"Australia’s USO
Wrangling Hits New Intensity"
Queensland quietly deploys
Starlink to First Nations communities, as rain fade
debate rages
The Queensland government has been
quietly deploying a so-called Rapid Low Earth Orbit
Deployment Project which has already connected ten First
Nations communities in the state with Starlink dishes.
One of the installations provided
potentially life-saving communications for some 300
people dislocated by a tropical cyclone last December,
even as opinions differ as to whether the technology
works effectively during rain.
The low proϐile
project is being run jointly by the Queensland
Government Custom[1]er
and Digital Group and the Local Government Association
of Queensland, which is overseeing council applications
and distribution of funding for the Starlink satellite
dishes.
What is most notable about this
initiative is its value for money. The government has
allocated just $1.25 million to the program, which aims
to provide improved digi[1]tal
infrastructure for an interim period while larger
infrastructure projects are deliv[1]ered
to increase digital inclusion.
“Funding of $45,000 has been
allocated for each community—more for the Torres Strait
region—which will provide approximately ϐive satellite
dishes for each loca[1]tion,”
the state government said. The project guidelines
suggest the funds also cover 36 months of service.
This suggests that upwards of 27
communities will beneϐit from the program, with a
cumulative total of nearly 140 dishes.
A spotlight was shone on the
project for the ϐirst time in a submission by the Qld
local government group to the Federal Department of
Communications’ current con sultation on the Universal
Service Obligation.
“The Rapid LEO Deployment Project
is a great pilot project that demonstrates what beneϐits
could be achieved for remote communities if the federal
government were to support further roll-outs,” the local
gov’t association said in its submission.
The association cited two speciϐic
examples of deployments under the project.
The first, for the Wujal Wujal
Aboriginal Shire Council, saw instant deployment of
Starlink connectivity after 300 residents were impacted
by Tropical Cyclone Jasper on 13 December last year.
The second is intended to provide
transformative broadband connectivity for the sole
accommodation facilities on Mornington Island, enabling
online bookings and providing secure income for the
owner, Mornington Shire Council.
The strong endorsement of LEOsat by
Queensland authorities comes at a time there
opinions are mixed as to whether the technology should
become a key part of the USO mix. The major ϐlashpoint
appears to be the performance of LEOsat during weather
incidents such as rain.
As CommsDay reported yesterday,
peak rural comms lobby, the Regional, Rural and Remote
Communications Coalition, said several of its 21 members
had noted “rain fade and service failure during
bushϐires on both NBN Sky Muster and Starlink
connections.” The user lobby group Better Internet for
Regional, Rural and Remote Australia said there was a
lack of public data on the reliability of satellite
services, and nominated two speciϐic examples of
individual user experiences with Starlink:
one of whom experienced around 50
minutes of downtime during a day-long storm, the other
experiencing around three hours downtime during a
week-long period.
By contrast, a trial Telstra
conducted of Starlink services across the equivalent of
644 customer days found overall service reliabil[1]ity
of 99.8%, higher than the 99.6% overall performance of
ϐixed networks.
Significantly, LEOsat reliability
during heavy rain fall events was 99.4%, deϐined as 1mm
of rain every 15 minutes. Telstra, which took the
measurements over the last summer, said heavy rain was
recorded less than 0.75% of the time.
This implies that Starlink would
suffer service unavailability during rain for less than
40 minutes per year. Average Starlink dropouts from rain
resolved in under five minutes, according to Telstra.
Anecdotal evidence from the
Starlink Australia Facebook group, which has around
80,000 members, is that most users typically experience
dropouts of a few seconds and rarely more than a minute
during rains of up to 60mm per hour. A common ob[1]servation
is that speeds drop during heavy rains but not to
unusable levels.
The 2023 report of the Federal
Government’s LEOsat Working Group noted that the
availability metric for LEOsat services may be slightly
lower than copper mostly due to rain fade, but that all
other metrics would be improved and the difference in
availability would be negligible.
There is surprisingly little
academic literature on LEOsat rainfade, with most work
Telstra’s Starlink trial
| Seven services measured over
combined 644 days
| 99.8% uptime
| 99.4% uptime during rain ( above
1mm every 15m)
| Average dropout time of 5 mins
during heavy rain
| Compared to 99.6% overall ϐixed
network uptime
employing theoretical modelling as
opposed to real world test results. A recent study on
candidate ground stations for Telesat in Africa when
measured against rain data found that three of six would
only be unavailable for 53 minutes per year while a
fourth would be unavailable for about four hours per
year. The other two would be unavailable for around two
days, due to rain.
