Starlink : Markets and Marketing

[RedLineTrain]

Very helpful discussion on Echostar.  Thank you.  One note about satellite TV.  Starlink could offer it, if they wished.  Just a matter of having enough birds to service it exclusively.  Not a problem in a couple of years.  Most of this business may go streaming, of course.  But I could certainly see an enduring market in some fashion for live events.

Regarding the phased array antennas, as I understand it, there is nothing inherently expensive in them.  The ingredient atoms don't cost much.   So I expect them to be dirt cheap, perhaps even in the near term.  The nice thing about Musk is that he is not afraid of designing his own silicon.  I can imagine that not many companies would wish to go that deep.  Neither OneWeb nor Airbus appear to have such teams.  Starlink his heavy with this type of skillset.

Those analysts who quote the $1k figure normally don't analyze the type of company that goes this deep on the technology.  Echostar et al. are at least two degrees removed from it.

[dondar]

Telecom services are regulated in each country, including satellite services.  There is nothing new about this territory.  Any country can ban Starlink if they want to.

Ban? No, they cannot. Eutelsat already provides this service via GEO satellites. It is called Konnect and is available in all European countries, Russia and Africa.

There is no chance that Starlink will be banned by Europe. Europe is still a market based economy and does allow competition. Europe can tax Starlink and regulate it, but they cannot ban it. And if some bureaucrat tries to ban Starlink, Elon will make them look stupid, file lawsuits everywhere, and he will probably win.

facepalm is very appropriate here.
Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

[niwax]

I do wonder where this person got his $1000 plus cost to acquire each customer for Starlink.  Is that supposed to be largely from the customer premises equipment?

And I would expect that the cost of that customer hardware will come down over time.  Way down.  Cable modems have already ridden their cost curve down for many years.  Starlink's customer equipment is only just about to start that journey.

I have seen articles and comments in online forums that phased array antennas are about $30,000 each and those are the new ones just introduced in the past year. The only entities that buy these things are airlines, the US military, government entities, etc. Many of the comments have been extremely doubtful that SpaceX and OneWeb are going to be able to get the prices down to consumer levels anytime soon.

I have no idea if this is true or not. I find it hard to believe that the parts involved cost anywhere near that amount. $30,000 probably takes into account low volume production, lots of R&D recovery, salesman commissions, etc.

But at the end of the day, I have no idea what a consumer quality phased array antenna is going to cost SpaceX on a per customer basis. I wish someone would provide us with some solid info.

Phased array can span a wide variety of devices, from beamforming wifi routers and cell phones with $1 components to massive military installations. I also would not underestimate the power of mass manufacturing. At a million units per month you don't just get learning effects but also step changes in your design - what used to be an FPGA and a circuit board can now be a custom fabbed chip, a CNC-cut part can become stamped, a 3D-printed chassis can be injection molded.

[dondar]

Usually "stop it" is best from moderators! 
Northern England, Wales, and particularly Scotland (with its wonderful islands) have lots of remote communities, and farms etc. Previous funds for connecting them have left the job quite unfinished. I suspect far from trying to exclude Starlink, existing companies will be relieved when Starlink solves this problem and allows them to walk away. Starlink will also likely do this with (little or) no state funding.
The UK has stepped to the right... the free market is being trumpeted... to deny (competition from) Starlink would be a complete joke!
Alternatively/additionally British Telecom could resell Starlink (if SpaceX agreed).

Airbus have spent ~2bln euros during 2018-2019 to "consolidate" satellite communication market by buying all kind of startups and obtaining stocks of bigger companies with the obvious scope to push out SpaceX. (there is no political, technological or immediate financial intensives for them to do that. In fact pretty much all aquisitions mean continuous money drain)
You can add another 2bln (up to 5 depending on counting) of arab money used for the same purposes during same period. ...

The group of people who control OneWeb comes from the british part of Airbus.
Airbus remains to be  the main investor of OneWeb. Period.

