2015 Regional Telecommunications Review
To:
2015 Regional Telecommunications Review Secretariat
Department of Communications
GPO Box 2154
CANBERRA ACT 2601
SUBMISSION
Submission made on behalf of:
Yaraka Isisford Branch
Isolated Children’s Parents’ Association Queensland Inc. (ICPA Qld Inc.)
Contact Details:
Branch President
Mary Killeen
Navarra
ISISFORD Q 4731
This submission contains no material supplied in confidence and may be
placed on the 2015 Regional Telecommunications Review website
2015 Rural Telecommunications Review
Submission
ICPA (Aust) is a voluntary, non-profit, apolitical parent body dedicated to ensuring that
all rural and remote students have equity of access to a continuing and appropriate
education. ICPA members work together for equity of access to education for all students
who live in rural and remote Australia
Given that our organisation (ICPA) is a voluntary, non-profit, apolitical parent body
dedicated to ensuring that all rural and remote students have equity of access to a continuing
and appropriate education, the focus of this submission will be telecommunications and the
impact of telecommunications on the provision of a continuing and appropriate education for
those students who are geographically isolated. Additionally there will be some focus on the
impact of telecommunications on the abilities of the families of these children to conduct
their business while residing in rural and remote Australia.
The Committee is seeking views on how the Australian Government and other levels of
government, industry and the community can support access to telecommunications services
that meet the needs of people living in regional, rural and remote parts of Australia.
Key questions to consider:
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?
The geographic isolation of those who reside in rural and regional Australia makes this cohort
of the population far more reliant on telecommunications than those who reside in urban
areas. Vast distances and sparsely populated areas dictate that a reliable telecommunication
system is essential for a number of reasons including;
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safety of life
education
business
social engagement
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
Distance Education lessons are increasingly delivered via the internet. When the internet does
not work at all or the upload and download speeds are SO SLOW that pages either will not
load at all or repeatedly drop out, it is almost impossible for children to maintain an interest
in learning. Disengagement from learning, fuelled by frustration caused by the poor
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The vast distances preclude residents from making alternative arrangements should existing
telecommunication infrastructure fail and this is especially so during periods of wet weather
when dirt roads become impassable. Those who live in more populated areas are more often
than not able to seek an alternative form of telecommunication should their preferred option
cease to work. They usually have the choice of using either a mobile or fixed line telephone
service which is a luxury not available to most rural and remote residents. In the event of a
medical emergency there is usually always somewhere to be able to dial 000 – no so in the
outback when the nearest neighbour can be up to 50 km or more away!
2015 Rural Telecommunications Review
Submission
performance of the internet is a real possibility and one which needs to be avoided if this
cohort of Australia’s future generations are to learn at a rate and standard comparable to their
unban counterparts.
More and more daily business is being conducted via the internet and the telephone. If either
or both of these telecommunication platforms are down, then rural and remote residents have
no alternative means by which to conduct their daily affairs. They cannot use the local
library, internet café or mobile “hot spot” as there simply is not one, without having to travel
considerable distances. Face to face interaction is also not available due to geographic
isolation.
While some would suggest that social interaction is a non-essential item and/or a luxury,
those who live in geographically isolated areas would argue strongly that it is crucial
especially in terms of ameliorating the loneliness which comes hand in hand with residing in
many rural and remote locations.
Q2. For those users already connected to an nbn network service, has the service met your
expectations?
Members of our branch utilise both Next G (only available to some members who reside in
the area of a Next G footprint) and also the nbn interim satellite service (nbn iss). It would
appear that neither of these services are meeting the expectations of branch members,
especially those educating their children via Distance Education.
The service has failed in a number of areas including:
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data plans which promise a certain speed and NEVER deliver at the promised speed
data plans which have had their capacity reduced to try to alleviate congestion
problems
data transfer speeds slowing to such an extent that the internet becomes unusable and
thus precludes the downloading of distance education materials, conducting business
such as internet banking, participating in any form of webinars or similar forums.
Page
One of our branch members who utilises the nbn iss for the provision of internet has two
students studying via distance education. Invariably the data allowance is exceeded prior to
the anniversary date of the plan. This member takes her mobile phone and drives some
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Of particular significance to our branch members is the size and cost of internet plans and the
fact that many plans have recently been compulsorily reduced to a maximum of 20
GB/Month (peak time - 8a.m. - midnight.). Families with Distance Education students,
especially those families with multi-level home class rooms, often exceed their data capacity
allowance prior to the anniversary date of the data plan. This results in plans being shaped
and speeds becoming even slower and more hopeless and frustrating, or suspended
altogether.
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
2015 Rural Telecommunications Review
Submission
distance to access the nearest mobile telephone network and then uses her “mobile hot spot”
to download distance education curriculum materials.
Is this any way to deliver education in the 21st Century – really????
Very recently it has come to our attention that service providers are now SUSPENDING
plans which exceed the specified date capacity rather than shaping such plans. The very idea
of leaving those students who rely on distance education without ANY internet access from
the date of suspension to the anniversary date of the data plan is unthinkable. While it is
possible to undertake distance education without use of the internet (at least on a temporary
basis) the standard of lessons is severely compromised and the student/s are disadvantaged
due to lack of interaction and availability of some curriculum materials
It must be noted that Satellite service consumers only have ONE internet connection via
which to conduct ALL their internet based activities. Most urban-based businesses have one
or more internet connections dedicated solely to business activities. The most residents in
urban areas have access to a variety of internet connections and plans etc.