Starlink said in March that it now
had over 200,000 customers in Australia. With NBN Sky
Muster now servicing around 87,000, the combined number
across the two satellite services has passed the 285,000
customers served by the USO-funded Telstra rural copper
network.
Grahame Lynch
USO copper lines now subsidised
$800 each per year as Telstra argues for wireless,
satellite reset
Telstra has revealed that it is now
servicing just 285,000 copper line connections, from the
$230 million in annual subsidy it gets from universal
service funding: costing over $800 per connection and
rising. It has also reported that its tests of LEOsat
services showed that the notion that they suffer from
rain fade is a myth.
The revelations came in a
submission to the federal government where it called for
major changes in the universal service obligation, not
least, an end to the requirement for it to maintain a
copper network in non-NBN fixed network areas until
2032.
The 285,000 footprint appears to be
declining fast according to varying data points: Telstra
was estimated to supply over 600,000 such services in
2018.
Telstra argued that it is now time
for technology neutrality in USO delivery.
“Different technologies have
different strengths and weaknesses, and none is perfect.
However, the recently launched
fixed wireless and Low Earth Orbit satellite
technologies are better able overall to provide
consistent, high-quality connectivity to premises in
areas that have not been connected to NBN Co's fixed
line network,” it argues.
“In addition to supporting high
quality voice, the data performance is generally much
better than legacy technologies such as copper-based
ADSL.”
The submission argued that concerns
that alternate technologies to fixed line are inferior
are unfounded.
A trial Telstra conducted of
Starlink services across the equivalent of 644 customer
days found service reliability of 99.8%, higher than the
99.6% performance of fixed networks. LEOsat reliability
during heavy rain fall events was 99.4%, defined as 1mm
of rain every 15 minutes.
“Heavy rain can impact the fixed
network via the flooding of network assets and cable
wash-outs, and these can often take days to repair which
in turn reduces aggregate availability. In addition, the
average duration of LEOsat service dropouts was under
five minutes, meaning that when a dropout occurred the
connectivity was typically re- established very quickly.
In contrast, copper outages can take hours or days to
resolve,” Telstra said.
Telstra argued: “The requirement to
use the copper network to deliver standard telephone
services to premises that were connected by copper at 1
July 2012 should be removed. Doing so will allow Telstra
to plan and execute an orderly migration of customers
from the ageing copper network to newer technologies
that are more capable of providing a high-quality
standard telephone service over time, mostly in regional
and remote areas but also at metropolitan premises not
currently served by 12,331 opens NBN CO: Plans to
streamline three consultations on high speed products
yesterday
UNIVERSAL SERVICE REGIME: Starlink,
Amazon make the argument for LEOsat offerings NBN Co.
There should be no technology-specific mandates or
exclusions.”
Telstra receives $230 million from
government, and, in part, from competitors via an
industry levy, to maintain the standard telephone
service each year.
Other major levy contributors,
unsurprisingly, have used the consultation process to
call for an end to the USO scheme as it stands.
NBN WANTS REFORM IN FAVOUR OF LEO:
NBN Co wants reform, namely the streamlining of the
Telstra-delivered USO and the mainly NBN-delivered
Statutory Infrastructure Provider regime into a single
service obligation.
“For approximately 97-98% of the
population covered by NBN’s fixed-line and fixed
wireless networks, the baseline network would be NBN or
other non-NBN SIPs,” NBN Co argued.
“For the remaining 2-3% of the
population, a LEO satellite network could be used to
provide baseline broadband and voice services in
regional and remote Australia via a LEO-based SIP,
provided government, industry and consumers are
satisfied that appropriate technical, commercial,
operational and security arrangements are in place to
reliably deliver those services to Australian
end-users.” it said.
Other telcos think it is time for
an end to the USO, with satellite able to adequately
take up the slack.
OPTUS WANTS EFFECTIVE USO REPEAL:
Optus said that since 1992, it had paid Tel[1]stra
more than $1.2 billion in USO levies, which it could
have invested in its own mo[1]bile
network.
“This has resulted in Optus’ mobile
network being almost one million square kilometres
smaller than it could otherwise have been,” it claimed.
“As currently administered, the USO
remains an economically inefϐicient subsidy of out
of-date technologies that ultimately serves to reduce
the level of private infra[1]structure
investment in regional and remote areas and entrenches
Telstra’s network dominance. Rather than ensure that
consumers in non-commercial areas receive modern
telecommunications services, the current USO regime
enables Telstra to “sweat” its copper assets – to behave
as a monopolist,” it said.
