THE 2021 Regional Telecommunications Review was recently released to the public with a long list of recommendations covering mobile black spots, repairs to existing copper landlines, internet speeds, social impacts and better collaboration amongst various levels of government to deliver services to rural areas.

The list didn’t end there – the review is a thorough 112-page downloadable document and its findings and recommendations were composed “through an extensive consultation process with regional, rural and remote communities” by the five-person Regional Telecommunications Independent Review Committee (RTIRC).

Every three years the subject is reviewed, and the 2021-and-fifth committee received a record-breaking 658 written submissions, along with strong feedback from 24 online consultation sessions attended by almost 500 people.

Committee chair, Luke Hartsuyker was pleased with the depth of the review, in that it didn’t just highlight problems, but also sought to bring practical and realistic solutions to the table.

“The record public engagement with the review is a reflection of the critical importance of communications for regional, rural and remote communities and businesses,” he said.

“Public feedback has given the committee evidence surrounding the use of regional telecommunications and will help set out a pathway forward for government and industry.

“Reliable telecommunications are essential for everyday life in regional, rural and remote Australia and have assumed a role much more on par with electricity. This was evident when the communications system goes down, as in recent bush fires, floods, and cyclones. In the same way that we need to keep the lights going, we also need to keep data flowing.”

The review noted that since the previous (2018 Edwards) review, “connectivity has assumed a more vital role in the lives of all Australians and the Australian economy, including regional areas”, but conceded establishing this foundation remained “a work in progress”.

Compiled below are some key parts of the document.

Emergency services reliance

Access to reliable telecommunications services has never before been more important to regional, rural and remote Australians.

Since 2018, this has been brought home by the devastating impacts of several natural disasters across the country, including the 2019-20 bushfires, the 2021 Eastern Australia floods and Cyclone Seroja, as well as the impact of the COVID-19 pandemic.

In regional, rural and remote areas, it is critical to have a working service in what are sometimes life-or-death situations.

To ensure this, many consumers have multiple telecommunications services to provide redundancy when it is most needed, even at considerable additional expense to themselves.

Throughout consultations, emergency services personnel reported that dedicated emergency networks, such as trunked government radio, quickly become congested during emergency situations and therefore are generally reserved for short, sharp voice communications.

As such, commercial mobile and broadband services are often used to communicate real-time information, including data, between and within emergency services agencies during emergencies.

‘At petrol stations [on the South Coast, following the 2019-20 bushfires], no-one could pay for fuel because no one has cash anymore. ‘They couldn’t get EFTPOS machines working because they couldn’t get a transmission line out there, so no-one could pay ... [People] had money in the bank but couldn’t even pull it out of an ATM.’ - Resilience NSW commissioner, Shane Fitzsimmons.

‘[Poor mobile service] compromises my ability ... as a volunteer emergency service driver with the (New South Wales Rural Fire Service (RFS). I am one of three active qualified drivers ... If there is no driver ... we have no way of communicating with other ... crews to respond to the emergency.’ - Rick Murray submission.

We note that, in addition to tools like cell broadcasting, roaming could help to improve the reliability and utility of mobile networks both during and after natural disasters.

In particular, access to reliable mobile connectivity, regardless of provider, would assist emergency personnel to effectively coordinate response measures, particularly where individual networks fail due to power outage or damage, but others remain operational.

We would therefore encourage both policymakers and mobile network operators to consider the feasibility for roaming to be trialled on infrastructure in disaster affected areas as part of a range of measures to ensure there is access to reliable communications in emergency situations.

General mobile service and data standards

We also note that mobile voice and data services are not subject to any regulatory availability or repair standards, apart from general consumer guarantees in the Australian Consumer Law.

This reflects the generally competitive nature of the mobile market (predominantly in urban areas), where dissatisfied consumers can switch networks.

However, in many regional, rural and remote areas, the absence of competing providers of mobile voice and data markets mean there can be insufficient competitive pressure to incentivise providers to undertake timely maintenance and repairs on mobile network infrastructure.

