SUBMISSION TO RURAL TELECOMMUNICATIONS REVIEW 2015

ON BEHALF OF

Upper Shoalhaven Valley Residents Group

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1. Introduction.

This submission concerns the area in the Southern Tablelands of NSW which lies midway between Canberra and the coast and south of Braidwood and which could be called the Upper Shoalhaven Valley (the Valley). More specifically, the Valley comprises the area reaching south from Jerrabattgulla Creek (750 metres altitude) through Gundillion and Krawarree (both named after local properties) to the ridgeline on Cooma Road above the Shoalhaven catchment, locally known as Pikes Saddle (1200 metres), a distance of approximately 50 kilometres.

The Shoalhaven River rises in the southern end of the Valley, in the area north of Pikes Saddle and flows north through the full length of the Valley. The Valley is bounded on the eastern side by the Minuma Range (1200 metres) and to the west by the Gourock Range (1400 metres), which are separated by approximately fifteen kilometres.

The Valley therefore encompasses slightly more than 750 square kilometres, all of which lies within the Palerang local government area.

More than 50% of the total area in the Valley is public lands, predominantly National Parks and State Forests. The freehold land in the Valley is mostly dedicated to rural activities, principally grazing, however there is a range of other rural and tourist industries.

The rural community is dispersed more or less evenly through the freehold area. There are no villages, towns or other small communities in the Valley. To the north the closest village is Majors Creek (approx. 20 kms) and the closest town is Braidwood (approx. 30 kms). To the south, the closest village is Numeralla (approx. 40 kms) and the closest town is Cooma (approx. 60 kms).

The social focus of the community is the Gundillion Hall, which is the only community or commercial premises in the region. The Krawarree Rural Fire Brigade has a shed adjacent the Hall.

A single road (Cooma Road) runs north-south through the Valley, roughly parallel to and to the west of the Shoalhaven River. Cooma Road runs from Braidwood in the north, through the Valley, over Pikes Saddle and on to Cooma to the south. Cooma Road is sealed as far as Krawarree and then continues unsealed over Pikes Saddle and for approximately another 25 kilometres.

Cooma Road forms part of the Nowra-Nerriga-Braidwood-Numeralla-Cooma route, which is the most direct access to the snowfields and the southern National Parks recreation areas from the southern Sydney area. Despite being unsealed for long sections, Cooma Road sees heavy snow-bound traffic throughout winter and substantial recreational 4-WD traffic at other times.

Jerrabattgulla Road, also unsealed, divides from and then loops to the west of Cooma Road at Jerrabattgulla Creek before rejoining Cooma Road to the south of Gundillion, a distance

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of approximately 20 kms. With the exception of several short, dead-end access roads, there are no other all-weather, 2-WD roads in the Valley. There are no public roads running east-west through the Valley.

There are a number of unsealed fire trails and 4-WD recreational tracks in the Valley, such as that giving access to the Deua National Park to the east of the Minuma Range. However these tracks are not all-weather roads and are frequently closed or impassable, even to 4-WD vehicles.

It is difficult to estimate the residential population of the Valley. Much of the private land has been purchased in small lots by absentee landlords who are resident elsewhere, most frequently in regional population centres such as Canberra, Sydney and the NSW South Coast towns. We estimate that the Valley has approximately 300 dwellings.

Telecommunications in the Valley

There is a copper-wire telephone service operating out of a small Exchange to the south of Gundillion (the Gundillion Exchange). There are no other telecommunications system(s) available in the Valley.

The copper wire system is in poor condition and is very unreliable. The in-ground wire is reported to have taken many lightning strikes and damage and even at its best it is frequently noisy and intrusive. In many places the in-ground wire is exposed and unprotected. Wire replacing that which has been irretrievably damaged or washed away by flooding is in places draped across open areas and hung across waterways between trees, the original wire support posts and systems having decayed to the point of uselessness and not replaced.

