SpaceX also faulted the FCC for relying on Ookla speed tests:

For instance, the Bureau's decision arbitrarily penalized SpaceX—and only SpaceX—for not meeting RDOF speed requirements years before SpaceX had any obligation to do so. The arbitrariness of applying this unstated standard exclusively to SpaceX was only compounded by the Bureau's reliance on Ookla nationwide speed tests without any notice that it planned to use such tests and even though those nationwide averages included areas that would not be served by RDOF. Even so, Starlink likely recorded the fastest speeds of any operator in the locations eligible for RDOF funds... Starlink has also deployed its service in advance of all RDOF deployment milestones and well ahead of most, if not all, RDOF awardees.