The Committee has heard instances of faults on regional mobile base stations going unaddressed for extended periods, with significant impacts for local businesses and residents, particularly in relation to the operation of EFTPOS.

Participants to the Review have also raised concerns around the closure of the Telstra 3G network by 2024.

This includes a perception amongst some consumers that the deployment of 4G or 5G networks to replace the 3G network may lead to reduced coverage outcomes in regional areas.

We were advised of multiple instances where consumers’ difficulties resolving simple issues took excessive time, commitment and persistence.

As a last resort, regional consumers have been forced into contacting the Telecommunications Industry Ombudsman (TIO) or their local Member of Parliament for their issue to be fixed.

However, even then, timeframes to repair issues can be lengthy and, although consumers are offered compensation, the issues often reoccur and may require repeated escalation.

As a result, people are often left fatigued from trying to address their problems, resulting in them giving up on finding a solution and living with less than optimal telecommunications.

2030 Digital Economy Strategy (DES) and population growth in regional areas

Digital connectivity is critical to the growth and resilience of the Australian economy, including in regional, rural and remote Australia.

This is reflected in the Australian Government’s recently released DES, which sets out a vision for the digitisation of almost all aspects of Australian society by 2030.

Given the increasing importance of digital connectivity in enabling economic and social outcomes now and into the future, we argue that telecommunications infrastructure should be considered the equal of transport and energy infrastructure in terms of scale, funding and planning.

It is clear that regional, rural and remote Australia will have a vital part in realising the DES goals.

Regional Australia accounts for approximately one-third of the Australian population, and some 40 per cent of Australia’s total economic output.

Key regional sectors like agriculture, manufacturing and mining contribute significantly to our economy, complemented by growing opportunities in health, education, tourism and other services.

Many of these are driven by small businesses.

Equitable access to, and engagement with, the digital economy will be vital in supporting the productivity and success of these regional industries, thus driving national economic growth.

More recently, the Australian Government has announced work on a ‘regionalisation’ agenda, focused on driving private-sector employment, population growth and economic diversification in regional areas.

This agenda leverages the increasing rate of net internal migration to large regional centres during and following the COVID-19 pandemic, as professionals and working families are attracted to the financial and lifestyle benefits offered by the regions.

According to YouGov research commissioned by NBN Co, 74 per cent of Australians believe that access to fast and reliable broadband is necessary to achieve a flexible lifestyle, including relocation to regional areas.

Legacy copper landlines and the 2032 deadline

The Australian Government has guaranteed the universal provision of voice services under legislation.

Copper landlines in regional, rural and remote areas are deteriorating and their reliability has been impacted.

While voice and broadband services generally experience high levels of availability, low fault rates and are connected and repaired in regulated timeframes, there remains a small cohort of users that experience unacceptable issues in getting their services repaired.

It is also becoming more and more difficult to source parts to undertake repair and maintenance on legacy systems.

There is continued concern around ongoing service delivery under the Universal Service Obligation (USO), which legislates the provision of standard telephone services and payphone services to all premises in Australia.

Telstra’s ongoing legislated role as the USO provider for voice and payphones is complemented by the Telstra

USO Performance Agreement (TUSOPA).

Under this agreement, which runs to 2032, Telstra receives $230 million per annum (GST exclusive) to provide fixed telephone services and $40 million per annum (GST exclusive) to provide payphone services.

USO and other public interest telecommunications services are funded by Australian Government funding (which contributes $100 million per annum), with the remaining funding required raised from an industry levy.

The USO covers the provision of telephone services nationally, including in urban areas where Telstra uses the NBN.

However, the role of the USO often focuses on rural and remote areas where Telstra still needs to provide its own infrastructure if required, and where the provision of telephone services remains generally uncommercial.

The TUSOPA contains a copper continuity provision, which requires Telstra to maintain existing copper landlines in areas outside of the NBN fixed line footprint.

At present, Telstra delivers approximately 400,000 telephone services outside the NBN fixed line footprint, largely via the copper network.