The technology in the Gundillion Exchange is reportedly obsolete and unreliable. Recent long outages in the Exchange are said to have been the result of air-conditioning failures and the difficulty in sourcing spares and outdated technical skills. The nine days that it took to source spares and technical skills to repair the Exchange in December 2014 corresponded to the worst period of fire risk that summer. The consequences of a bushfire at a time when the telephone system, the sole means of communications throughout the Valley, was out of service for an extended period could have been disastrous. We understand that remote sensing systems to detect actual and imminent equipment failure in the Exchange was not installed.

Recent discussions with Telstra staff confirm that Telstra has no intention of upgrading the Gundillion Exchange beyond the possible addition of remote sensing systems.

There are endless examples of copper wire, system and component failures but the most persistent cause of outages is that the copper wire system as a whole has little or no resistance to rain. Whenever the Valley experiences rains exceeding that of a passing shower, the telephone system has an outage ranging from hours to days and often more in some areas. The outage can be local or extend to most or all of the Valley.

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Telstra has recently indicated it will address some of the more obvious problems with the copper wire but these are merely Band-Aid measures when viewed against the overall decrepit state of the copper wire system.

Such a system could never be regarded as adequate but when there is no other telecommunications alternative, it frequently leaves Valley residents, businesses and recreational visitors without the support, backup and safety to which they are accustomed in areas better serviced by the telecommunications industry.

Summary

The Valley is a sparsely populated relatively remote rural region.

The existing copper wire telephone system in the Valley has been neglected and poorly maintained for decades and is now totally unacceptable in almost any performance terms.

There are currently no telecommunications system alternatives to the existing, unreliable copper wire system.

The unreliable copper wire system and the absence of any alternative communications system significantly disadvantages all businesses in the Valley and acts to depress and discourage the local economy. This disadvantage is increasing with time and the increasing sophistication of other, more modern communications systems and services.

The unreliable copper wire system and the absence of any alternative communications system significantly disadvantages all residents in the Valley and prevents the provision and adoption of many recent advances in health, education and employment services and technologies. This disadvantage is also increasesing with time and the increasing sophistication of alternative communications systems and services.

The Valley terrain presents difficulties in the provision of alternative telecommunications systems and this fact coupled with the low population density means that it is unlikely that the Valley could ever mount a business case that would support the investment necessary for alternative telecommunications systems. Sadly, it is clear that there is not an adequate business case to support normal maintenance and repair of the existing copper wire and its infrastructure.

The Valley is host to both significant through traffic and substantial recreational activities within the region’s National Parks and State Forests however there is no telecommunications systems available in those areas of road and Park which are most likely to be the scene of accident and misadventure. This places all road and Park users at significant additional risk and limits the services and support available to medical, rescue and disaster response services.

The irony is that although the Valley is located less than 100 kms as the crow flies from the National Capital our telecommunications system is at best third world and much of the time little better than the communications systems available to the settlers when they drove their oxen into the Valley in the first half of the nineteenth century!

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Responses to Issues Questions

Q1. Do people in regional Australia believe their reliance on telecommunications differs from those in urban areas? How does it differ and can you provide examples?

Please note that this and all the responses that follow are specific to the rural environment and circumstances described above.

We believe that people in this rural area suffer from significant disadvantages because they do not have an equitable, and frequently do not have any, access to the level of communications almost universally available to urban and semi-urban Australian residents. To illustrate the issues involved, we will split the rural population into two broad groups: Those who own and operate rural businesses and private Individuals.

Further, the question presumes that the rural community already has a degree of access to modern telecommunications. In our region there is only a decaying and highly unreliable copper wire telephone system. This offers only intermittent landline communications and no mobile communications whatsoever.

The effect of this limitation on this rural population is that there is no reliance on communications much beyond that evident in the middle of the last century. A brief reflection on that period (for those who experienced it) will quickly reveal the extent of the disadvantage that all of this rural population are currently experiencing.

If modern telecommunications systems were to become available to this rural population we believe that there would initially be an almost immediate and substantial improvement in almost all aspects of the business, social, health, welfare, education and competitiveness of this rural population as a whole. We would for the first time since the first great advances in telecommunications technologies enjoy the same services, conveniences and advantages that are available to the urban population.

