Comment on TTP/Sure’s Starlink paper: A Security, Political and Technical Assessment

On March 17th 2025, two presentations were given by Sure Falkland Islands in Stanley. The first was to the islands’ businesses who are members of the islands’ Chamber of Commerce, followed by a public meeting at 17:30.

The main speaker at the two presentations was Alistair Beak, Group Chief Executive Officer of Sure International. Sure International provide telecommunications services in the Isle of Man, Guernsey, Ascension Island, St Helena, Falkland Islands and Diego Garcia.

The contents of the two short presentations raised so many issues in the audience’s minds that I felt these needed to be specifically addressed.  This led to the creation of the three OpenFalklands’ posts listed below.

• Starlink in the Falklands – March 2025 – Sure’s views on Starlink in high-density regions
• Starlink Falklands Islands Internet Traffic and Argentina: The Facts
• Sure Warns of Profit Loss as Starlink Lands in the Falklands

The OpenFalklands posts above have been widely circulated among satellite engineering professionals on LinkedIn, receiving no negative feedback – only support. I continue to stand by the content of those posts. However, after reviewing the newly released report, I believe that additional statements are worth commenting on.

During the presentations, the presenter said his comments about Starlink were based on a report written by “industry satellite experts”. A member of the audience requested that Sure Falkland Islands forward a copy of that report.

A copy of the report entitled “Starlink licencing for the Falkland Islands – A Security, Political and Technical Assessment” was made available by Sure Falkland Islands on their website on the 11th April 2025. The report was written by a well-known and respected technical consultancy called The Technology Partnership (TTP) based in Royston, Hertfordshire, UK.

“After Alistair Beak’s visit in March 2025, we [are] committed to releasing an independent commissioned report on Starlink Licensing in the Falkland Islands. The paper is written by TTP, who are specialised satellite industry experts. It includes extensive technical information and offers an engaging read.”

The Cost of Compromising Objectivity

One thing that clients consistently expect from all consultancies, regardless of size, is a professional, open, and unbiased approach.

A well-known challenge in consultancy work relates to the adage, “The customer is always right.” In this context, the “customer” is the client commissioning the report. Because the client is paying for the work, there is often an implicit expectation that the findings will align with their objectives. Balancing professional objectivity and satisfying a client’s expectations can be difficult for any consultancy, but it is vital.

This is where many readers of The Technology Partnership’s (TTP) report have taken issue. The document presents a highly one-sided and overwhelmingly negative assessment of Starlink’s potential role in the Falkland Islands. Given that the report was commissioned by Sure Falkland Islands and its parent company, Sure International, such a disappointing slant might not be entirely surprising.

The bias within the report is evident not just in tone, but also in its selective technical framing and misrepresentations. At the same time, Sure is preparing to launch a new, reduced-latency service based on the OneWeb satellite constellation. Therefore, it is rather sadly reasonable to infer that the report was commissioned to undermine Starlink’s prospects, rather than offering a balanced technical analysis.

At a broader level, a fundamental principle in business, especially when presenting to clients or the public, is to avoid directly attacking competitors. This principle appears to have been disregarded entirely in this case.

The overt bias in the report reflects poorly on all stakeholders involved: TTP as the author, Sure Falkland Islands and Sure International as the commissioning parties. Such an approach is unlikely to be well received by industry peers, including OneWeb, its parent company Eutelsat, Eutelsat’s partners like Intelsat, or even SpaceX – the owner and operator of Starlink. It may also strain relationships with Sure International’s parent company, Beyon (formerly Batelco).

Sure International apparently commissioned this report to negatively influence the Falkland Islands Government’s decision-making around the licensing of Starlink. This was not only an inappropriate strategy – it seems to have backfired, potentially damaging Sure’s reputation among island residents. It has certainly not been written for individuals with little technical knowledge to read.

What is particularly frustrating is that OneWeb’s LEO service is, in its own right, an excellent product. It has a rightful place in the global satellite connectivity market, and is well-suited to meet specific needs in the Falkland Islands. It is a different offering than Starlink and is not designed to compete head-to-head in the consumer space. Given this, there was no strategic necessity to attack Starlink so aggressively in the report. Picking a fight where one isn’t needed does little to benefit any party involved.

Finally, the report also ventures into areas that fall well outside the boundaries of a technical analysis, further undermining its credibility and purpose.

Source: Statista

Technical Assertions Under Scrutiny

After reading the report, several points that required comments were identified.

