Generally there are four types of internet delay namely propagation delay, processing delay, queueing delay and transmission delay. For satellite link, regardless of Geo or Leo the propagation delay will be dominating the equations.

I believe Starlink's engineers would have figured all the delay situations to claim less than 100ms latency and hopefully they will publish a credible white paper about it to refute FCC's counter claim.

Elon if you're reading this please send email to my username on Gmail for a third party verification of the latency, and of course with a small amount of fee in USD :-)