Rural Australia has demonstrated repeatedly that it will readily and wholeheartedly adopt any and all technologies that provide advantages or added convenience in either the rural way of life or rural business. We see no reason to believe that access to modern communications technology by our rural community would be any different. Modern communications technology has already been harnessed by rural communities all across Australia and given similar access this community would quickly follow in their footsteps.

Within a very short time of gaining access to modern communications technology, we believe that the rural population would integrate it into everyday activities and become more reliant upon it than similarly engaged urban users. In most cases this reliance would flow directly or indirectly through more efficient management of travel time or transfer of people and goods between rural locations and population/service centres.

To further explain this and to provide the requested examples, let us take the first of the previously identified rural groups: Rural Business Operators.

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Rural Business Operators in our region spend most of their working day in areas and locations remote from their business premises, often alone. Having no access to any mobile communications (current situation) means that messages and data exchanges to and fro between the business operator and his clients and business base are delayed by at least the time periods between access to landline systems. This inevitably means delays in other stages of the business and a significant loss of competitive advantage.

Having access to mobile communications would facilitate day to day rural business operations in much the same way as their urban counterpart and begin to level the business playing field but the rural business operator will always suffer from the inherent disadvantage of distance because he/she does not have the same ease of access to parts, services, customers and supplies sources.

The critical issue here is that the dead time spent travelling between jobs, locations and suppliers and the associated delays in delivery of critical supplies represents a greater loss to rural businesses than their urban counterparts. The ability to reduce or eliminate this travel dead time and improve delivery times through faster, more responsive and efficient business management would increase the rural business operators’ reliance on readily accessible communications technology. Further increases in efficiency would flow from better time and space management flowing from ready access to real-time developments and customer demands.

When working alone in remote areas, any accident or vehicle problem will have safety or recovery consequences disproportionately greater for a rural worker than for his or her urban counterpart. The rural worker must therefore have a greater reliance on mobile communications.

Modern telecommunications hold much promise for rural businesses, some that are unique to the rural environment. One such example relates to the need for remote sensing and monitoring of stock, boundaries, gates, water, equipment and infrastructure, feed troughs, feral animal activity and general security. Much time is spent on rural properties visiting remote sites to monitor issues such as the above. Substantial improvements in efficiency can be achieved by the use of digital site cameras that report back to a central location using a mobile network.

Similarly, transmission of photographs and on-site video can substantially improve efficiency and reduce the costs of a wide range of professional and trades services in rural areas. For example, the local Veterinarian can diagnose animal illness and prescribe treatment without the delays and costs of site visits, remote service and parts suppliers can provide real time on-site feedback, improve service and reduce delivery times. Using mobile phones with picture or video capacity means diagnosis, advice and support is available immediately on-site and as required, eliminating lost time in transit and related costs. There are many more examples of why rural industry reliance on better telecommunications would be greater than the urban counterpart and we strongly believe this reliance will increase with advancing communications technology.

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The second identified rural group, private individuals, would also rapidly become more reliant on modern communications technologies than their urban counterparts for reasons indirectly related to distance from population centres. Private individuals in rural areas must all interact to some degree with urban populations. The time, inconvenience and delays involved in frequent travel to population centres for goods and services substantially increases the costs of rural life and detracts from the advantages. This disadvantage, cost and dislocation is generally much greater than that experienced by their urban counterpart if only because of the increased travel time and accommodation costs where overnight stays are required.

Modern telecommunications technologies provide many options to minimise or eliminate the time and costs of travel between remote rural locations and urban centres. These options are particularly evident in health care, education, entertainment, business transactions and day to day commerce as well as an increasing number of other commercial and social activities. The greater advantages to be gained from these communications services by rural people is a clear driver for greater reliance on modern telecommunications systems.

Examples of the higher degree of reliance likely to be experienced by rural residents include emergency services and some recent advances in health care. Once again, this reliance is driven by the greater distances between service providers and rural residents. Modern emergency services provide a range of advice and support which is built around mobile communications. For example: Bushfire preparation and coordination is greatly facilitated by ready access to telecommunications and is unique to rural communities.