Page5: “However, assuming sufficient angular separation of the satellites several satellites can serve the same cell.”

The report does not consider Starlink’s adaptive load balancing, beam steering, and capacity management, which SpaceX has already employed, as discussed in the previous post. Starlink actively manages congestion using beam-forming, adaptive polarisation, load balancing across satellites and dynamically assigning users to cells/beams based on current conditions. These are advanced technical features that are unavailable to OneWeb.

Page 5: “While this may be available on a satellite level, current terminals can only operate in one polarisation.”

This is incorrect; Starlink terminals and their satellites use simultaneous vertical and horizontal beam polarisation.

Page 6: “For this reason, Starlink had to introduce subscriber limitations per cell in order to maintain an acceptable degree of service like for instance around London and the Southeast of the UK.”

As do all ISPs.

Page 6: “Currently most households are being served by ADSL in Stanley and rural 4G both providing 15Mbps of access speed”

This is highly inaccurate when it uses the word “most” to describe the current portfolio of broadband service download speeds. The only 15Mbps package is ‘Unlimited Pro’, while the rest range from 4 to 10Mbps with unstated upload speeds of only 1Mbps, which only a very few customers have purchased due to its high cost of £320 per month.  Local users experience 4G download speeds of only around 4 Mbps down.

Page 7: “For Starlink, assuming an overall bandwidth limitation of 800Mbps per beam…”

This is not the whole picture as discussed in the previous report, so the assumptions, calculations and results will be inaccurate. Overall, the QoS technical analysis seems based on highly outdated information and misleading assumptions about Starlink’s capabilities. Starlink uses a dynamic mesh of multiple satellites and beams, where each beam can serve multiple areas and a single area can be served by multiple overlapping beams. An 800Mbps beam bottleneck is incorrect.

Page 6/7 calculations: “The Falkland Islands’ population is about 3,500 with Stanley hosting about 3,000 inhabitants and the remaining 500 inhabitants are spread out over the rest of the country (Camp and MPC). …assuming an uptake of  1,200 [Starlink terminal] households in Stanley”

Using these numbers as the basis of a QoS calculation is wrong. In the 2021 census, there were 1817 households, and looking at the number of Sure ADSL accounts in 2017, a more relevant number of ADSL accounts in 2025 to use would be 1,800 – although only Sure knows the actual number. There has only been conjecture about the percentage of households wishing to upgrade to Starlink, but this varies from 20% to 40%. Of course, this could be much higher. Using the 34% assumption in TTP’s calculations, a more realistic number would be 612, half the number used in TTP’s model. This would considerably impact the results without even considering Starlink’s advanced technologies.

Page 7: “At the telco level, uncontended service at high availability rates is standard practice, assuming some 1,000 sites across Stanley implies an access speed of less than 1 Mbps.”

Sure, Falkland Islands Intelsat’s GEO services do NOT operate at an uncontended rate, so why bring this up in this discussion? It is misleading, as no other ISP, mobile or LEO/GEO satellite operator does either. Another independent model suggests that 420 users sharing will see download speeds of 30 Mbps average per household at peak time. The claim that access speed would be “less than 1 Mbps” in a business-grade setup for 1,000 sites is not supported by real-world evidence or Starlink deployment data.

Page 9: “Another effect to consider is that LEO constellations still experience some micro-outages where data are actually lost and cannot be recovered… Whereas this issue is not a major problem for standard consumer broadband customers, it does not meet quality criteria of standard telecoms grade solutions or secure networks.

Several satellite operators, MNOs, cloud operators and telcos have tested Starlink and measured minor outages of a few seconds every 2-3 minutes. This can be acceptable for consumer broadband but does not meet telco-grade service offerings for mobile network operators, let alone secure, reliable networks.“

This can be put down to technical and service scaremongering. With Starlink’s far greater number of satellites than OneWeb, a Starlink terminal can maintain contact with several satellites simultaneously, minimising the extent of dropouts compared to OneWeb. Starlink always has 3-6 satellites overhead, while OneWeb has 1–2. Moreover, I have experienced multiple micro-outages when using the OneWeb service, so even they suffer from this well-known issue.

Page9: “Starlink service, once fully deployed, will experience significant QoS issues:

– Access speeds for consumers may be less than 2Mbps during peak.

– Telecom grade professional data services are not shared at all, would be less than 1Mbps as they require high reliability.”

This is an over-reach performance forecast of significant proportions that is not experienced even in highly congested geography like London.

