Could TPG end up partially subsidising NBN for Qantas Wi-Fi?

NBN Co placed in a potential conflict of interest under new regional broadband tax

Earlier this year, I made a submission to the Government’s consultation on the Telecommunications Reform Package.

I’ve been meaning to write a summary for some time.  I thought I’d whip one up together after it was announced that the Government planned to introduce the legislation next month despite not responding to the submissions.

As part of the reform package, the government planned to introduce a $7.09 charge per line to most fixed line “superfast” broadband services (defined as 25 Mbps download speeds or greater).

This is to help subsidise the cost of nbn’s fixed wireless and satellite networks — primarily servicing regional and remote communities around Australia.

The NBN fixed line footprint is expected to be the primary contributor of the tax.  However, other operators such as TPG with its fibre to the building network will also be hit.

NBN Co’s commercial interest

The problem is that the NBN satellite network is no longer solely about the delivery of broadband services to regional areas.

It now has other commercial interests — including the Satellite Mobility product which allows commercial entities like Qantas to tap into the satellite network for the delivery of in-flight Wi-Fi.

This could mean that a provider like TPG could be paying taxes which help subsidise the provisioning of Wi-Fi services on a Qantas aircraft.

No restrictions on subsidy for regional broadband only

The proposed bill had no restrictions that the funding must only be used to provision broadband services to regional areas — as I explained in 2.1.5 and 2.1.6 of my submission.

So, NBN Co is placed in a conflicting conundrum.  It can spend its subsidy funds on improving the quality of satellite services to regional communities like relaxing the Fair Use Policy with no additional revenue.

Alternatively, it could spend it on developing new revenue streams through commercial products like the Satellite Mobility product — competing with the likes of Optus who also have satellites in the sky.

My suggestions?

In my submission, I suggested:

  1. The Bill should make clear that the funding made available through the Regional Broadband Scheme is not available for services where the primary purpose is not to deliver broadband to regional communities.
  2. The strict Fair Use Policy (FUP) imposed by NBN Co on its Satellite network means the quality is still not directly comparable to fixed-line super-fast broadband services.As a condition of the Regional Broadband Scheme funding, the funding recipient should prioritise upgrades to the capacity and service reliability of rural and regional customers over the development of supplementary products like the Satellite Mobility product.
  3. Ensure similar protection is afforded to services delivered by means of the NBN Fixed Wireless network.

Full submission

Qantas to sign trial satellite product with NBN for Wi-Fi

nbn co and Qantas set to begin a proof-of-concept agreement to test the delivery of a on-board Wi-Fi from February 2017

The company responsible for building the National Broadband Network, nbn, has released its test agreement with Qantas allowing them to test a “Proof-of-Concept Aeronautical Mobile Satellite Service” on a Qantas test aircraft.

The proof-of-concept test is expected to help guide the development of nbn’s Satellite Mobility Product expected to launch in the third quarter of 2017.

Qantas has already begun preliminary engineering testing of its proposed on-board Wi-Fi product on a Boeing 737 aircraft (VH-XZB). The national carrier intends to partner with service provider ViaSat to deliver on-board Internet connectivity once the mobility product becomes available.

The trial product will be delivered over a Layer 3 VPN connection over the NBN Satellite Network. nbn will be responsible for the network between the Air Network Interface (ANI) located on the test aircraft’s Air Terminal and the Mobility Network-Network Interface (M-NNI) located at the NBN Point of Interconnect (POI).

As part of the trial, the network speed will be limited to 20 megabits per second for each aircraft on at most two aircrafts concurrently. The connection will also be limited to agreed flight corridors.

Earlier analysis by jxeeno blog has concluded that on-board Wi-Fi products are likely to have little or no impact on the congestion of beams given the short duration of time each aircraft spends under a single beam.

The proof-of-concept agreement is set to kick in from 1st February 2017 and is expected to run until 1st September 2017 unless terminated early or extended. However, Qantas is yet to officially announce its public launch date for the on-board Wi-Fi service.

NBN HFC self-install to become default

HFC installation premium for customers with existing lead-ins amongst changes in latest NBN product roadmap

The company responsible for building the National Broadband Network, nbn, has updated its product roadmap for the third quarter of 2016. Here is a summary of some of the key changes:

HFC product

nbn’s HFC product launched at the end of last month in a limited footprint in Redcliffe region in Queensland (PR044). The company also recently signed a contract with six delivery partners to upgrade and rollout the existing Telstra HFC footprint for nbn’s use.

