Environment and Communications Legislation Committee -Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Bill 2025
CHAIR: Welcome. I understand that information on parliamentary privilege and the protection of witnesses giving evidence to Senate committees has been provided to you. I invite each organisation to make a short opening statement, and then, at the conclusion of those remarks, I’ll invite members of the committee to ask questions. Australian Telecommunications Alliance?
Mr Coleman: This submission from the ATA was provided on behalf of our mobile network operator members. We represent a group of more than 60 participants across the industry, but this particular submission was on behalf of mobile network operators. The development of low-earth satellites and direct-to-device technology, which is sometimes called satellite-to-mobile or direct-to-handset technology, is certainly a very promising technological development, and it could well provide universal outdoor mobile coverage at some point in the future.
While Australian mobile networks provide coverage to more than 99 per cent of where Australian’s live and work, that still only equates to around one-third of Australia’s land mass. While I think the ambition is broadly supported—that we want to have universal mobile coverage—it is still a nascent technology. What we are seeking to do with this legislation is establish a requirement on mobile network operators to provide services which do not actually exist from a technological perspective. They have not been tested, let alone deployed, at scale in a commercial environment.
Our three key asks in our submission are, firstly, that the commencement date for the bill, should it be passed, be moved back to 1 January 2030 at the absolute earliest. At the moment, with the start date of 1 December 2027, it is highly unlikely that the technology required to deliver the service will exist, highly unlikely that the handsets required to access the service will be widely available or affordable and highly unlikely that the spectrum issues around the delivery of the service will have been resolved. That is the first request—that we move back the default date.
The second request in our submission is that we have some certainty over the nature and the amount of public funding available. At the moment, while there are provisions in the bill for public funding to be made available for the delivery of UOMO services, no work has been done on the costs involved—the costs for mobile network operators to provide the service and the amount of usage that we can expect to see for the service—so there is a high amount of uncertainty over the costs involved.
The final request is that we address the obligations and expectations on the satellite providers themselves. Currently, all of the commercial risk, operational risk and legal risk is put onto Australian mobile network operators. Ultimately, they do not own or operate LEO satellite networks, so there should be similar obligations on the satellite providers that are supplying the underlying technology. I’ll leave it at that.
CHAIR: Thank you. Vocus representatives?
Mr Lewin: Thank you for the opportunity to appear today. I’d firstly like to offer a quick summary about Vocus. We are Australia’s leading specialist fibre and network infrastructure provider, with national-scale fibre assets and a proven capability delivering carrier-grade connectivity. We own and operate 50,000 kilometres of secure, high-capacity fibre, connecting all Australian mainland capitals. We also have nearly 15,000 kilometres of subsea cables connecting Australia to the US and South-East Asia. Most importantly, Vocus also plays an integral role in the low-Earth-orbit, or LEO, satellite ecosystem through our ground infrastructure capabilities and our deep expertise in building connections to LEO satellite gateways.
Throughout many of the submissions there was a strong emphasis on the criticality of terrestrial infrastructure and the associated costs and complexity of extending fibre into low-density areas, which is where the ground infrastructure is likely to be required. Our core message is therefore straightforward: the delivery of UOMO at scale depends as much on the ground segment and the terrestrial fibre as it does on the satellites and spectrum. Unlocking more satellite ground stations and connecting them with secure, high-capacity terrestrial fibre and backhaul into mobile core networks is critical to expanding coverage quickly, efficiently and resiliently. As terrestrial fibre is the backbone of the Australian telecommunications industry, without this terrestrial fibre layer, coverage will be constrained by where gateways are located and how much traffic they can reliably carry.
So, against this backdrop, Vocus’s position is twofold. Firstly, a universal common offering layer that utilises mutual ground stations via terrestrial fibre and backhaul should be established; and secondly, it is essential to promptly update funding arrangements such as the universal service guarantee to include ground infrastructure and terrestrial fibre. Notably, funds should extend beyond mobile network operators and address the entire network stack to ensure that the benefits under the bill are fully realised. Failure to consider terrestrial fibre and backhaul may result in inefficient allocation of resources. A shared model will also reduce duplicative capital spend across providers, thus avoiding multiple near-identical ground builds and parallel fibre routes to serve the same geography.