Page 10: “…telecommunication and satellite networks have always been considered as strategic assets which need to be protected and regulated for a good reason to ensure the safety, sovereignty, and wellbeing of nations.

Routing Security: This has been demonstrated by a series of secure communication initiatives like lawful intercept requirements.”

Sure will also be unable to provide a lawful intercept service on their OneWeb service – Sure can provide this capability in a limited form – Horizon emails / SMS only – on their Intelsat GEO service. It’s another scaremongering issue.

Page 10: “Actual traffic measurements of Starlink satellites flying over the Falkland Islands conducted by an international satellite operator on a given day indicated that about 50% of traffic was routed via Chile, and 20% of traffic landed in Argentina.”

Where did the other 30% of Falklands’ traffic go?

Numerous Falkland Islanders, another consultancy and the CIO of the Falklands have done many traceroutes over Starlink over several months, and they have yet to find a single trace that shows traffic being routed via Argentina. All have been routed via Chile. That’s not to say traffic can’t be routed via Argentina, as it obviously can. Still, it seems incredibly rare, if happening at all and, in any event, is encrypted as all Starlink traffic is.

Page 10: “More critical scenarios include the approach of the U.S. Department of Defense (DoD) to procurement of satellite capacity from commercial suppliers. Any satellite solutions must solely terminate on US soil to prevent any enemy interference. Only as a secondary solution, operations out of allied territories are deemed acceptable.”.

How is this relevant to the commercial deployment of a commercial Starlink service in Stanley and Camp? It’s misleading at best.

Page11: “Taking a close look at Argentinian gateway locations, it is most likely that some traffic is already being routed through Argentina directly.”

Page 12: “It is reasonable to assume that a sizeable amount would be routed through Argentina.”

It was stated on page 10 that “Actual traffic measurements” had identified 20% of Falklands traffic landing in Argentina. Which is it – “likely”, “reasonable to assume” or “actual measurements”? Real experience says it is none of these.

Page 12: “Finally, it is important to note that lawful intercept of Starlink users in the Falkland Islands would not be possible if traffic was to terminate in Argentina. The Falkland Islands Government would never know what type of traffic or data is transmitted or received from Starlink terminals when traffic is being terminated outside its territory unless there are agreements on lawful intercept in place. However, this may be difficult to achieve with the current Argentinian government. In any case, lawful intercept should be an explicit licensing requirement in case the FIG would like to proceed with the licensing of Starlink.“

‘Lawful Intercept’ means that a government (with proper legal authority, such as a warrant or court order) can secretly access and monitor a person’s communications, like intercepting phone calls, messages, or internet traffic, without the target’s knowledge.

This is highly confusing and is difficult to understand. Can Sure confirm that they can provide a lawful intercept of Falklands’ traffic passing over a OneWeb terminal located in Camp? Most chat applications are encrypted these days, which limits any ISP’s ability to decode content.

Page 14: “Whereas professional telecommunications companies are equipped to deal with this [DDoS attacks] to a certain extent, this cannot be expected from a private household or small businesses. Most likely, a private household or small business would not even realise that they are being attacked until it is too late.”

Is TTP saying that a DDoS attack could target individual households or small businesses in the islands if they use Starlink? Surely not?

Page 14: “To continue receiving development aid from the US, they [countries] may need to license and allow operations of Starlink. Officially it can be communicated as a wonderful way to enable digital inclusion in developing countries, however, it prevents countries developing their own satellite and space ecosystem as existing markets for local service providers and telecoms operators are being undermined.”

This is a spurious comment as not many countries are in a position to finance or develop their own “space ecosystems”. It is an irrelevance.

Page14: “In summary, Starlink is being and will continue to be used to pressure governments to sign deals, allow licensing access of Starlink or both as it has been demonstrated in Ukraine.“

This is quite a strong accusation to make against a competitor.

Page 14: “There is significant anecdotal evidence of how Starlink specifically has been used in the past to exert pressure on governments and for political gain. At the beginning of the Ukraine-Russian war during 2023, the Starlink service was put into question whether it should be provided and according to unconfirmed reports”.

This is an incorrect and wholly inappropriate statement – “anecdotal evidence” has no place in this report. “Anecdotal comment” is not “evidence”. The claim that Starlink can be “turned off” in Ukraine originates from an incident in which the Ukrainian government criticised the company for not providing coverage in Russian-occupied territories. Starlink declined this request, citing concerns that doing so would violate U.S. sanctions against Russia. This situation has since evolved into a narrative suggesting that Starlink access can be arbitrarily controlled at Elon Musk’s discretion. This interpretation is misleading. Musk has publicly reiterated that Starlink will not be used as a tool for political leverage. A Wikipedia overview.

