"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 

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