Self-install to become default
As part of the current rollout strategy, nbn will send an installer to install the HFC Network Termination Device (NTD) at the customer’s premises when a service is ordered. However, the company plans to implement an RSP install and customer install option by the end of first and second quarter of 2017 respectively (PR112, PR129).

Once this process is implemented, nbn will begin charging customers who already have an existing lead-in a professional NTD installation a fee if they request for one.

Other HFC planned products
Deployment of DOCSIS 3.1 NTDs remain on-track for upgrade by the end of 2016 (CE045).

nbn also plans to introduce service transfers on HFC by September 2016 (PR121), as well as various diagnostic capabilities for Traffic Class 1 services.

The company does not plan to offer business grade “Traffic Class 2” tiers over HFC until 2018 or beyond (PR118).

NBN Satellite Service

ISS migration period extended
The migration of nbn’s existing Interim Satellite Service (ISS) customers to the new “Sky Muster” Long Term Satellite (LTS) service has been extended out until February 2017 (PR023). nbn had originally planned to migrate all its existing ISS customers to the Long Term Satellite solution by the end of 2016.

However, teething issues appeared to have hampered the originally anticipated activation rate — shifting the expected end date for the migration by two months.

There have been numerous reports of missed appointments, inability for NBN NTD modems to reconnect after a power reboot and most recently, the decision to retain the existing ISS satellite service after an LTS installation and retrospectively visit the customer to remove the ISS dish.

Consultation on “Managed Services Education” over Satellite
nbn is investigating the possibility of providing enhanced services for distance education students. The company has listed a number of possible products including a managed unmetered data service and multicast video broadcast services over its LTS service. Consultation on this service is expected to begin in September 2017.

Consultation on “Satellite Mobility” which could enable services like on-board Wi-Fi or Internet access for emergency services in remote areas has also been pushed back slightly to September (PR123).

Cell Site Access Service

As reported earlier, nbn concluded its initial Cell Access trial and has begun offering a Cell Site Access Service (CSAS) test service in Beaudesert, Queensland (PR039).

Detailed analysis: How will Qantas’ on-board Wi-Fi impact NBN satellites?

Geospatial analysis of the daily Qantas flight paths and NBN satellite beam coverage shows how NBN’s satellite network could be affected.

Writer’s note: Qantas is a customer of ViaSat, not NBN Co. ViaSat intends to trial on-board internet using NBN Co’s satellites — however, they have indicated they intend to launch their own satellites (ViaSat-3) to deliver a long-term solution for on-board Wi-Fi globally. This Qantas-ViaSat-NBN Co deal is dependent on industry consultation being completed in June 2016.

Qantas has recently announced that it plans to offer a Wi-Fi service on board its A330 and Boeing 737 fleet from early 2017 by utilising capacity on NBN’s recently launched Sky Muster satellite.  However, many Australians living in rural and regional Australia have raised concerns that the Qantas service will cause further congestion on an already limited service.

The company responsible for building the National Broadband Network, nbn, had completed a review of satellite capacity in its Fixed Wireless and Satellite review where it identified 31 beams around Australia that would be oversubscribed or severely oversubscribed once a take-up rate of 65% is reached.  As a result, the company will introduce strict Fair Use policies to significantly limit the amount of data to 150 GB (priced at a premium) that can be used by each customer on a 4-week rolling average basis.

Consequently, the Qantas announcement has infuriated many who are within the satellite footprint.  Analysis of flight paths taken by Qantas’ domestic flights using their A330-200, A330-300 and Boeing 737-800 fleets show that all planes fly through at least one congested or severely congested satellite beam.

Key findings:

  • 334 Qantas domestic flights utilise the A330-200, A330-300 and Boeing 737-800 fleet on the day analysed.
  • Every flight flew under at least one oversubscribed or severely oversubscribed beam.
  • 58% of oversubscribed or severely oversubscribed beams will have minimal impact, with at most 2 planes flying under the beam at any given time.
  • The Sydney-Brisbane and Sydney-Gold Coast routes travel entirely within severely oversubscribed NBN Satellite beams (34, 29, 25, 20).
  • The Sydney-Melbourne, Melbourne-Canberra, Sydney-Canberra and Townsville-Brisbane routes travel entirely within oversubscribed OR severely oversubscribed NBN Satellite beams.