Page 16: “Finally, Starlink has emerged as an opportunistic model rather than a core priority or Space X. The main purpose remains to colonise Mars and to use any additional cash flow to finance this mission including Starlink:“

An “opportunistic business” pursues short-term gains by capitalising on immediate opportunities, often without a long-term strategic plan or consistent values. Starlink is undoubtedly NOT an “opportunistic” business by any measure used.  I’m not sure how to react to a statement about “Mars” being SpaceX’s primary objective in a professional technical report, as it is well beyond the objective knowledge of the authors.

Page 16: “SpaceX is heavily subsidized by US taxpayers“

As is OneWeb by the UK Government to the tune of £400m – are TTP unaware of this?

Page 16: “In order to provide a reliable, secure network a multi-orbit approach including GEO and LEO is recommended. A combination of classic GEO connectivity, amplified by alternative professional LEO constellations like OneWeb would provide the best of both worlds. Viasat estimates that only 10% of global IP traffic is actually latency sensitive, as about 58% is accounted for by Video streaming. Therefore, using a classic GEO solution is still appropriate in most instances “.

It is not just about latency. Can GEO satellites deliver UHD video services over GEO satellites today?

Page 17: “Additionally, 5G backhaul solutions enabling shared access platforms feeding local towers could provide a seamless end user experience at superior quality of service whilst enabling lawful intercept.“

This is the only visionary statement in the document, but talking about 5G services in Stanley is not pertinent to this report.

Page 17: Regarding the “Overall Conclusions and Recommendations” section, it focuses on irrelevant negative aspects. There are no “Recommendations”. If there were any, they have been redacted for this public version.

Page 18: One source quoted for the technical aspects of this report is “A Technical Comparison of Three Low Earth Orbit Satellite Constellation Systems to Provide Global Broadband”.

This is a rather old book as it was published in 2019. However, given the rapid advancements in satellite broadband technologies, such as those adopted by Starlink, since its publication, some of its content will now be outdated. There are several more up-to-date reference materials available in 2025.

Page 18: The second source quoted is “Digital Divide: Telespazio and Altec Announce Strategic Collaboration to Connect Schools in the Patagonian province of Rio Negro.“

Why is this referenced, as it is a press release concerning Argentina? This details a partnership between Telespazio, an international space services company, and Altec, an Argentinian technology firm, aimed at enhancing internet connectivity in remote areas of Río Negro, Argentina.

Conclusions

The report produced by The Technology Partnership (TTP), commissioned by Sure Falkland Islands and Sure International, lacks the objectivity expected from a professional consultancy. Its highly negative stance on Starlink suggests it was written to support the probable client’s commercial interests rather than to provide a balanced and technically sound analysis. I would have expected the report to look at the strengths and weaknesses of both solutions, which hasn’t happened here.

The publication of this report has damaged the credibility of TTP, and in fact, Sure itself, for promoting the report. In consultancy, impartiality is everything. When that is lost, so is trust – especially among technical experts, industry stakeholders, and the public. In this case, the strategy seems to have backfired, with many Falkland Islands’ readers seeing the report as an unprofessional attempt to influence government decision-making and public opinion.

Rather than promoting OneWeb on its own strengths, the report focused on discrediting Starlink. This was a missed opportunity. OneWeb is a solid product in its own right and could have been positioned as a complementary or alternative service without the need to attack a competitor. Unfortunately, the tone and approach of the report imply weakness rather than confidence.

Promoting a flawed and biased report also raises concerns about internal standards at Sure and TTP. It goes against the principle that professionals – especially in highly technical fields – should never disparage competitors in front of clients or customers. This has likely caused reputational harm and could strain relationships with key players like SpaceX, OneWeb/Eutelsat, and even Sure International’s own parent company, Beyon.

Finally, the attempt to sway public policy using such a one-sided report undermines the integrity of the licensing process. Decisions that affect national infrastructure, especially in isolated regions like the Falklands, must be based on transparent, factual, and balanced input. This report failed to meet that standard and may ultimately have weakened Sure’s position in the eyes of the very audience it was intended to influence.

My recommendation is that TTP and Sure should formally withdraw the report.