Where mobile coverage is inadequate, landline telephony remains essential for regional users.

In rural communities (201 to 9,999 people) and remote communities (up to 200 people), Telstra is required to either repair faults on USO services within two and three working days respectively, to offer alternative solutions, or to pay compensation.

In its submission to the Review, the TIO also provides case studies of serious delays in rectifying landline outages, and reports that it received 3833 complaints regarding regional landline services in 2020-21 (although it is noted that this number has declined year-on- year since 2018-19).

Limited internet data

The increasing demand for data in regional, rural and remote Australia is not always being adequately met by the oftentimes constrained connectivity options available to regional consumers.

Participants in the Review have reported significant congestion issues, particularly on the mobile and NBN fixed wireless networks, which are impacting everyday business transactions and other activities.

While the costs of continuous capacity upgrades are high, telecommunications network operators have a responsibility to invest in their networks to prevent major network congestion which impacts quality of service.

The growth in data consumption has been a long-standing phenomenon and is largely predictable.

Data from NBN Co shows that download consumption per month on the NBN has increased by 820 per cent between December 2012 and June 2019, with a further 16 per cent growth in average monthly data download per user between 2018-19 and 2019-20.

In 2018-19, the non-metro component of total data consumption on the NBN was 48 per cent, with regional monthly average download per user at 246 GB (compared to 270 GB for metro users).

NBN Co reports that during the peak of initial COVID-19 lockdowns in April 2020, average monthly downloads were 11 per cent higher than the yearly average, rising from 297 GB to 330 GB.

Increased use of data intensive applications like videoconferencing, cloud services and Virtual Private Networks (VPNs) also led to an increase in upload data usage per user, increasing by 27 per cent between February and April 2020 (from 22 GB per month to 34 GB per month).

As flexible work arrangements continue into the future, upload data consumption is likely to continue to increase.

NBN Co … predicts that customer demand on the NBN will grow by 300 per cent over the next 10 years.

The Committee has heard numerous reports of congestion on the mobile and NBN fixed wireless networks in regional, rural and remote areas.

Many attendees to the public consultations noted extremely slow download and upload capacity during peak periods of use, especially in the tourist season and evening period, despite having a strong connection to the network.

However, it is clear to the Committee that overall, investment in additional network capacity is not keeping pace with increasing demand in regional, rural and remote areas.

We have heard that as regional mobile networks are deployed or upgraded, pent-up demand for data is released and sites quickly become congested again as users readily take full advantage of improved speeds and access to data.

Given this, we are concerned mobile network operators may not be adequately scoping capacity upgrades to account for what are largely predictable trends in data consumption over the long-term.

Unique needs of farmers

Primary producers are increasingly using Internet of things (IoT)-connected devices to collect, process and analyse data to assist in productivity-enhancing decision-making across areas like nutrient regulation and application, land use, animal health, climate risks, water efficiency and other production related factors.

This data also plays a critical role in regulatory compliance, logistics and the marketing of products to consumers.

Appropriate connectivity options, including several emerging technologies, are necessary to deliver the potential productivity gains from the increased use of data in regional economic sectors.

Connected devices like sensors, drones and automated machinery, as well as artificial intelligence and machine-learning, are enabling producers and suppliers to undertake real-time and predictive analytics to improve productivity, manage input costs, comply with industry regulations and improve the traceability of products through supply chains.

As of June 2020, there were an estimated 4.4 million IoT services in Australia.

The International Data Corporation (IDC) predicts that there will be 55.7 billion connected IoT devices worldwide by 2025, generating almost 80 billion zettabytes of data.

The Australian Computer Society suggests that by 2050, the average farm will produce 4.1 million data points per day using IoT connected devices.

In order for these smart devices to realise productivity gains and drive growth in regional industries, they require appropriate connectivity options which are able to support the collection, processing and analysis of the data they generate.