In closing, Vocus supports the intent of the bill but urges that its implementation explicitly recognises the enabling role of terrestrial fibre and backhaul providers. We look forward to assisting the committee and answering any of your questions.
CHAIR: Senator Henderson.
Senator HENDERSON: Thank you all for your attendance today. Mr Coleman, I am surprised by your request for a commencement date of 2030, given that Telstra is in negotiations with Starlink right now about entering into a contract. Starlink has made it clear that its next generation technology will be available by around September or October of next year, before the mooted commencement date. So how can you justify delaying this by such a long period of time?
Mr Coleman: I think there are a few answers to that. First of all, this is more than just an interplay between the satellite providers and the mobile network operators. We also have devices as part of that equation. Even in a scenario where the technology was in place by the end of next year—and, for the record, I think that it is highly unlikely that all of the technological requirements will be in place by the end of next year. But even in a case where that occurred—
Senator HENDERSON: Just to be clear, I didn’t say that. I just referred to one contract between Starlink and Telstra, but, yes, I hear what you say. I just wanted to clarify that.
Mr Coleman: Yes, it’s important to clarify that. But, even if that condition were met, it would still require users of the service to have access to a very modern handset which is capable of using that technology. I think it would be a mistake to provide a perception for consumers that, on 1 December 2027, there’s going to be a UOMO service, one which is fully voice capable and fully data or text capable, and that they will be able to use it from day one. That will not be the case. They will require a very modern handset, which would be able to access some elements of what is proposed in the UOMO bill. It certainly doesn’t appear to be the case that voice services would be widely available. That is dependent, again, on handsets, on spectrum availability, on network interoperability and even on the application of standards in both networks and technology, which have not yet been commercially deployed, let alone tested. For services important as this one—there are going to be users in regional Australia, and they’re not only going to be using it for calling friends and family, although they’ll definitely be doing that. If they’re going to be calling emergency services, we want that service to be thoroughly tested to ensure that it is reliable.
That very tight window doesn’t build in a lot of time for the testing of that service or for the education of consumers about the device that they would need to invest in to be able to use the service, and these are not cheap devices that they would need to purchase to be able to use the service. There are a lot of variables in there, and so I think it is very reasonable that you would seek to delay the implementation of this until you have met all of those prerequisites and until the service has been thoroughly tested across all operators—before you would put the piece of legislation into effect.
Senator HENDERSON: What is the cost involved in making outdoor universal access available, between the MNOs and the LEOsat providers? What sorts of costs are we talking about?
Mr Coleman: It would depend on the nature of the contract between an MNO and a LEO provider. One option would be a wholesale arrangement, where the MNO would enter a contract with a LEO operator and buy those services on a wholesale basis. As another method of doing it, you could have an MNO and a LEO operator effectively go into an agreement where there is joint funding of ground infrastructure, such as ground base stations for a LEO service. Again, there would be some kind of a wholesale agreement in place for the use of the data that connects through the satellites in the sky. There is a range of options there. Of course, you would also need to negotiate over the value of the spectrum that would be used to deliver the service. It could be done by terrestrial spectrum for certain low-bandwidth applications, like text messaging, and that’s what we’ve seen in the live service today. It might use satellite spectrum for some elements, like in a technology called MSS, which is a satellite spectrum technology. There is such a wide range of variables in there. It would really come down to the specific contracts between the mobile operator and the satellite provider, and then, of course, there would have to be a question of how those costs would be reflected in a retail environment.
Senator HENDERSON: What representations have you made to the minister’s office or the department about the lack of funding, the commencement date and the fact that the technology does not currently exist to deliver universal mobile outdoor connectivity, and what has been the response of the minister or the department?
Mr Coleman: On behalf of the ATA, our submission to this Senate inquiry is where we have raised those issues around funding. I know that the mobile operators themselves and other industry organisations, such as AMTA, have also made representations on this front. So I can’t directly answer your question in that we have not made direct representations to the MO or the department beyond what is in our submission to this Senate inquiry. The point that we raise, though, is that, within the explanatory memorandum for the bill, it enables funds through the Public Interest Telecommunications Services Special Account, what we call the PITSSA, that there could be funding made available to pay for the UOMO service. The problem that we have is that we don’t know how much it’s going to cost. We don’t know how many people are going to use it.