Any use of public money to "finance Elon Musk" will mean immediate political death of responsible politician in current British media climate.
P.S. People who won brexit exibit all signs of the "family like" behaviour. One has to be deligional to think or hope they are about "free market". They are for the "not controlled" market where they are the law.

[RedLineTrain]

How are the landing rights determined in the EU?  On a country-by-country basis?  Centralized?  One country takes the lead for each application?

Apologies for such a basic question that may have already been discussed.

[RocketGoBoom]

Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

And what indicates to you that Starlink will be banned in Europe? I don't see how they can do that legally, especially with the spotlight that Elon can bring to the situation.

[Nomadd]

Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

And what indicates to you that Starlink will be banned in Europe? I don't see how they can do that legally, especially with the spotlight that Elon can bring to the situation.

They don't have to ban it. All they have to do is not permit it. Starlink will have a geographical database of areas service is permitted, and connections won't be granted anywhere they're not allowed. I doubt if they'll just allow service to any area, other than international, that hasn't expressly permitted it.

[DistantTemple]

Usually "stop it" is best from moderators! 
Northern England, Wales, and particularly Scotland (with its wonderful islands) have lots of remote communities, and farms etc. Previous funds for connecting them have left the job quite unfinished. I suspect far from trying to exclude Starlink, existing companies will be relieved when Starlink solves this problem and allows them to walk away. Starlink will also likely do this with (little or) no state funding.
The UK has stepped to the right... the free market is being trumpeted... to deny (competition from) Starlink would be a complete joke!
Alternatively/additionally British Telecom could resell Starlink (if SpaceX agreed).

Airbus have spent ~2bln euros during 2018-2019 to "consolidate" satellite communication market by buying all kind of startups and obtaining stocks of bigger companies with the obvious scope to push out SpaceX. (there is no political, technological or immediate financial intensives for them to do that. In fact pretty much all aquisitions mean continuous money drain)
You can add another 2bln (up to 5 depending on counting) of arab money used for the same purposes during same period. ...

The group of people who control OneWeb comes from the british part of Airbus.
Airbus remains to be  the main investor of OneWeb. Period.

Any use of public money to "finance Elon Musk" will mean immediate political death of responsible politician in current British media climate.
P.S. People who won brexit exibit all signs of the "family like" behaviour. One has to be deligional to think or hope they are about "free market". They are for the "not controlled" market where they are the law.

OK you and gongora, have now provided  more information, and yes what you say is persuasive that Airbus, et al have tried to create a fortified position, where they hope to retain control and can resist Starlink.
I also agree that "free market" is likely double speak for "free for us and our friends".

However despite attempts to demonise Musk, and Tesla etc, he is working to keep his appeal wide. Also all his products end up being top quality, and usually technologically years ahead of the competition. If Starlink is resisted in the UK, then Scotland may break the log jam. They have the need, and the SNP (Scottish National Party) use issues like this to demonstrate how the current parliament makes decisions against Scotland's interest.  Also Airbus is (seen as) European, and is only partly British. There is plenty of Brexit sentiment against anything European. It remains for me hard to imagine Starlink being denied the right to operate in the UK. Delayed, yes. Denied by regularatory authorities/law etc. no.
And Nomad, refusing to licence, is banning. If SX applies for all the relevant licences, they will have to have (invent) "good" reasons not to issue them. (maybe after due process/review/delay). A lack of trade agreements could delay things, and if a US/UK trade deal excludes telecoms, I admit there is quite a risk there. (The repercussions of Brexit! Quite a surprise!)

[dcengineering]

Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

And what indicates to you that Starlink will be banned in Europe? I don't see how they can do that legally, especially with the spotlight that Elon can bring to the situation.

They don't have to ban it. All they have to do is not permit it. Starlink will have a geographical database of areas service is permitted, and connections won't be granted anywhere they're not allowed. I doubt if they'll just allow service to any area, other than international, that hasn't expressly permitted it.