Satellite (Sky Muster) services

Given that NBN Co indicates that average data usage on a Sky Muster Plus plan is approximately two to three times that on the standard Sky Muster service, we argue there is unmet demand for data on the standard Sky Muster network, which continues to inhibit users from fully realising the economic and social benefits of the service.

Satellite users have told us that their usage of the service is highly self-moderated due to the number of variables they need to consider, including data limits, ‘peak’ and ‘off-peak’ periods, and whether they can purchase additional data blocks or change their plans once they reach their monthly data cap.

Even for Sky Muster Plus users, there is some confusion around which types of data are metered, which likely inhibits them from using their connections to the same extent as those on fixed line or fixed wireless services.

Even where data limits or unmetered data are sufficient for data-intensive use-cases, the high latency on Sky Muster may also continue to impede users from fully utilising the service.

The two satellites that provide the Sky Muster service are in geosynchronous orbit at a distance of approximately 35,700 km above the Earth, which significantly increases the time it takes for data to travel between the end-user and the wider network.

Users report that latency on the service can be as high as 800 milliseconds, which is up to 80 times higher than on the NBN fixed-line network.

Feedback received during consultations and submissions suggests that available download speeds on the fixed wireless and Sky Muster networks are currently sufficient for most purposes, including streaming.

However, regional users have identified that maximum available upload speeds, which are generally around 5 to 10 Mbps, are quickly becoming unsuitable for everyday business activities, including the use of cloud applications and videoconferencing tools while working from home.

Many contributors to the Review suggested that Low Earth Orbit (LEO) satellite services have the potential to significantly transform the regional telecommunications landscape.

These satellites orbit much closer to the Earth’s surface … however, a larger number of satellites is needed to provide consistent connectivity, with LEO satellites operating in constellations often comprising thousands of units.

The closer proximity of LEO satellites reduces latency and the sheer number of satellites helps to enable higher capacity and speeds.

The most mature LEO satellite provider is SpaceX, whose Starlink service currently has approximately 1700 LEO satellites in orbit.

Early adopters of the SpaceX Starlink service reporting download speeds of up to 300 Mbps (though this is likely to fall to 150 Mbps as network demand increases), and data is unlimited on the service.

LEO satellite technology is promising and could realise a step change in the delivery of services in regional, rural and remote areas.

However, we note that the industry is still in its infancy and services are yet to be deployed at scale.

There are also a number of unproven issues around LEO satellite constellations, including service reliability.

For instance, the number of satellites in a constellation and the limited anticipated lifespan of each satellite may require providers to constantly deploy new units, increasing costs for providers and end-users.

Additionally, end-user terminals remain untested in extreme weather conditions common to the Australian climate … as per other satellites, LEO satellites are also impacted by vegetation, hilly terrain and climatic conditions like heavy rain.

Digital literacy vs connectivity literacy

Connectivity literacy, a concept first developed by Better Internet for Rural, Regional and Remote Australia (BIRRR), refers to the skills and knowledge needed by a consumer to get connected and stay connected to telecommunications services.

 It is separate from digital literacy as it is the skills required to navigate through a choice of providers and technologies, understand terminologies, plans and equipment, which are different skills to what are needed to physically use the service for specific activities.

For some consumers connectivity literacy is the first step on the path to digital literacy; however, for others, being digitally literate does not necessarily mean that they have the skills to get connected.

Many regional users are dealing with complexities in identifying and resolving service and infrastructure problems.

However, the complexity of regional connectivity issues and solutions is not only poorly understood by consumers and regional users, but also telecommunications providers and customer service staff.

Regional consumers, businesses and local government need access to independent advice and improved connectivity literacy to support them in making informed connectivity choices.

There may be a role for the Regional Tech Hub in supporting local governments and regional stakeholder organisations to identify and understand the connectivity options available to them and their communities.

The governance framework of the Regional Tech Hub should also be updated to include an expert advisory panel with appropriate experience across regional telecommunications, regional development and engagement.

One of the largest challenges faced by consumers is the large number of myths that persist about telecommunications services in regional, rural and remote areas, spread by inaccurate or misleading information.