Ambulances are equipped with remote monitoring and communications systems that allow in-transit diagnosis and support that greatly improves patient treatment both in the period before the ambulance arrives and in transit. This facility assumes greater importance to rural residents as they generally must wait longer before assistance arrives and spend longer periods in transit.

Q2. For those users already connected to an nbn network service, has the service met your expectations?

As discussed above, there has been no NBN rollout in this region nor does the NBN Rollout Map provide any anticipated date.

Q3. Having regard to the technical solution likely to be used in your area, do you have views on the adequacy of that solution in terms of meeting needs now and into the future?

There are at least two aspects to this question that need to be addressed separately.

The needs of the local community.

With our limited understanding of the technical aspects, strengths and weaknesses of the alternative telecommunications systems, it seems likely that the available options for the Valley are mobile networks and satellite. Satellite systems seem to be limited in many

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respects so we conclude that the most likely solution to our telecommunications needs is a mobile network.

Despite the difficulty of the terrain, it seems likely that as a first step a mobile network could be established in the Valley that would serve the majority of the resident population (both business and private) with a relatively modest investment, perhaps one or two towers.

If we were successful in attracting support, this might be the first priority, in parallel with a sustained effort to improve the existing copper network to provide reliable service to those not initially within the mobile network envelope. Safety, Health and Welfare

The Valley is a busy conduit for through traffic to the snow and for recreational users of the large National Parks in the region. Despite this, the section of Cooma Road that is unsealed and represents the greatest danger to road users is that which has no access to any form of communications network.

Similarly, the National Parks and State Forests in the region are all in areas not serviced by any form of communications network.

Any resident of the Valley will testify to the great number of accidents of all kinds in this region, on the roads and in the Parks, many of which are experienced by drivers and riders from urban areas who are unaccustomed to unsealed, wet, slippery, sometimes icy and generally poorly engineered roads and abundant wildlife. Any accident in this region can be serious merely because of the difficulty in reporting injury, diagnosis and appropriate first aid, identifying the accident site and the delays before support or rescue arrives.

Similar considerations apply to vehicle breakdowns in remote areas. Drivers are unable to contact repair and recovery services and consequently experience inconvenience and delays at the very least. At times of adverse weather or strong fire risk, an unreported vehicle breakdown can have substantially more serious consequences.

Response and control of other natural disasters in the region also suffers from the lack of any form of communications in these same areas. Visitors to the National Parks are effectively isolated as there is no reliable form of communication or broadcasts into the Park areas. Visitors cannot therefore be quickly advised of bushfire risk or other developing threats and natural disasters.

Mobile network coverage of the full length of Cooma Road and into the deep river valleys in the Parks would require either a much more extensive network of towers or a combination of mobile and satellite systems. Providing telecommunications networks into the Parks and along the full length of Cooma Road would likely also address most all of the more difficult private communications sites.

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Q4. Irrespective of the adequacy of your local access, are there issues with backhaul or long distance carriage that impacts on your use of telecommunications services?

This question is beyond our technical skills and understanding however we do understand that an optical cable has been laid to the Gundillion Exchange from the north.

One likely site for a mobile network tower lies adjacent Gundillion Hall, approximately one kilometre north of the Gundillion Exchange. We believe this site deserves consideration for the following reasons:

Proximity to the Gundillion Exchange; Proximity to Cooma Road; Proximity to grid power; We believe a mobile tower on this site would provide telecommunications services

to the majority of residents in the Valley; and The site is on Commonwealth land.

We understand that most of the other network options are unsuitable for the Valley due to limited range and/or the dispersed population.

Q5. For users living in areas without mobile coverage, what priorities, other than specific locations, do you consider should be recognised in future efforts to improve coverage?

The discussion above details most of the priorities and reasons we believe support our need for improved communications systems. In summary, these priorities are:

1. Mobile network covering as much of the resident population in the Valley as economically possible:

To provide equitable access to modern mobile communications and redress the imbalance between rural and urban communications facilities, services and opportunities.