Analysis: by congested beams

Over half (58%) of congested beams are not affected or are minimally affected by Qantas planes.  Of the 31 beams considered oversubscribed or severely oversubscribed, 5 of them do not cover any current eligible Qantas flight paths.  7 beams will have at least one flight under the path at some point, and 6 beams will have up to 2 flights under it at the same time (within a 10 minute time frame).

Unsurprisingly however, the beams covering areas immediately surrounding capital cities will have the greatest number of flights under it at any given time:

  • Beam 42 (Sydney Beam) is the worst affected, with up to 7 Qantas flights within a 10 minute time frame travelling under it.
  • Beams 47 (Melbourne Beam) and 20 (Brisbane Beam) come in second, with up to 6 Qantas flights within a 10 minute time frame travelling directly under each of them.
  • Beam 37 (Adelaide Beam) comes in third, with up to 5 Qantas flights within a 10 minute time frame travelling directly under each of them.

It should be noted though, that for the day analysed — the Sydney and Brisbane beams only had the greatest number of flights under it for a single 10 minute time frame (between 8:50am – 9:00am and 7:30pm – 7:40pm respectively).

Finally, by considering the average number of Qantas planes under a beam over a 24 hour period — we see that Beam 47 (Melbourne) tops out at 1.94 planes with Beam 42 (Sydney), Beam 20 (Brisbane) and Beam 41 (Canberra) following closely behind at 1.52, 1.45 and 1.22 planes respectively.

Beam* Max concurrent
flights under beam
(over 10 min period)
%age of time with
at max plane
under beam
%age of time with
at least one plane
under beam
Avg. number of
planes under beam
over 24 hrs
47 (Melbourne) 6 2% 67% 1.94
42 (Sydney) 7 1% 63% 1.52
20 (Brisbane) 6 1% 63% 1.45
41 (Canberra) 4 5% 58% 1.22
37 (Adelaide) 5 1% 49% 0.86
24 (Armidale) 5 1% 53% 0.83
48 (Omeo) 4 1% 51% 0.76
66 (Perth) 3 1% 51% 0.63
34 (Newcastle) 3 3% 40% 0.57
33 (Bathurst) 4 1% 33% 0.48
25 (Grafton) 2 3% 33% 0.37
46 (Ararat) 3 1% 28% 0.36
3 (Townsville) 2 3% 28% 0.31
15 (Wondai) 3 1% 24% 0.30
29 (Port Macquarie) 2 1% 26% 0.27
36 (Yorketown) 3 1% 22% 0.26
35 (Port Lincoln) 2 2% 22% 0.24
7 (Mackay) 2 3% 19% 0.22
11 (Rockhampton) 2 2% 20% 0.22
31 (Whyalla) 1 15% 15% 0.15
44 (Kangaroo Island) 1 8% 8% 0.08
63 (Guilderton) 1 8% 8% 0.08
16 (Maryborough) 1 6% 6% 0.06
2 (Charters Towers) 1 3% 3% 0.03
1 (Cairns) 1 3% 3% 0.03
51 (Geelong) 1 2% 2% 0.02
49 (Bega) 0 0% 0% 0.00
52 (Inverloch) 0 0% 0% 0.00
54 (Burnie) 0 0% 0% 0.00
56 (Hobart) 0 0% 0% 0.00
68 (Bridgetown) 0 0% 0% 0.00

* Beam name is based on a suburb/town/city directly under the beam and may not be the official name used by nbn

Analysis: by flight

Each flight and its flight path were analysed to see which NBN Satellite beam it flies under. The results shows that every single Domestic Qantas A330 and B737 flight flies under at least one oversubscribed or severely oversubscribed satellite beam.

The most prominent are the Sydney-Brisbane and Sydney-Gold Coast routes, which flies entirely within severely oversubscribed beams (that’s beams 34, 29, 25, 20).  Sydney-Melbourne, Melbourne-Canberra, Sydney-Canberra and Townsville-Brisbane routes fly entirely through oversubscribed or severely oversubscribed beams.

For the full analysis output, click here!

Concluding thoughts…

I find the results of this analysis somewhat inconclusive. Firstly, unlike domestic US services — the number of Qantas flights expected to get the Wi-Fi service is quite small.

