/26/23)..67 The BEAD Program is
designed on the premise that all unserved and underserved will be addressed through BEAD funding. To
achieve universal access, the state must determine which areas should be prioritized for fiber build-out and
which areas may be more cost-effectively served by fixed wireless or another technology like LEO satellite
service. The analysis of the cost per passing of different technology types indicates that NTIA-defined, high-
cost areas may present opportunities for the state to explore alternatives to fiber.
Approximately 15,000 unserved and underserved locations are within high-cost areas in Washington, primarily
in the eastern regions of the state. Figure 3 depicts the geographical distribution of high-cost areas. These
areas are likely to have higher than average fiber deployment costs due to factors such as low population
density and unique topography. This may necessitate using alternative technologies to maintain the economic
64 Benton, "Fixed Wireless Technologies and Their Suitability for Broadband," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf
65 Note: Benton Institute paper defined very low density as 2,399 passings, at five homes per mile; low density as 2,445 passings, at 9
homes per mile); medium density as 2,279 passings, 15 homes per mile; small town (not defined)
66 Space News, "What could happen to the LEO broadband constellations?" (2021), https://spacenews.com/op-ed-what-could-happen-
to-the-leo-broadband-
constellations/#:~:text=Operating%20the%20constellation%20requires%20sophisticated,million%20per%20satellite%20per%20year
67 Note: This figure is before any adjustment for duplication of locations that are already subject to enforceable commitments to
provide service, and which are either in the planning or construction phase. The Subgrantee Selection Tool provided in the Eligible Entity
Planning toolkit offers investment cost data for unserved and underserved BSLs in Washington. After deduplication analysis, NBAM
reports 236,136 unserved and 85,433 underserved BSLs. The Subgrantee Selection toolkit has investment cost information for only
206,101 unserved and 83,379 underserved BSLs.
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 19
viability of the BEAD Program. The state should solicit and consider projects of all technology types in these
regions. Fiber applications should still be accepted and considered, given the program's goal to maximize fiber
deployment wherever feasible. Nonetheless, these high-cost areas will require additional consideration during
the subgrantee selection process, allowing the WSBO to select the technology type that maximizes the impact
of Washington's BEAD funds.
Figure 3: NTIA-Defined high-cost areas 68
Although preliminary high-cost areas identified by the NTIA Extremely High-Cost Threshold tool indicate the
locations that should be considered for alternative technologies, other costly areas above the estimated
average cost per passing, or potential end-user connection, should also be considered. To gain additional
insight into these regions, the average investment cost per BSL was considered by county, as illustrated in
Appendix Table 4. The areas highlighted as costly tend to overlap with the areas outlined in Table 3, above. For
example, Garfield County has the highest estimated average cost per BSL and the entire county, excluding
Pomeroy, is considered a high-cost area by the NTIA. However, based on average costs per BSL, costly areas
68 The National Broadband Availability Map, "High-Cost Areas," (2023)
https://experience.arcgis.com/experience/634f354d7004487a9bc6617efcde6646
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 20
exist outside of these high-cost areas. Asotin, Douglas, and Walla Walla counties do not contain high-cost
areas but have average costs per BSL exceeding $15,000 (see Figure 4). See Appendix Table 4 for more
details. The WSBO can take a similar approach to assess these areas during the subgrantee selection process,
which will occur in 2024.
Figure 4: Average cost per BSL by county 69 70
Within identified areas where fiber deployment may not be feasible due to costs, the state could consider the
topographical features to determine if locations will be best served by fixed wireless or LEO satellites. For
example, fixed wireless service may perform poorly in areas with significant obstructions such as hills,
buildings, trees, and other features that block the signal between a service location and a nearby radio tower. 71
69 The National Broadband Availability Map, (2023) National Broadband Availability Map | National Telecommunications and
Information Administration (ntia.gov)
70 Note: Note: The Subgrantee Selection Tool provided in the Eligible Entity Planning toolkit offers investment cost data for unserved
and underserved BSLs in Washington. After deduplication analysis, NBAM reports 236,136 unserved and 85,433 underserved BSLs. The
Subgrantee Selection toolkit has investment cost information for only 206,101 unserved and 83,379 underserved BSLs.