Senator HENDERSON: Well, there’s no there’s commitment, is there?
Mr Coleman: There is no funding commitment. That is correct.
Senator HENDERSON: I ask you to place on notice to this committee any and all correspondence between yourselves and the MNOs in relation to the UOMO bill? That’s any internal correspondence, any briefing notes or any other any other written correspondence between you, as the industry representative, and Optus, TPG and Telstra, please.
Mr Coleman: I am happy to do so. That will largely be around the development of our submission, so I’ll take that on notice.
Senator HENDERSON: Yes. Any other any other matters in relation to the UOMO bill out of your office would be very much appreciated.
I go to Vocus. I was interested in your representations about the importance of a shared model. Could you explain in a bit more detail the importance of the fibre network, the terrestrial network in the country and the role that ground stations play?
Ms Aitken: The reason why we wanted to make representation in our submission around the importance of ground infrastructure and, most importantly, fibre, as you rightly point out, is that, regardless of whether we have a mobile network and regardless of whether we have satellites in the sky, at some point all of those all of those bits of infrastructure need to connect to high-capacity fibre infrastructure in the ground. As we mentioned in our opening statement, we have rolled out fibre connectivity to all the major satellite providers here in Australia, but that doesn’t mean that there are not going to be more requirements to do that, particularly when we’re looking at needing to service areas that are currently underserved. In relation to your question, for us it’s about emphasising the importance of fibre connectivity as part of the delivery of your UOMO. We spoke about the technology stack. Ground infrastructure is going to be incredibly important. At the end of the day, satellites still need terrestrial infrastructure and ground infrastructure in the space of antennas and fibre connectivity in order to operate.
Senator HENDERSON: To be really clear here: it’s not feasible for someone to have a direct connection between their device and the satellite?
Ms Aitken: They will, but, at the end of the day, that satellite still needs to talk to a ground station here in Australia.
Senator HENDERSON: And why is that? Could you step us through the technology constraints?
Ms Aitken: There’s a piece that we’ll call latency or ping, which is the time it takes for a satellite connection to get to an end user. You need to actually have that ground infrastructure. That will be your antennas, your big satellite dishes that you’ve seen generally located in regional areas. You need to have those located on the ground in order for that connectivity between the ground infrastructure and the data that sits within our domestic shores and the satellite that’s operating in orbit. You need both of those for that to then connect to the end customer with the device.
Senator HENDERSON: So it’s not feasible to be holding a device in the middle of the outback and just connect directly to the satellite. The signal does still need to go via a ground station.
Ms Aitken: Yes, correct.
Senator HENDERSON: Do you think there will be a time when consumers will be able to connect directly to a satellite and avoid any ground station infrastructure?
Ms Aitken: I think that’s going to be a question for the satellite operators. I think that, as it stands today, you still need to have the core networking of that satellite ground infrastructure. At a certain point, what future technology looks like—we’ve seen it advance so quickly in the last 10 years, but, as it stands today, you still need to have that ground infrastructure for the satellite and the network to talk to.
Senator HENDERSON: I also ask you, on notice, if you could provide any correspondence between yourselves and the minister’s office or the department about the UOMO bill and any estimate of costs involved in what infrastructure is required to deliver universal mobile outdoor access?
Ms Aitken: Wonderful. We’ll take that on notice.
Senator HENDERSON: Thank you.
CHAIR: Senator Hanson-Young.
Senator HANSON-YOUNG: This is for the Telecommunications Alliance. Senator Henderson’s pushed you a bit on the timeframe and the idea that you feel as though the default date is too close. What is your view on domestic roaming as a gap filler or an alternative? If access to the LEO system is not able to happen as soon as the government perhaps wishes, what about making sure that people can access via domestic roaming?
Mr Coleman: We haven’t gone into the issue of domestic roaming in our submission. If the objective of the UOMO bill is to fill in coverage black spots outside of terrestrial mobile network coverage, domestic roaming does not address that issue. Domestic roaming would address the issue of inequitable coverage between operators, but it would not create any new coverage beyond the reach of those existing operators. So, for the purposes of the discussion today around the UOMO bill and what it seeks to achieve, domestic roaming is a very different and separate issue. That’s the reason why we have chosen not to go into that in our submission.