I don't see how this can be true. What possible obligation would SpaceX have to geo-fence Starlink service? That doesn't make any sense. These countries or regions would need to ban or regulate access to the end user terminals and justify their decisions to do so. There is zero requirement for SpaceX to do this for them.

Seriously, what are they going to do to SpaceX if they don't geo-fence Starlink? Ban them? Fine their non-existent operations in those countries perhaps?

[gongora]

Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

And what indicates to you that Starlink will be banned in Europe? I don't see how they can do that legally, especially with the spotlight that Elon can bring to the situation.

They don't have to ban it. All they have to do is not permit it. Starlink will have a geographical database of areas service is permitted, and connections won't be granted anywhere they're not allowed. I doubt if they'll just allow service to any area, other than international, that hasn't expressly permitted it.

I don't see how this can be true. What possible obligation would SpaceX have to geo-fence Starlink service? That doesn't make any sense. These countries or regions would need to ban or regulate access to the end user terminals and justify their decisions to do so. There is zero requirement for SpaceX to do this for them.

Seriously, what are they going to do to SpaceX if they don't geo-fence Starlink? Ban them? Fine their non-existent operations in those countries perhaps?

There have been many posts like this in the Starlink threads over time, and I don't understand why they keep cropping up.
 Radio frequency transmissions are regulated world-wide.  Countries have the right to regulate the use of frequencies for communications in their territory.  The US government has obligations to regulate the behavior of US companies.  That's just the way it is, and it's not going to change because a few SpaceX fans want the company to have worldwide access.  If SpaceX just starts communicating everywhere it would be an international incident.  In countries where it's not permitted user terminals could be seized and the users arrested in some countries.  Other countries could use the full range of economic/diplomatic levers they press for such incidents, targeting US activity in their country in general, not just SpaceX activity.

[dcengineering]

Eutelsat has transparent agreement with Russia. all russian internet traffic from Konnect is routed through russian control center.
https://de.eutelsat.com/de/sites/eutelsatv2/home/news/press-releases/Archives/2011/press-list-container/eutelsat-extends-agreement-with.html
Most of the european countries (the Netherlands definitely) are the members of Eutelsat and have intimate access to the internal parts and obviously provided all necessary licensing and permits for Eutelsat to operate in Europe. Africa has access also on the permit base and the connections were (I don't know of now) subsidized by the french.

And what indicates to you that Starlink will be banned in Europe? I don't see how they can do that legally, especially with the spotlight that Elon can bring to the situation.

They don't have to ban it. All they have to do is not permit it. Starlink will have a geographical database of areas service is permitted, and connections won't be granted anywhere they're not allowed. I doubt if they'll just allow service to any area, other than international, that hasn't expressly permitted it.

I don't see how this can be true. What possible obligation would SpaceX have to geo-fence Starlink service? That doesn't make any sense. These countries or regions would need to ban or regulate access to the end user terminals and justify their decisions to do so. There is zero requirement for SpaceX to do this for them.

Seriously, what are they going to do to SpaceX if they don't geo-fence Starlink? Ban them? Fine their non-existent operations in those countries perhaps?

There have been many posts like this in the Starlink threads over time, and I don't understand why they keep cropping up.
 Radio frequency transmissions are regulated world-wide.  Countries have the right to regulate the use of frequencies for communications in their territory.  The US government has obligations to regulate the behavior of US companies.  That's just the way it is, and it's not going to change because a few SpaceX fans want the company to have worldwide access.  If SpaceX just starts communicating everywhere it would be an international incident.  In countries where it's not permitted user terminals could be seized and the users arrested in some countries.  Other countries could use the full range of economic/diplomatic levers they press for such incidents, targeting US activity in their country in general, not just SpaceX activity.