71 Benton, "Fixed Wireless Technologies and Their Suitability for Broadband," (2022),
https://www.benton.org/sites/default/files/FixedWireless.pdf
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 21
This can result in slower speeds and higher latency. This differs from LEO satellite service, which requires a
clear view of the sky.
This analysis provides a preliminary indication of the areas in Washington that may not be feasible to serve
with fiber while also reserving funds for all unserved and underserved locations utilizing BEAD funding. In
these areas, the WSBO should strive to solicit applications for different technology types, including LEO
satellite services. This strategy offers two key benefits. First, incentivizing bids for multiple technology types
will maximize the state's capacity to select the most cost-efficient and impactful solutions based on technical
merits. Second, this approach will allow the WSBO to optimize its extremely high-cost threshold. This is
because additional data points from various application types will support a clearer picture of the likely project
costs to serve these areas.. The WSBO will be better equipped to serve all Washington locations with high-
speed internet using the state's BEAD funds.
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 22
Appendix A:
Table 2: Satellite provider coverage
Advertised speed range
Provider Type Coverage
(download)
Viasat 72 GEO 99.65% 25–150 Mbps
HughesNet 73 GEO 100% 15–50 Mbps
SpaceX 74 LEO 99.98% Fixed
25–100 Mbps (standard)
40–220 (priority)
Mobile
5–50 Mbps (standard);
40–220 Mbps (priority)
Table 3: Provider plans and prices75
Provider Plan details Price
25Mbps
$49.99/month; $69.99 for first 3 months
60 GB of high-speed data; unlimited standard
data
50 Mbps
$69.99/month; $99.99 after first 3 months
100 GB high-speed data; unlimited standard data
75 Mbps
$99.99/month; $149.99 after first 3 months
Viasat 76 150 GB of high-speed data; unlimited standard
data
100 Mbps
$149.99/month; $199.99/month after first 3
300 GB of high-speed data; unlimited standard months
data
100 Mbps
$199.99/month; $299.99/month after first 3
500 GB of high-speed data; unlimited standard months
data
15 Mbps
HughesNet 77 $49.99
15 GB of high-speed data; No hard data limits
72 Viasat, "Home Internet Plans," (2023) https://www.viasat.com/satellite-internet/plans/;
73 HughesNet, "Home Internet Plans", (2023) https://www.hughesnet.com/get-started
74 Starlink, "Starlink Specifications," (2023), https://www.starlink.com/legal/documents/DOC-1400-28829-70
75 Note: Provider plans includes only a subset of providers advertising service availability to at least 25% of broadband serviceable
locations (BSLs) in Washington
76 Viasat, "Home Internet Plans," (2023) https://www.viasat.com/satellite-internet/plans/;
77 HughesNet, "Home Internet Plans", (2023) https://www.hughesnet.com/get-started
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 23
Provider Plan details Price
25 Mbps
$49.99 for first 6 months; $74.99 thereafter
50 GB of high-speed data; No hard data limits
25 Mbps
Fusion - combines satellite and wireless
$74.99 for first 6 months; $99.99 thereafter
technologies
100 GB of high-speed data; No hard data limits
50 Mbps
Fusion - combines satellite and wireless $149.99/month for first 6 months; $174.99
technologies thereafter