Senator HANSON-YOUNG: But we are talking about making sure that people have access and equitable access. Does your association have a view as to whether domestic roaming should be something that is looked at?
Mr Coleman: No, this organisation doesn’t have a view on domestic roaming.
Senator HANSON-YOUNG: Do any of your members have a view on domestic roaming that you’re aware of? Is it something that you’ve discussed?
Mr Coleman: I’ve certainly seen public commentary from our members on domestic roaming. They will have a range of different views, and we do not have one consolidated view on behalf of the industry on that issue.
Senator HANSON-YOUNG: Okay. In terms of the LEOsat technology, you’ve raised some concerns around sovereignty risk issues. I’m keen to understand that. Is it that they’re all overseas, foreign owned options currently? Do you think Australia should be investing in our own capacity?
Mr Coleman: Certainly, one of the concerns that we have raised in our submission is that all of the obligations under the current bill are applied to Australian mobile network operators. None of the obligations are applied to the underlying infrastructure service providers, which are the LEO satellite providers. Presently, there is only one truly global LEO satellite network, which is provided by Starlink. There are others that are in the wings and are currently being developed, and I think it’s a really positive thing that there’s a lot of competition developing in that market, but none of them are being developed by an Australian operator. That creates a real disparity in the obligations that are going to be put on Australian mobile network operators and overseas providers that those mobile network operators are required under the bill to contract with to provide this service, but they do not face any of those same obligations. I think that is something that should be addressed. I do think it does raise questions about sovereignty that ultimately the parliament would be legislating a requirement to provide a service to Australians over which Australia does not have any control from a technological perspective. Certainly, there are contractual requirements that could be put in place to put standards on the delivery of that service, but, ultimately, the underlying infrastructure is not provided by an Australian company, and that does raise sovereignty issues.
We have not gone into the issue—to address the second part of your question—about whether or not Australia should have its own LEO satellite service. There is only one currently, and there are a couple of other LEO operators that are seeking to provide such services. But, by their very nature, LEO satellite constellations are global. They sit about 300 to 500 kilometres above the Earth’s surface and they are constantly going around the globe. If you create an Australian LEO service, really what you are creating is another global LEO service which is going to be spending most of its time providing coverage to other countries, not Australia, because of the nature of how those satellites operate. What we’re getting to in the bill is that, if there are going to be obligations on Australian mobile network operators, those should be mirrored or at least in some way applied to the providers of the underlying infrastructure.
Senator HANSON-YOUNG: How do you see ensuring that there’s some responsibility and obligation on those satellite providers could be achieved? I take your point that there’s only one at the moment and that, if there are going to be more, they’re still going to be global.
Mr Coleman: That’s right. Within the bill, there is the opportunity to put obligations on the satellite providers and not just on mobile network operators. At the moment, the market is very limited. Competition is very limited. It puts Australian operators at a significant commercial disadvantage in their negotiations with overseas based LEO operators because, under this bill, they will have a requirement in legislation to enter into a contract with them. They will not have a choice. They do not get to set the terms of that negotiation. The overseas based operators will know that they will have an advantage in those negotiations if the MNOs have to enter into a contract with one of them to provide this service because there is no alternative. That’s one of the commercial risks.
Of course, there is also the operational risk. From a technological standards perspective, the standards are still in their nascency when it comes to how direct-to-device services operate. Let me give you one small example. When you’re making a mobile phone call on an Australian mobile network, if you’re in a taxi and you go from one mobile cell to another mobile cell, that call will hand over from one cell to another. The technology for that to occur on a satellite network, when that call transfers from one satellite to another satellite, has not ever been operationalised yet. There are emerging standards in place that will make that possible, but they have not yet been operationalised. They have not yet been tested. At the moment, all of the operational risk for making sure that would work, under the bill, would be put on the mobile network operators. They have no control over those satellites to be able to do that. They have no control over the standards and whether or not they’ve been implemented to do that yet. That gives you a bit of colour around the risks that are involved with the current implementation date of 1 December 2027. Those things may all be addressed in coming years, but it is highly unlikely that they will have been addressed by the current default date.