2. Extensive service and repair of the existing copper wire network and update Exchange technology.

To provide a reliable communications system to those Valley residents not covered by the first stage of any mobile network system and to provide a backup system for possible mobile network outages.

Secondary objective to increase the reliability of the copper network and hence improve accident and health responses.

3. Consideration of telecommunications needs of users of Cooma Road and recreational activities within Parks and State Forests.

To improve accident, health and natural disaster responses in more remote sections of Cooma Road and National Parks.

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Q6. What opportunities do the mobile network industry see for extending coverage in regional Australia and increasing investment in mobile networks?

This question is addressed to service providers and therefore beyond our capacity to respond. However, the Valley community is strongly united and has been remarkably successful in raising funds and delivering tangible benefits to the local and adjacent communities.

We are confident that the Valley community would commit to and support any proposal to install a better, more reliable communications network. We anticipate that this support would include fund-raising and providing work in kind,

Businesses in the Valley include earthmoving, fencing and other construction and trade services, all of whom would be approached to provide support.

Q7. Do you have any views on co-investment approaches that might help to improve the broadband technology outcome in your area?

We have yet to be informed of the likely date and type of NBN service that will be provided in the Valley.

We are certain that when this detail becomes available the community will consider it and make whatever suggestion or offer is appropriate. Given this community’s past record of commitment and application, it seems likely that an appropriate offer will be made.

Q8. How might new applications and services that utilise mobile networks for voice and data transform the way you live and work?

As we have described above, we currently have no mobile telecommunications whatsoever and within the Valley confines we are locked into an outdated, unreliable copper wire system that most urban residents would regard as antediluvian.

Merely bringing Valley telecommunications services into line with that generally available within urban centres would vastly improve the competitive advantage of local businesses, attract more tourists to the region, boost the local economy and greatly increase the health, safety and amenity of the general population as well as visitors and tourists.

The benefits that we expect this single change to deliver are so great that we have difficulty arriving at a reasonable expectation however, beyond the immediate boost to the local economy and benefit to residents, there stretches the even greater opportunity to participate in the surge of new applications and spin-off technologies now being generated.

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Q9. What communications barriers have you experienced in expanding or operating your business or providing services, such as health or education? Have you been able to overcome these barriers and if so, how?

It seems almost redundant to respond to this question as the current level of telecommunications within the Valley was long ago obsolete in almost all of mainland Australia and most of the rest of the world. Valley residents on vacation have observed African cattle herders on the Maasai Mara who have better telecommunications networks than we have here in the Valley.

Without mobile communications, without the ability to send and receive text and graphics, without the ability to access the internet and the dependent technologies and applications, without the ability to access business and social support networks we will always be uncompetitive and lagging.

We could not offer suggestions of how to improve international jet flight if the only aviation experience we had was in a hot air balloon.

Q10. What communication functions (e.g. speed, mobility, reliability, data, etc.) would best suit your needs, noting the limitations of each technology (e.g. mobile, wireless, satellite, fibre)?

In our view, any improvement in communications would be greatly appreciated. Even making the current copper wire system reliable would be a great advance. Beyond that our experience is very limited. Perhaps the best approach would be to first select the network option that would provide the widest possible range of services to the greatest cross section of the Valley community.

Some network options, such as fibre and Wi-Fi are clearly not suited to the disbursed Valley community and local experience suggests that satellite systems would have inherent limitations if over-subscribed. We therefore believe that mobile networks would provide the best compromise between cost, speed and accessibility.

Q11. Do we need to continue to guarantee the standard telephone service for all (or only some) consumers, and if so, to what extent?

We have already addressed this issue. We believe that it is essential to not only continue to maintain the current copper wire network but that it also needs to be thoroughly serviced and repaired.

Because of the local terrain, it is almost inevitably there will be a percentage of the local population who will be unable to access whatever modern telecommunications network is installed. It is essential that these residents have at least some form of reliable telecommunications system and in so doing, all residents will have a backup communications system.

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Q12. Are there new or other services, the availability of which should be underpinned by consumer safeguards?

We feel unable to offer an informed response to this question. By virtue of the limited copper wire service available within the Valley we have had insufficient exposure to new services available on more modern telecommunications systems.

