02 March 2026
Sam Brown
[FYI request #33428 email]
Reference: OIA2526-0723 & OIA2526-0819
Tēnā koe Sam,
Official Information Act request relating to critical communications resilience and
emergency service dependencies
Thank you for your Of icial Information Act 1982 (OIA) requests received on 5 January 2025
and 30 January 2025. You requested:
1. Current emergency communications plans and protocols, including what percentage
of critical communications capacity relies on satellite systems, and specifically, what
proportion depends on foreign-controlled commercial satellite providers.
2. Any risk assessments, contingency plans, or advice regarding service continuity
scenarios where satellite communications providers become unavailable, whether
due to technical failure, withdrawal of service, foreign government direction to the
provider, or geopolitical disruption.
3. Backup communications arrangements and redundancy planning for scenarios
where primary satellite services are degraded or unavailable, including assessment
of whether terrestrial alternatives provide adequate coverage for emergency
response.
4. Any advice or analysis on the resilience implications of geographic concentration in
critical communications infrastructure, or conversely the benefits of maintaining
diverse technology platforms and multiple service providers.
5. Any review or assessment conducted following recent civil defence emergencies
(such as Cyclone Gabrielle) regarding the performance and reliability of different
communications technologies during extreme weather events or natural disasters.
6. Correspondence with telecommunications providers regarding service level
expectations, prioritisation arrangements, or mandatory service continuation
requirements during declared emergencies.
And:
7. Any risk assessments, threat analyses, briefings, or advice provided to Ministers or
senior officials regarding national security implications of New Zealand's increasing
reliance on foreign-controlled satellite communications systems (specifical y
Starlink/SpaceX operated by Elon Musk) for critical infrastructure, emergency
services, or government communications.
8. Any assessment of whether a single individual having operational control over critical
communications infrastructure used by New Zealand emergency services,
government agencies, or essential services creates unacceptable national security or
resilience risks, particularly where that individual has demonstrated wil ingness to
disable services in geopolitical contexts (for example, limiting Starlink service during
the Ukraine conflict or declining to provide service to Taiwan)
23 Kate Sheppard Place | PO Box 5010 | Wellington 6140 | New Zealand
Tel: +64 4 830 5100 | [NEMA request email] | www.civildefence.govt.nz
On 9 February 2025 we contacted you regarding the scope of these requests. On the same
day, you refined your requests to be for:
1. Cyclone Gabrielle Communications Review (public interest priority) Any assessment,
review, lessons learned, or debrief documents regarding communications technology
performance during Cyclone Gabrielle, specifically:
a. Which communication systems failed or degraded
b. Which systems proved most resilient
c. Any identified gaps in communications redundancy
d. Recommendations for improving resilience
2. Satellite Provider Dependency Risk Assessment Any documented risk assessments,
briefings, or advice regarding:
a. Operational resilience if satellite communications providers become
unavailable
b. Dependency on foreign-controlled commercial satellite services for
emergency communications
c. Service continuity planning if primary satellite providers withdraw service
3. Current Emergency Communications Architecture I accept your proposed "overview
of general approach" for current planning, but request it include:
a. What proportion of critical emergency communications relies on satellite vs.
terrestrial infrastructure
b. Whether redundancy planning assumes the availability of multiple technology
platforms
4. Telecommunications Provider Engagement (narrowed scope) Any substantive
correspondence or agreements with Starlink/SpaceX or other LEOSat providers
regarding:
a. Service level expectations during emergencies
b. Prioritisation arrangements for emergency services
c. Service continuation commitments during disruptions
•
Exclusions to reduce scope:
o
No routine administrative emails or meeting scheduling
o
Timeframe limited to 1 January 2022 - present (4 years)
o
Exclude information already proactively released (provide links instead)
The time frame for responding to your 5 January 2025 request was extended under
section 15A of the Act by 15 working days because it necessitated a search through a
large quantity of before a decision could be made on the request. Following this
extension, I can now respond.
Response
I have responded to your queries in turn below:
Question 1 - Cyclone Gabrielle Communications Review
23 Kate Sheppard Place | PO Box 5010 | Wellington 6140 | New Zealand
Tel: +64 4 830 5100 | [NEMA request email] | www.civildefence.govt.nz
Cyclone Gabrielle caused widespread disruption to communications infrastructure,
particularly in areas where physical damage and loss of power affected terrestrial networks.
Impacts varied significantly depending on local conditions, including infrastructure
vulnerability, geographic isolation, and the availability of backup power. For example, fibre
connectivity was disrupted where physical routes carrying cables were damaged, cellular
services were degraded where sites lost power or were physically impacted, and alternative
systems were constrained where backup power was unavailable.
Where terrestrial communications infrastructure was disrupted, satellite connectivity was
used by multiple agencies to help restore communications capability. This included the
deployment of commercial Low Earth Orbit (LEO) satellite services, such as Starlink, which
was rapidly established in areas where ground-based networks are unavailable. These
services formed one component of a broader set of communication measures implemented
during the response.
New Zealand’s Civil Defence Emergency Management (CDEM) system operates under a
devolved model. While NEMA provides national coordination, policy, and guidance,
operational communications capability and infrastructure investment decisions sit with
individual CDEM Groups, local authorities, telecommunications providers, and other
agencies. As such, NEMA does not hold comprehensive, centrally validated information
comparing the performance or resilience of specific communications systems across all
affected areas.
I am refusing your request for an assessment document under section 18(e) of the OIA, as
the document does not exist.
Question 2 - Satellite Provider Dependency Risk Assessment
Satellite communications form one component of NEMA’s broader emergency
communications arrangements. Planning for communications resilience considers the
potential unavailability of any single technology or provider and emphasises the use of
multiple independent platforms where appropriate.
New Zealand, like most countries, relies on commercially operated satellite services, many
of which are foreign owned. Resilience planning therefore focuses on diversification across
providers and technologies rather than reliance on any single service.
Continuity planning assumes that individual services or providers may become unavailable
and emphasised the ability to transition to alternative communication methods if required.
Satellite services are used alongside terrestrial networks and radio systems as part of a
layered approach to maintaining communications during emergencies.
Question 3 - Emergency Communications Architecture
NEMA’s Emergency communications rely on a combination of technologies, including
terrestrial telecommunications networks, radio systems, and satellite services.
Communications capability varies across regions depending on local infrastructure,
geographic conditions, and investment decisions.
As stated previously, New Zealand’s CDEM system operates under a devolved model. As
such, NEMA does not hold comprehensive national data quantifying the proportion of critical
emergency communications that rely on satellite versus terrestrial infrastructure.
Redundancy planning assumes that individual systems or technologies may become
unavailable during a major emergency. Accordingly, planning emphasises the use of
23 Kate Sheppard Place | PO Box 5010 | Wellington 6140 | New Zealand
Tel: +64 4 830 5100 | [NEMA request email] | www.civildefence.govt.nz
alternative communication methods across dif erent platforms rather than reliance on any
single technology.
Question 4 -Telecommunications Provider Engagement
NEMA engages with telecommunications providers, including satellite service providers, as
part of preparedness and response planning. During emergencies, services may be
procured to support operational needs where existing infrastructure is disrupted.
The remainder of your request is refused under section 18(f) of the OIA due to substantial
collation and research.
You have the right to ask the Ombudsman to investigate and review my decision under
section 28(3) of the Act.
Nāku noa, nā,
Stefan Weir
Chief of Staff
23 Kate Sheppard Place | PO Box 5010 | Wellington 6140 | New Zealand
Tel: +64 4 830 5100 | [NEMA request email] | www.civildefence.govt.nz
Document Outline