The Committee was made aware during the public consultations of a number of inaccuracies related to the delivery of NBN services in particular.

These include users being told that the NBN is not available in their area (despite the ubiquity of Sky Muster), or alternatively, that it is compulsory to move to the NBN in areas served by ADSL.

Consumers are not always informed or well-supported enough to challenge inaccurate information, and this impacts on the decisions they make.

Affordability

The affordability of telecommunications services for regional, rural and remote Australians is an ongoing issue.

Although telecommunications affordability is improving, regional Australians are paying a higher proportion of their income on telecommunications than their urban counterparts due to reduced consumer choice in technologies and plans, as well as the need to maintain multiple forms of connectivity where services are unreliable.

As government services move online, the affordability of data is a key concern.

Unmetering or ‘de-rating’ the data charges from the use of platforms like myGov, as well as offering a subsided NBN product for low-income earners, are measures which could improve equitable access to essential online services.

The concentration of low-income households in regional Australia makes the affordability of telecommunications services a key barrier to digital inclusion.

The 2021 Australian Digital Inclusion Index (ADII) found that 47 per cent of the regional population are impacted by the affordability of telecommunications services, compared to 35 per cent of the metropolitan population.

Further, regional Australians are paying a higher proportion of their income on telecommunications, with 33 per cent of the regional population paying up to 10 per cent of their household income, compared to 21 per cent of metropolitan population.

Indigenous access

The Committee is aware that Indigenous Australians have lower levels of digital participation than the Australian population due to a combination of factors.

These include more limited access to infrastructure, the affordability of telecommunications services, and reduced levels of digital skills and confidence.

An estimated 30 per cent of remote and very remote Indigenous people do not have household telephone or internet access.

In some remote Indigenous communities, most people do not have the option of home schooling, working from home, or accessing basic services online due to cultural and affordability barriers.

Shared network access a possible solution to Mobile Black Spot Program (MBSP)

Given the significant costs of network deployment over vast distances, it is impractical to provide universal mobile coverage across the entire Australian landmass.

Even where mobile infrastructure exists, coverage outcomes can be influenced by a number of technical and physical factors, including network configuration and local terrain.

According to mobile network operators, mobile coverage is now indicatively available to an estimated 99.5 per cent of the Australian population and 33 per cent of the Australian landmass.

However … we have doubts about the accuracy and consistency of the mobile coverage data available to consumers.

‘Telstra may have a continuous network of towers along a major road for a significant distance (with some towers even installed via the ‘Blackspot’ program), then there is a critical gap in Telstra coverage which does not meet ‘Blackspot’ criteria as there is already a rival operators tower in place ... users ... need two different carriers’ devices to bridge the gap.’ - City of Greater Geraldton submission.

While market conditions in Australia are different to those in other jurisdictions, we note the successful outcomes of passive and active Radio Access Network (RAN) sharing arrangements between multiple carriers in the United Kingdom and New Zealand.

These initiatives are using industry cooperation to deliver expanded geographic mobile coverage outcomes at reduced cost to each participating provider.

Under Round 5A of the MBSP, mobile network infrastructure provider and operator Field Solutions Group (FSG) was awarded funding to undertake two trials of new mobile deployment models in partnership with Optus.

The first trial involves the use of an active neutral host RAN to deliver coverage from FSG’s Regional Australia Network and the Optus mobile network on seven new mobile towers along Queensland’s Adventure Way between Thargomindah and Cunnamulla.

The neutral host model will use a single set of electronics and radio equipment on each tower to deliver coverage from both providers, with the potential to accommodate additional carriers.

The trial aims to demonstrate the technical feasibility of the neutral host model, as well as its benefits in reducing costs for mobile network operators and driving competitive coverage outcomes in less economically viable areas of rural Australia.

The second trial will utilise a domestic roaming arrangement to allow Optus customers to ‘roam’ onto FSG’s Regional Australia Network in regional, rural and remote areas.