In general, we feel that telecommunications consumer safeguards should ensure that no person is financially, socially, medically or otherwise disadvantaged by virtue merely of his or her geographical location and that everyone should have access to a range of economic basic communications services which are independent of the network being used or the service provider.

Other safeguards, such as privacy and security are also required and will probably require periodic review and update. .

Q13. What standards should apply to your services? How might they best be enforced?

A broad range of standards should apply to all telecommunications services, as they already apply to other forms of service providers. These include guaranteed network accessibility and performance, privacy, best practice in respect of business practice and ethics, third party review and conflict resolution, protection from price manipulation, limits on commercial marketing and exploitation, transparency of contracts, charges and business practices, etc.

Experience suggest that the telecommunications industry is incapable of self- regulation, at least in respect of fees and charges, customer relations and where best practice conflicts with profitability. So it seems inevitable that an independent Authority is required with sufficient power to oblige participation by service providers and adequate power to discipline recalcitrant individuals and organisations. This Authority should also have the capacity to recommend legislative change where genuine conflict exists.

Conclusion

One final issue needs to be addressed. It would be a substantial mistake to rely on Telstra’s own service records and history to gain an accurate picture of the reliability of the copper wire telephone service in the Valley. Either by accident or artifice, Telstra’s reporting practices and policy combine to under-report the number and extent of service outages and present an entirely misleading picture of system reliability.

At a fundamental level, how can a user report the failure of the telephone when the telephone is the only means of communication? With the current copper wire system the only way to report a telephone outage has been to travel back along the telephone line in an effort to find someone with a working phone. In the best of circumstances, this can mean a trip of many kilometres, much time and some risk. In other, less favourable circumstances, it may be impossible to report the fault. For example, the residents of the Wyanbene area in the Valley must all pass over a low-level weir to reach their properties

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which are accessed by a dead-end road into the Wyanbene Caves. If the river rises the weir quickly becomes impassable and there is no other access to the main road. The telephone wire into the Wyanbene area is strung between trees across the river and is frequently the first casualty of a storm or heavy rain. Once the telephone wire is cut or carried away the residents of Wyanbene have no way in which they can report telephone failure.

Further, the copper wire system is such that the higher up the line the fault occurs, the greater the number of users affected. Or as one of our residents succinctly observes “one out, all out”.

The net result has been that every single fault that is reported hides a great many affected users.

Further, Telstra will not accept fault reports from users contracted to other service providers or fault reports from other than the registered user. The effect of this policy on the residents of Wyanbene (described above) is that they frequently are unable to report telephone failures.

Clearly, this policy places artificial and unnecessary obstacles in the fault reporting pathway and inevitably results in an under-reporting of service failures.

Finally, when we have reported telephone faults in the past, we have been consistently advised that a substantial charge will be made if the technician finds that the fault lies in other than Telstra’s own system. On several occasions the line self-healed in the time between the fault being reported and the arrival of the technician. We speculate that this situation is caused by a “wet spot” in the copper wire that causes shorts when it rains but which recovers when it dries out. This rain-fault-recover cycle has now had many, many iterations.

In these circumstances we have no fault to demonstrate to the technician when he eventually arrives and we are both embarrassed and at financial risk. Consequently we have observed and learned the pattern of telephone outages following rain and we no longer report faults where we believe the outages will self-heal within a short time. We accept that this effectively under-reports the level of service failures but it is a pragmatic response to a chronically unreliable copper wire system.

Whilst we are commenting on Telstra’s policies and practice, we should mention that in our experience Telstra clients appear to be on the bottom rung of the priority ladder in respect of service and fault repair. Since changing from Telstra to another service provider we have noted a substantial improvement in response times to outage and fault reports even though the same Telstra technicians carry out the repairs. We now routinely advise all new Valley residents to review any Telstra contracts and consider moving to another service provider.

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This submission has been prepared by and on behalf of the Upper Shoalhaven Valley Residents Group.

If you have any questions, need expansion on any point or require further information, please contact any of the following contributors:

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