200GB of high-speed data; no hard data limits
Current: $120/month + $600/kit
Fixed BEAD middle-class affordability option:
Standard: 25-100 Mbps (download); 5–10 Mbps
(upload); latency: 25–60 ms Standard plan: $75 –$85/month (includes kit)
Priority: 40-220 Mbps (download); 8-25 Mbps
(upload); latency: 25–60 ms Per location cost of $3,750–$5,000 factors in
cost of increase satellite deployment, terrestrial
SpaceX 78
gateways, increased points of presence, state
Mobile specific enrollment portals, next gen Starlink
kits, reduced price service offering for 3 years;
Standard: 5-50 Mbps (download); 2–10 Mbps BEAD compliant reporting
(upload); latency <99 ms
Priority: 40-220 Mbps (download); 8–25 Mbps *Starlink does not currently participate in ACP
(upload); latency: <99 ms ** Starlink has no contracts or early termination
fees
T-Mobile 79 Up to 1000 Mbps (download) Plans starting $50/month
Verizon 80 300 Mbps to 1 Gbps $50–$90/month
78 Starlink, "Starlink Specifications," (2023), https://www.starlink.com/legal/documents/DOC-1400-28829-70
79 T-Mobile, "T-Mobile Internet Plans," (2023), https://www.t-mobile.com/home-internet/plans
80 Verizon, "Verizon Home Internet," (2023), https://www.verizon.com/home/internet/
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 24
Provider Plan details Price
Fiber $50–$75; Wi-Fi equipment provided with no
Lumen 81
Speeds offered: 500 to 940 Mbps monthly charge
Cable
Comcast 82 $35/month (1 year) for 100 Mbps plan
Speeds offered: 75 to1200 Mbps
Table 4: Average cost per BSL by county 83
Rank County Number of unserved and underserved BSLs Average cost per BSL
1 Garfield 696 $31,486
2 Asotin 976 $29,426
3 Douglas 1,197 $18,883
4 Walla Walla 2,637 $15,122
5 Adams 4,374 $14,448
6 Wahkiakum 219 $13,643
7 Klickitat 7,204 $12,702
8 Lincoln 7,620 $12,351
9 Ferry 3,608 $12,266
10 Columbia 2,605 $10,800
11 Grant 1,750 $10,062
12 Whitman 7,917 $9,714
13 Grays Harbor 3,150 $9,571
14 Okanogan 14,023 $9,552
15 Franklin 4,555 $9,540
16 Chelan 3,957 $9,517
17 Benton 3,921 $9,073
81 CenturyLink, "Home Internet Plans," (2023),
https://www.centurylinksavings.com/v2/?ckmid=101207&a=101615&ocid=1015949&agid=&subid=1764952795.&cpid=&cookiereset=1
&gclid=&c=109343&_gl=1*9bj3ou*_gcl_au*MTE4MzUwOTkwNS4xNjkxNzk0MjI3
82 Xfinity, "Home Internet Service, (2023), https://www.xfinity.com/learn/internet-service
83 The National Broadband Availability Map, "WA_BSL_ProjArea," (2023)
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 25
Rank County Number of unserved and underserved BSLs Average cost per BSL
18 Skamania 2,850 $8,315
19 Stevens 15,650 $7,841
20 Yakima 7,281 $7,798
21 Pacific 2,193 $7,711
22 Kittitas 9,467 $7,191
23 Pend Oreille 4,209 $6,391
24 Jefferson 5,698 $5,748
25 San Juan 1,522 $5,501
26 Lewis 16,755 $5,023
27 Cowlitz 7,184 $4,937
28 Skagit 6,923 $4,844
29 Mason 6,451 $4,638
30 Clallam 10,079 $4,481
31 King 11,904 $4,454
32 Spokane 26,373 $4,395
33 Thurston 10,217 $3,728
34 Whatcom 11,765 $3,629
35 Pierce 16,730 $3,595
36 Island 5,661 $3,322
37 Kitsap 7,066 $3,158
38 Clark 15,450 $3,135
39 Snohomish 17,640 $3,134
LOW EARTH ORBIT (LEO) SATELLITE FEASIBILITY REPORT 26
File and source
- File
- 2023_commerce-reports-leo-satellite-report-final-e550d3eb-fc3b-4b1e-b4e4-60.pdf
- Size
- 1,525,658 bytes
- SHA-256
- 9b7ef3f5f0be3b5f3867454ff058e92d0f294a4ceb1123fb37df06ecd7bc3608
- Original
- app.leg.wa.gov