With under 350 flights spread out geographically and over a 24 hour period, I doubt the planes would have a material effect on congestion. Currently, the worst case scenario seems to be up 6-7 planes flying under a single beam at any given time. However, in the case of the 7-plane statistic, it happens only once in a 24 hour period. The speed at which planes travel also mean that they will typically fly in and out of narrow beams within 10-15 minutes, meaning any impact should be distributed across multiple beams as the plane flies through the airspace.

On the other hand, the bulk of the flights will fly under already oversubscribed areas. This is especially true for the beams serving the areas immediately surrounding the capital cities, which are all severely oversubscribed (bar-Darwin). These areas also have the greatest number of concurrent flights, represented by the “average number of planes over 24 hours” statistic.

So, no. I don’t think there’s an immediate threat to congestion. However, it does set a precedent. If more carriers get on board… and if international flights get added to the pool as well — things could well change in the future.

NBN Long Term Satellite beams
Diagram showing NBN Co satellite beams and risk of congestion as determined in the Fixed Wireless/Satellite Strategic Review (FWSat SR).

Assumptions made in this analysis:

  • The flight data analysed was from Wednesday, 23rd Feb 2016.
  • Qantas will only install the Satellite-powered Wi-Fi solution on their A330-200, A330-300 and Boeing 737-800 fleet.
  • In all cases where the plane transverses an area with both a wide and narrow beam, the congested, narrow beam is selected.
  • Plane locations are calculated in 10 minute intervals.
  • Congestion (oversubscribed beams) are based on results in the NBN Fixed Wireless and Satellite Review.

Just how fair is nbn’s proposed Satellite Fair Use Policy?

Simple maths shows 2x more per-user capacity compared with interim satellite, but only 0.7x more data allowance is proposed.

After revealing the proposed restrictions and fair use policies to help manage traffic and congestion on nbn Satellite service, some residents have taken to Whirlpool Broadband Forums to express their concerns.  The primary concern being that a 75 GB 4-week rolling average limit doesn’t translate to 75 GB of “anytime data”.

According to the draft Fair Use Policy, nbn will — in addition to limiting the maximum usage per service to 75 GB on the standard CVC Class 0 — also limits the ISP-wide 4 week rolling average download and upload during peak periods (from 7am to 1am the following day, local time).  Currently, the base CVC Class 0 is proposed to be 15 GB download and 3 GB upload.

This means, if the Fair Use Policy isn’t altered before the final satellite product release, a service provider would have to either carefully balance a number of lower capacity plans with higher capacity plans to maintain an average of 15GB, or offer one plan that provides close to 15GB with around 40GB of off-peak data up for grabs for all users.

(25/5 Mbps)*
User data cap
(4-week rolling avg)
Peak Period Download
(ISP 4-wk average)
Peak Period Upload
(ISP 4-wk average)
0 $27.00 75 GB 15 GB 3 GB
1 $45.00 100 GB 20 GB 4 GB
2 $67.00 150 GB 25 GB 5 GB

Realistically, however, we can expect RSPs to oversell slightly given the 15 GB limit is averaged across the ISP using the assumption that a portion of their users will not reach the 15 GB limit.

Comparing increased capacity with Fair Use Policy

But just how fair is this 15 GB / 3 GB averaged limit being proposed by nbn?  Let’s see how it compares with the current nbn Interim Satellite Service and nbn Fixed Wireless network.

Per-user allocated capacity

Firstly, let’s check how much satellite capacity is expected to be assigned to an end user.  Since nbn imposes minimum customers-to-CVC (AVC-to-CVC) ratio (so RSPs can’t hog virtual capacity), we can calculate these numbers by dividing the CVC capacity by the maximum and minimum customers.

Estimating the per-user allocated capacity on the draft NBN satellite service FUP
Estimating the per-user allocated capacity on the draft NBN satellite service FUP

As seen above, this averages out to be around 125 kbps per user on CVC Class 0, 145 kbps per user on CVC Class 1 and 190 kbps per user on CVC Class 1.