Under this arrangement, Optus subscribers will be able to continue to use Optus voice and data services on their mobile device when visiting an area with coverage on the FSG Regional Australia Network.

The trial aims to demonstrate the ability for place-based networks in areas unlikely to be served by traditional mobile network operators to realise cost effective connectivity for customers of these providers through a domestic roaming agreement.

Accuracy of coverage maps

We note that coverage data is predictive, meaning it uses a number of technical assumptions to indicate the likely areas to receive coverage from nearby base stations and may not accurately reflect a user’s actual coverage experience.

‘[The Australian Government should] develop a national telecommunications map, depicting mobile, broadband and trunk coverage, including network capacity using available data sets.’ - Northern Territory Government submission. 

Lack of collaboration leading to communities missing connectivity opportunities

Some stakeholders have suggested that the multitude of separate and often competing Australian, state and territory government investments may be compounding existing digital divides in regional areas by deploying small-scale telecommunications interventions which lack interoperability and consistency, even within regions.

The Committee heard examples of this, including instances where fibre connectivity, funded by state education departments, has been delivered to schools without access being provided to the surrounding community.

Also, as identified by the Isolated Children’s Parents’ Association (ICPA) and some other Review participants, broadband procurement processes undertaken by state departments, may not always deliver solutions that meet the particular needs of regional schools, health centres and the wider area.

In our view, this speaks to a need for improved cross-government collaboration in setting and acting upon strategic priorities for regional telecommunications investment through a formal investment and planning framework.

The Committee considers that a more effective targeted approach to regional telecommunications investment should encompass the Australian Government partnering directly with state and territory governments to identify shared priority regions or corridors of economic and social growth.

Funding could then be offered for the telecommunications industry to partner with the local community on the co-design of telecommunications infrastructure projects which address the identified digital connectivity needs of these regions.

Other contributors to the Review have expressed the desire to access existing fibre networks to deploy improved telecommunications services to their communities.

In both an online consultation and submission, representatives from the Shire of Ngaanyatjarraku in remote Western Australia noted there is a major fibre route traversing the Great Central Road, with access pits in a community within the Shire.

The Shire has engaged with private providers regarding the potential to deploy community Wi-Fi to address local network congestion and provide access to essential online services.

However, they identified they are unable to utilise the existing fibre due to the high cost of access.

We have heard similar claims from other councils, who also note a lack of public information on the availability of fibre in their regions to inform potential investment in ‘last-mile’ infrastructure.

In submissions and consultations, councils have asked for publicly available and comprehensive mapping of both fibre routes and their network capacity in order to identify gaps in access or redundancy, as well as opportunities to use spare capacity on existing fibre to deploy telecommunications services to their communities.

State governments are also opening up spare capacity on fibre used for state-owned utilities and rail in regional areas.

For instance, QCN Fibre, a Queensland State Government Owned Corporation, utilises spare capacity on Powerlink and Energy Queensland’s 12,000-kilometre fibre network across regional Queensland to provide wholesale transmission capacity to internet and retail service providers (RSPs) at metro-equivalent pricing.

Similarly, in Victoria, VicTrack has deployed fibre capacity along rail easements in regional areas and has made this available to broadband providers to deliver business fibre services to regional centres.

Summary

Mr Hartsuyker hoped the review would be a useful resource to help continue moving Australia forward as it grapples with a low population density in regional areas but the growing need to implement digital tools at a satisfactory level.

“There is a new paradigm in the way we use telecommunications and Australia will be relying even more on digital connectivity as it strives to become a leading digital economy,” he said.

“Regional Australia will play a vital part in meeting this goal.

“Australia is now at a crossroads where it can either risk the digital divide expanding, or see the regions flourish. It is important that the digital divide does not widen, and that regional, rural and remote Australians are not left behind as Australia reaps the benefits of the digital economy.

“The decisions that are made now will determine whether the regions live up to their extraordinary potential as a great place to live, work, invest and do business.”

The 2021 Regional Telecommunications Review is available for download at https://bit.ly/3HazNY7 as a pdf or Word document.