Senator HANSON-YOUNG: In relation to some of the broader issues of ensuring there is public confidence in service delivery and in particular, of course—the most important of all—safety, you would know we’ve spent a lot of time in this committee talking about triple zero. Could I ask that the Australian Telecommunications Alliance provide on notice any communications concerning the ACCAN consumer survey it has had, such as documents, emails and draft letters, with the MNOs—Telstra, TPG, Optus—and any communications it has had in relation to that consumer survey with the regulator, the ACMA, the department or the minister’s office, please.
Mr Coleman: I’ll take that on notice.
Senator HANSON-YOUNG: Thank you.
CHAIR: Senator Ananda-Rajah.
Senator ANANDA-RAJAH: A quick question to Vocus: you spent a bit of time talking about the infrastructure. Do you think that the government should invest in building the neutral ground infrastructure, including stations? Do you think that the satellite operators would engage with such an offering?
Ms Aitken: That’s a great question—Senator Henderson touched on funding before, as did Luke Coleman—and my answer to it is yes. Many of the submissions that were put in by the mobile operators emphasise the investment that is likely to be required in infrastructure. Infrastructure is more than just mobile towers and spectrum—it will need to look at ground infrastructure. I think our call for this is, ‘Is there an opportunity to look at existing funding arrangements?’ And, if we’re looking at existing funding arrangements, such as the universal service guarantee, how do we look at the full technology stack that is going to be required to deliver UOMO?
As has been pointed out, we’ve had programs—like the Mobile Black Spot Program and the Regional Connectivity Program—which have been public-private partnerships or three-way partnerships with the federal and state governments in order to deliver that connectivity requirement into regional areas. Our call is that this is not going to be any different to those funding requirements, as it stands today. Your question about satellite operators and how that would work is a question best posed to them. But, from our standpoint, if there’s more opportunity for public-private partnerships between the Australian telecommunications industry and the Australian government, then—to Luke Coleman’s point and Senator Hanson-Young’s comment about sovereignty—that keeps our infrastructure on our shores and with the sovereign operators as well.
Senator ANANDA-RAJAH: Thank you. Luke, I know the industry wants to push this out, and I understand the concerns you’ve raised, but the issue here is that we shouldn’t let the perfect be the enemy of the good. We have communities right around this country, including in Victoria, who are suffering through natural disasters. I speak pointedly of the Longwood fire, which was the largest loss of private land in Victoria’s history. It only happened about three months ago. I’ve now spent several weeks speaking directly to farmers. The network went down on day one or day two. This is existential for these communities; it has only compounded their trauma; it’s affected first responders. I take your point, but is there a middle ground where something can be deployed to at least provide some type of service—something—for these communities, especially during natural disasters?
Mr Coleman: Senator, you used the phrase ‘not to let the perfect be the enemy of the good’, but, when it comes to the regulation of the emergency call service, perfect is what is typically aspired to, not just good. If we were to implement a piece of legislation where consumers are given the impression that they will have access to the triple zero service before it has been thoroughly tested, before the handsets are widely available to support that service and before the spectrum requirements are thoroughly analysed, tested and put in place to make that service available, there would be a high degree of risk that people living in regional Australia would expect that they would be able to reliably access the triple zero service using the UOMO service. It has not been tested. It is not yet technologically available. There are a lot of unknowns.
So, while I certainly agree with the sentiment that you’ve put, that something is better than nothing, the regulation that we have around the triple zero service quite rightly aspires to the absolute highest degree of perfection to ensure that that service is as reliable and resilient as it possibly can be. We do not yet have those conditions around this service—which is not yet commercially available, has not been tested and has not been implemented—and that poses a high degree of risk, I think, for people living in regional Australia who may have higher expectations than can be met.
Senator ANANDA-RAJAH: Thank you.
CHAIR: For both the witnesses here, if it’s possible to table your opening statements—if you haven’t done so already—that would be wonderful. Otherwise, thank you for your evidence today. If you’ve taken any other questions on notice, please provide your answers to the secretariat by no later than Friday 1 May 2026. Thank you very much