It keeps being brought up because the real world doesn't work the way you claim it does. "That's just the way it is" - No... its not. Transmissions don't care about borders and never have, that is especially true if the TX is in orbit. The ITU attempts to regulate spectrum worldwide but like all international laws and standards they are completely dependent on the cooperation of member states for enforcement.

"Countries have the right to regulate the use of frequencies for communications in their territory."

What they "have the right to do" and what they actually have the power to do are completely different things. Country X will argue one thing, country Y another and the ITU will throw up its hands and do nothing because the two are not easy to resolve. You can go watch this exact situation play itself out at the OECD over the digital tax in real time, and by "real time" I mean decades of arguing. This is firmly uncharted territory legally and politically, feel free to ask France how targeting US digital companies unilaterally worked out for them. The US didn't go after its own companies in response, it targeted French industry with massive tariffs and France decided to wait for the OECD decision instead because of it.

SpaceX already has FCC and ITU permission for the first 12,000 satellites. If countries want to block that spectrum they need a credible argument beyond "we don't like competition" and then they will need the cooperation of the ITU and then the US government on top of that. That's a completely backwards approach which will almost certainly fail and/or take a very long time to resolve.

The way to block Starlink access is through regulating or banning the sale and use of the end user terminals, not trying to control the spectrum itself.

[gongora]

It keeps being brought up because the real world doesn't work the way you claim it does. "That's just the way it is" - No... its not. Transmissions don't care about borders and never have, that is especially true if the TX is in orbit. The ITU attempts to regulate spectrum worldwide but like all international laws and standards they are completely dependent on the cooperation of member states for enforcement.

So you're saying if a Chinese or Indian or Russian company want to launch a constellation and start offering service in the U.S. without asking the FCC, that's cool because it's a free world?

[dcengineering]

So you're saying if a Chinese or Indian or Russian company want to launch a constellation and start offering service in the U.S. without asking the FCC, that's cool because it's a free world?

I'm not sure the FCC would necessarily have a problem with that, but if they did they would refuse to license the end user terminals or the US government would block their import on national security grounds or whatever. Its really no different than the Huawei ban

Attempting to force those countries or companies into geo-fencing their constellations would be a waste of time. The end user terminal is a spectrum user in and of itself, so there really isn't a need to in any case. Still, it does open up the possibility of a functional black market for these terminals in countries which really do not want Starlink to be operating.

[Lar]

I'm about as free market as they come but I understand that terminals will have some sense of where they are (they have to or they won't be able to find the right birds to talk to) and I expect that SpaceX will be required to disable operation of terminals in areas they don't have operational rights (so you can't just smuggle a terminal in and have it work) or be at risk for a lot of other business.

It's possible that the CIA might modify some terminals or something cloak and dagger but I wouldn't bank on ordinary people being able to get service if their government opposes it.

Maybe when SpaceX has a bigger yearly turn over than most governments it might be different. Maybe.

As gongora alludes to , this has been asked and answered many times already.

[ChrisWilson68]

Wouldn't it make sense to look at how it works with Iridium for a sense of how it's likely to work with Starlink?  My impression is that some countries, including Russia, make it illegal to use Iridium.  My impression is that they enforce that by arresting people they find in possession of Iridium phones.  My impression is that Iridium doesn't do anything to keep their satellites from communicating with ground equipment anywhere in the world.

I could be wrong about that, and I welcome correction from anyone with more information about how this works with Iridium.  But I would expect however it works for Iridium to be a model for how local-government regulation will work for Starlink.

[Nomadd]

So you're saying if a Chinese or Indian or Russian company want to launch a constellation and start offering service in the U.S. without asking the FCC, that's cool because it's a free world?

I'm not sure the FCC would necessarily have a problem with that, but if they did they would refuse to license the end user terminals or the US government would block their import on national security grounds or whatever. Its really no different than the Huawei ban

Attempting to force those countries or companies into geo-fencing their constellations would be a waste of time. The end user terminal is a spectrum user in and of itself, so there really isn't a need to in any case. Still, it does open up the possibility of a functional black market for these terminals in countries which really do not want Starlink to be operating.

