Question 1

What is the Telecommunications Development Levy and why should LEO operators pay it?

Accepted Answer

The TDL is a levy on NZ telecommunications carriers that funds Telecommunications NZ Ltd's universal service obligations. These include the deaf and disabled relay service, relay services, and rural payphones. Carriers with qualifying NZ revenue above NZ$10M are liable. In 2024 the Commerce Commission determined that Starlink met this test, with NZ$74M+ in qualifying revenue. LEO operators should pay because they capture the most commercially attractive rural subscribers. Those subscribers would otherwise contribute to the cross-subsidy through terrestrial carriers. MBIE should now review whether the NZ$10M threshold and the TDL rate remain calibrated as LEO penetration grows.

Question 2

How would active RAN sharing between One NZ and 2degrees work in practice?

Accepted Answer

Active RAN sharing means two operators share the active radio equipment - antennas, baseband units and spectrum. This goes beyond passive sharing of masts and power infrastructure, which is already common in NZ. Each operator retains its own core network and retail differentiation, but avoids duplicating the most capital-intensive rural access layer. The Commerce Commission would need to issue guidance permitting this in designated geographic zones, under a presumption of permissibility. That guidance should explicitly treat LEO D2C as a competitive backstop. In those zones, LEO D2C makes retail differentiation through coverage separation economically unjustifiable.

Question 3

What are the 111 emergency obligations for direct-to-cell satellite services in New Zealand?

Accepted Answer

111 obligations under the 111 Contact Code require carriers to ensure subscribers can reach emergency services. For D2C satellite services delivered through One NZ or Spark's network, it is unclear whether those obligations extend to satellite connections. The subscriber may effectively be outside the 111 framework when connecting via satellite. MBIE should extend the 111 Contact Code to satellite-primary households. This would require either mandatory emergency routing capability or explicit written disclosure that the service does not support 111 calls.

Question 4

What is New Zealand's copper withdrawal timeline and how does Starlink fit in?

Accepted Answer

Copper withdrawal in the UFB footprint (87% of NZ population) is already under way. Chorus is decommissioning its copper network in UFB areas as customers migrate to fibre. The Copper Withdrawal Code sets out the process. However, it does not formally recognise Starlink as a qualifying broadband alternative for customers outside the UFB footprint who cannot take fibre. MBIE should amend the Code to formally recognise Starlink's current service specification as a qualifying alternative. It should also consult on a firm national copper retirement date of December 2030.

Question 5

Why does New Zealand face a civil defence risk from LEO satellite bypass?

Accepted Answer

New Zealand's seismic and weather exposure - particularly on the South Island - means terrestrial network outages during civil emergencies are a real risk. LEO D2C services can provide coverage where terrestrial networks are absent or fail. But some may operate outside the 111 Contact Code framework, without domestic gateways that GCSB can access for lawful interception. That would create a two-tier emergency communications system: one regulated and available to emergency services, one not. NEMA's engagement with MBIE on the 111 Code extension is as much an emergency management question as a telecommunications regulatory one.

New Zealand's LEO and Hyperscaler Regulatory Gap: The Case for Reform

Abstract

Key Takeaways

What's Inside

New Zealand's Sovereign Asset Exposure

The Strategy Pivot: New Zealand's Regulatory Framework

The Policy Roadmap: Commerce Commission and MBIE

Frequently Asked Questions

Sources

Abstract

Key Takeaways

What's Inside

New Zealand's Sovereign Asset Exposure

The Strategy Pivot: New Zealand's Regulatory Framework

The Policy Roadmap: Commerce Commission and MBIE

Frequently Asked Questions

Related Reports

Sources

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