Optus recommended that the
government immediately repeal the USO from all areas
where there are at least three networks, including
mobile and satellite networks, capable of supplying
voice or voice equivalent services to a fixed location.
It also warned the government away from picking a
particular satellite solution “winner”, saying that GEO,
MEO and LEO may all play a role in a “system of
systems.”
TPG SAYS SIP CAN REPLACE USO: TPG
said it wants an immediate transition away from existing
Telstra contractual arrangements. “The USO is no longer
required where the Statutory Infrastructure Provider
regime compels wholesale providers to provide a voice
service. Any residual concerns regarding consumer
safeguards can be dealt with by imposing obligations on
NBN Co, as the default SIP,” it argued.
It said that should there be a
requirement for an ongoing industry levy to fund the
USO, it should be expanded to “OTT providers” and be
based on profits and not revenues.
VOCUS ASKS WHY A USO? Vocus Group
asked “Given that commercial services are now available
to 100% of Australian premises, it is not unreasonable
to start with the question – do we need any form of USO
at all?”
“Premises with coverage from at
least two mobile networks, as well as LEO and NBN Sky
Muster, can be considered ‘competitively served’ as they
have a range of commercial pricing options available
from a range of providers.”
“But for premises
with coverage from only one mobile operator as well as
LEO and NBN Sky Muster, the presence of only two viable
voice services should allow for endusers to receive a
subsidy to ensure they can obtain a minimum-standard
level of service at an affordable price.”
Subsidies for end-users shouldn’t
go to operators but instead be offered to end users, who
would be able to choose a preferred service.
Grahame Lynch, Commsday
Starlink wants in on Australian
universal service provision
Starlink operator SpaceX has called
for a “pro-competition” model to deliver Australian
universal service, calling for a “complete re-write” of
the existing Universal Service Obligation regime in a
submission to a consultation.
It should be replaced
with a technology agnostic scheme that has a “greater
focus on competition, multiple providers and multiple
robust service offerings for consumers,” rather than
having “a focus on a single provider of limited legacy
services, as is currently the case,” SpaceX has told the
federal government.
It said that a revamped USO could
allow customers “to choose from multiple services,
including LEO satellite broadband” and rather than a
focus on technology or particular provider be based
around minimum standards to deliver voice and other
critical services.
SpaceX said the Department of
Communications should implement a “consumer choice
model” based on a selected panel of service providers
that have shown they can meet minimum requirements:
“These competitive USO providers could include operators
of a variety of different telecommunications networks
that are capable of supplying qualifying services,
including LEO satellite networks such as Starlink, fixed
wireless networks and mobile networks, as well as new
networks that may be launched in the future. As
technology advances, the Department can periodically
increase standards.”
AMAZON WEIGHS IN: Amazon’s Project
Kuiper similarly argued that LEOsats offer an
alternative technology for universal service. However,
it cautioned that it would be “premature” to expand the
Standard Telephone Service to require direct-to-device
functionality.
Although Kuiper has not announced
its service plan, it noted that it was capable of
supporting voice products with call quality comparable
to a terrestrial network, as well as support other
carriers with backhaul services.
“Project Kuiper will operate as an
internet service provider, serving individual
households, as well as schools, hospitals, businesses,
government agencies, and other organizations,” it said.
“Although Amazon has not yet revealed the pricing for
Project Kuiper, affordability is a key principle.”
It noted that Australia’s universal
service regime developed “in an environment here supply
and demand conditions were well-established” due to
Telstra’s monopoly on services in non-commercial areas
and “conditions of relatively low technological
dynamism, where copper-based wireline access networks,
supplemented by microwave, have been the prevailing
terrestrial network solution in regional and remote
areas of Australia”.
“The supply of STS under the USG
mostly assumes a geographic dimension: the overwhelming
majority of people reliant on the statutory Universal
Service Obligation for their STS and the overwhelming
areas of net cost associated with its provision are
those inhabiting rural and remote parts of the country,”
it said.
The government has been able to
“act with a high degree of certainty” when setting out
the requirements of the STS and the geographic areas
where regulatory obligations operate. Direct-to-device
services are “subject to high degrees of competitive and
technological dynamism” and “are nascent and immature in
Australia and global[1]ly
across a range of dimensions.”
As a result it’s not possible to
define a baseline service based on direct to device, or
“identify areas in which such a baseline service might
not be commercially supplied according to the dimensions
of accessibility, availability, and affordability.” That
makes it inappropriate to consider as part of the scheme
until “supply and demand conditions have developed as
they are expected to over the short to medium term.”
Rohan Pearce, Commsday
Just one of many key talking points at the
forthcoming:
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