Posting the same thing over and over isn't going to make it correct. Starlink is not going to grant connections in areas that have banned the service. There's no need to worry about illegal equipment because the system won't work there.
 I hate to be the one to break it to you, but freedom of the market, speech or anything else is not universal.

[RocketGoBoom]

It keeps being brought up because the real world doesn't work the way you claim it does. "That's just the way it is" - No... its not. Transmissions don't care about borders and never have, that is especially true if the TX is in orbit. The ITU attempts to regulate spectrum worldwide but like all international laws and standards they are completely dependent on the cooperation of member states for enforcement.

So you're saying if a Chinese or Indian or Russian company want to launch a constellation and start offering service in the U.S. without asking the FCC, that's cool because it's a free world?

It won't be the FCC that regulates the spectrum issues for a Chinese/Indian/Russian company with a constellation.

The global spectrum rules are governed by the International Telecommunication Union (ITU). Initially the rules were setup in the 1990s for two potential LEO constellations at that time which never got off the ground. Basically, the first two constellations into low earth orbit (LEO) get their choice of the best half of the spectrum. Any 3rd, 4th or 5th (etc) constellation has to be designed to work around the first two constellations if there is a conflict for spectrum. All the FCC does is regulate companies based in the USA and submits to the ITU on their behalf.

https://spacenews.com/spacex-submits-paperwork-for-30000-more-starlink-satellites/

The FCC, on SpaceX’s behalf, submitted 20 filings to the ITU for 1,500 satellites apiece in various low Earth orbits, an ITU official confirmed Oct. 15 to SpaceNews.

So a European government which has a bias against SpaceX/Starlink, because they are loyal to Eutelsat or SES or whatever, cannot deny SpaceX/Starlink the ITU approved spectrum in their European country. Once that ITU spectrum is approved for a company's constellation, that approval is global for the spectrum rights in the Ku and Ka bands.

I suspect that the theoretical SpaceX hating European country at issue could heavily tax end user service in their country. I don't think an individual EU country could ban the end user equipment because those will have to follow common EU product rules for everyone. The EU product rules for a SpaceX phased array antenna, if the EU chooses to regulate it, will be the same in all EU countries.

I suspect the primary means of slowing down SpaceX will be through taxes. But those taxes will likely need to be the same as Eutelsat charges for their Konnect satellite service. I don't think the EU could design a special tax rate for SpaceX Starlink customers which is different from Eutelsat Konnect satellite internet customers. That would be subject to challenge in court very easily.

As long as SpaceX Starlink designs their antenna and it meets common EU product rules, then SpaceX should be fine to operate in every EU country. The EU countries cannot take away or deny Starlink's spectrum if it is approved by the ITU, which is a United Nations authorized body for this purpose.

The ITU rules were updated recently in November 2019 and all that changed is the percentage of the constellation that must be launched within a certain number of years. That presents no problem based on the speed SpaceX is moving to launch satellites. In fact, the new ITU rules are an advantage for SpaceX because nobody else can launch a constellation as fast as Elon can.

[gongora]

It won't be the FCC that regulates the spectrum issues for a Chinese/Indian/Russian company with a constellation.

The global spectrum rules are governed by the International Telecommunication Union (ITU). ...

Pretty much everything you write after this point is incorrect.  Countries can't stop the constellation from existing, but they can certainly deny it landing rights in the country.  ITU priority is based on filing date, and I'm pretty sure SpaceX wasn't one of the first two.  The FCC is most definitely not following any supposed rule about two companies having priority for communications in US territory.  The FCC defined their own process for determining who would share the spectrum and has more than two companies as co-equals.  For communications into the US the first constellation in service (the definition of which is a matter of dispute right now) gets first choice of frequencies when mandatory band splitting is triggered, but they still have to split the frequencies with anyone else on equal footing with them.

and... has SpaceX actually gotten ITU approval?  They've gotten FCC approval for the 12,000 satellites.