CVC Class Maximum CVC (Mbps) Average per-user capacity allocation (kbps)
0 475 125
1 550 145
2 735 190

In comparison, the dimensioning of nbn‘s Fixed Wireless network allocates roughly 500 kbps per-user and 40 kbps on the current nbn Interim Satellite Service (ISS).  In light of this, let’s compare the percentage difference in capacity on the various CVC Classes compared to Fixed Wireless and ISS:

CVC Class Per-user capacity (kbps) % of ISS capacity (40 kbps) % of FW capacity (500 kbps)
0 125 313% 25%
1 145 363% 29%
2 190 475% 38%

So, the standard CVC Class 0 product has roughly 2 times (or is 313% of) per-user allocated capacity on the Interim Satellite Service.  It is also roughly a quarter of the capacity on the NBN Fixed Wireless network.  How do the Fair Use Policies for the ISS and Fixed Wireless compare numerically to the proposed Long Term Satellite?

Fair use policies

Interim Satellite Service: nbn‘s fair use policy for the Interim Satellite Service is structured similarly to the proposed Long Term Satellite policy.  Currently, the cap at a per-AVC (or customer) basis is 50GB.  313% of that would bring it to ~150GB, rather than the 75GB proposed.

But as we have said, this limit means little given the bulk of downloads generally occur during peak time.  While nbn doesn’t have a peak time average limit on the ISS, the company has mandated an ISP-wide averaged 9.7 GB download limit on a 4-week rolling average basis.  For this model, let’s assume that ~90% of traffic occurs during peak time — coming to an estimated ISP-wide averaged 8.7 GB download limit on a 4-week rolling average basis.  313% of that would bring us to ~27.6 GB, compared to the 15 GB proposed.

In summary, while per-user assigned capacity has increased by around 2x compared with the ISS — data limits in the fair use policy have only increased by a mere 0.72x.

Fixed Wireless: nbn‘s fair use policy for the Fixed Wireless network is straightforward.  RSPs must maintain, on average across their user base, less than 200GB download (let’s consider download only).  Like the ISS, there are no limits on peak/off-peak usage… but let’s assume that 90% of traffic is carried during peak time (meaning ~180 GB download).  If we take 25% of the Fixed Wireless fair use policy, we get 45 GB per month of peak time data per month.

Having calculated that, however, it’s important to remember that Fixed Wireless is a fundamentally different product.  Given it has far more capacity compared with any satellite product, there is more room to wriggle when it comes to the fair use policy limits.  However, for completeness sake, while the per-user capacity on the LTS is around 25% of Fixed Wireless — the data limits in the fair use policy are a mere 8.3%.

CVC Class % of ISS capacity % of ISS FUP (1) % of ISS FUP (2) % of FW capacity % of FW FUP (1)
0 313% 172% 150% 25% 8%
1 363% 230% 200% 29% 11%
2 475% 245% 300% 38% 17%

Table: % of per-user allocated capacity when compared with ISS capacity and FW capacity, and compares this with the % of the various data allowances set in proposed Fair Use Policy
(1) refers to the ISP-wide 4-week rolling average, (2) refers to the per-AVC cap (50 GB on ISS, not applicable for FW)

The summary

nbn appears to be very conservative when it comes to allocating data allowances on the Fair Use Policy.  Comparing to the Interim Satellite Service, per-user capacity has increased by between 2x to ~3x (depending on which CVC Class you choose).  However, ISP-wide peak-time data allowance only increases by between ~0.72x to ~2.5x (again, depending on CVC Class being compared).

As the writer doing the analysis, I believe there is scope for nbn to increase limits currently proposed in the draft Fair Use Policy.  Ideally, if service providers can buy two times more CVC capacity compared with what they can do on the ISS — they should be able to offer customers around the same amount more data… but I’m not going to sit here and pretend that using capacity can be calculated using simple maths.

Real networks are far more complex beasts, and simple calculations do not necessarily reflect how real networks behave.  But I believe a simple scale projection, as I’ve done above, would aid the public gaining some perspective on how little data caps have increased in comparison to the new satellite’s extra capacity.

All is not lost:

Some service providers who are helping nbn test their satellite systems before the Q2 2016 launch are actively working with nbn to get the best Fair Use Policy possible.  In the words of Paul Rees, the managing director at SkyMesh:

“We’re doing all we can to get the best FUP for customers that provides decent Data Allowances that don’t wreck LTSS performance at peak times.”

“The FUP hasn’t been set in stone yet, those numbers are just part of a draft document. So let’s have some calm, and save the ‘going nuts’ until the FUP has been formally decided.”

Wise words, Paul.  We wish you all the best in your pursuit.