[RocketGoBoom]

It won't be the FCC that regulates the spectrum issues for a Chinese/Indian/Russian company with a constellation.

The global spectrum rules are governed by the International Telecommunication Union (ITU). ...

Pretty much everything you write after this point is incorrect. 

That is not even remotely accurate. The way the EU regulates products is common throughout the EU. There are not separate rules for each country. You cannot write such a broad rejection of everything I wrote without providing some evidence to support your position.

Countries can't stop the constellation from existing, but they can certainly deny it landing rights in the country.  ITU priority is based on filing date, and I'm pretty sure SpaceX wasn't one of the first two.  The FCC is most definitely not following any supposed rule about two companies having priority for communications in US territory.  The FCC defined their own process for determining who would share the spectrum and has more than two companies as co-equals.  For communications into the US the first constellation in service (the definition of which is a matter of dispute right now) gets first choice of frequencies when mandatory band splitting is triggered, but they still have to split the frequencies with anyone else on equal footing with them.

and... has SpaceX actually gotten ITU approval?  They've gotten FCC approval for the 12,000 satellites.

I think you are discussing something different than what I was referring to. I am not making any point about who has actually achieved ITU approval already or who was first or second or third. However the new rules approved in November 2019 seem to favor OneWeb and SpaceX to be the first to achieve the required percentages of the constellation into orbit.

OneWeb and SpaceX are launching and nobody else seems to be on schedule to beat them in the goal of reaching the required percentages. That is why SpaceX made 20 different filings for 1,500 satellites each. SpaceX will achieve those 1,500 satellites in a certain order (batch #1 thru batch #20), therefore completing the 1,500 satellite deployment and securing spectrum rights for each ITU filing. The first 1,500 batch has already reached the 20% completion point with 300 satellites launched.

Here are the changes, which now apply to everyone that has filed for this ITU spectrum since 2011. SpaceX is clearly working a loophole in the rules by breaking up their constellation into 20 different ITU filings of 1,500 satellites each.

https://www.itu.int/en/mediacentre/Pages/2019-PR23.aspx

Filings for frequency assignments to NGSO satellite systems composed of hundreds and thousands of satellites have been received by ITU since 2011, in particular in frequency bands allocated to the fixed-satellite service or the mobile-satellite service.

Under the newly adopted regulatory approach these systems will be required to deploy 10 per cent of their constellations within two years from the end of the current period for bringing into use, 50 per cent within five years, and complete the deployment within seven years.

My point about competition in the EU is that the rules are common for the entire EU and all 27 countries. Individual EU countries cannot start making product rules only for one country. That defeats the purpose of the trade union and reducing friction in commerce.

The ITU spectrum, once approved, is not something that individual countries get to regulate either. If you go back and look at the post you responded to, I don't believe that I ever made the claim that SpaceX has already been approved for ITU spectrum. I was saying merely that individual EU countries won't be able to ban a company for that reason. And the individual EU countries won't be able to ban the end user equipment either so long as the SpaceX phased array antennas meet EU product rules. If approved by the EU, the product is legal in all 27 EU countries.

So if ITU approved spectrum rights cannot be challenged by individual countries (Fact check: TRUE) and the end user product is approved for the EU, it also cannot be denied access by individual EU countries (Fact check: TRUE) .... then what else is there for an individual country to regulate? Maybe the taxes on the monthly bill for the end user in that country. Maybe some fees to support whatever the local rules mandate.

But can an individual EU country just ignore common EU competition and product rules and arbitrarily deny SpaceX that ability operate and sell to customers in one EU country? I think not. That is an extraordinary claim to make and I think the burden is on you to support it with evidence. And secondly, why would they even want to?

[gongora]

I was mostly responding to the first part of your post, which was not EU specific.  The new constellation deployment rules still give a very long time to complete the constellation.