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?
The majority of members of Yaraka/Isisford ICPA reside in the towns and communities of
Yaraka and Isisford. Some members already have access to the Next G network which
enables them to use mobile phones etc. However Next G data plans are very expensive and
due to congestion issues members using them are experiencing frustrating drop outs etc.
Yaraka has been selected to receive a mobile telephone base station on Mt Slowcombe under
the Federal Government’s Mobile Black Spot Programme. Obviously access to a mobile
telephone network will enable those who reside within its footprint to utilise mobile
communication devices to their advantage. As an ICPA Branch and also as a community we
are delighted that Mt Slowcombe has been chosen and the installation and commissioning of
this equipment cannot happen soon enough! 
However there are members of our branch who will reside outside of this mobile footprint.
For these members, it is essential that they be provided with a fixed line telephone service
which is NOT satellite based. Currently those members who do not receive a fixed telephone
service via the Next G network are serviced by High Capacity Radio Concentrator (HCRC).
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
It has been suggested that USO telephone subscribers who will utilise the NBN LTSS (for
internet access) will have their USO Voice services moved on to the NBN LTSS.
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“NBN Satellite
2015 Rural Telecommunications Review
Submission
NBN LTSS is a high latency (Delay) internet system that introduces at least 500 milliseconds
delay into any voice call. An NBN LTSS based phone call to another NBN LTSS based phone
would experience a one second delay in transmission as this call would “double hop”
through the satellite. e.g. Phone A to satellite to exchange to satellite to phone B, each time
the call transits the satellite the delay is 500 milliseconds so going through the satellite twice
gives a 1000 millisecond (1 Second) delay. So if “A” says “How are you”, “B” will hear it 1
second later. “B” replies “OK”, “A” will hear that reply 2 seconds after they posed their
original question.
A School of Distance Education student or any other users who need to use a Teleconference
Bridge will experience that one second delay. e.g. Student A to satellite to exchange to
teleconference bridge to exchange to satellite to Student B.
Any sort of group activity such as music would not be possible because of the 1 second delay.
Telstra’s existing USO Satellite Network which is used in very remote areas has a built in
Telecommunication platform that ensures that the maximum latency (Delay) between satellite
users is limited to one hop. It still experiences the same problem when a teleconference
bridge is involved if there are two students using the USO Satellite Network. However this is
extremely rare.
The previous Federal Government advised that as the NBN LTSS (permanent satellites) is
designed for the internet only, they would not be suitable for the USO Fixed Telephone
Network.
The following concerns need to be addressed and acceptable solutions provided before the
NBN LTSS network can be considered for the provision of a USO Voice service.
1. Is a fault on the NBN LTSS equipment that disrupts the voice service treated as a
voice CSG fault with a target of 3 working days to repair or as an Internet fault with
a best efforts clearance time e.g. 1 - 2 weeks or more? In this case as both voice and
internet are delivered into the home via a single modem any fault on this modem will
cause both voice and internet to be disrupted. Unless the user is “lucky” enough to
reside within a mobile telephone service footprint they will be left isolated and this
may then become a safety of life issue.
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3. If the NBN LTSS is used for USO voice, will its reliability be upgraded so that it will
not stop transmitting when there are adverse weather conditions, i.e. rain, snow or
there is a dust storm? (This is a very common problem with satellite based services in
remote areas)
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2. Will voice services on the NBN LTSS have priority when there is congestion as so to
maintain a Safety of Life service?
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
2015 Rural Telecommunications Review
Submission
4. What is being done to ensure fax machines, dialup data and existing telemetry
services will operate on the NBN LTSS?
5. What is being done to ensure that voice calls between satellite voice services on the
same satellite and between two NBN satellites are single hop?
6. Is a solution planned to ensure that when a teleconference bridge is used, users
(Students) will only experience single hop delay, unlike the two hop delay between
users who would be on satellite?
7. The proposed NBN LTSS end user equipment is mains powered. Will NBN provide a
battery backup solution that reflects the power characteristics for these sites when
such sites are used for USO voice?
8. What is the maximum number of USO voice services that can be on the same NBN
satellite while maintaining its internet data performance?
9. Will the priority medical assistance process apply to services on voice over NBN
LTSS?” (1)
(1)
ICPA Queensland Council Inc. Telecommunications Position Paper June 2015
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?
No
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 further the mobile telephone network is expanded, the more current satellite based
customers should be able to migrate to this network. This migration should help to mitigate
current congestion issues experienced by satellite internet users. Obviously any increased
expansion of the mobile network should utilise technology capable of meeting the everincreasing demands of the digital age consumer.
Q6. What opportunities do the mobile network industry see for extending coverage in
regional Australia and increasing investment in mobile networks?
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
Q7. Do you have any views on co-investment approaches that might help to improve the
broadband technology outcome in your area?
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N/A
2015 Rural Telecommunications Review
Submission
N/A
Q8. How might new applications and services that utilise mobile networks for voice and data
transform the way you live and work?
New applications and services that utilise mobile networks for voice and data will transform
the way our branch members (those of which currently reside outside of a mobile network
footprint) live and work by providing them with access to the digital information super
highway in a way they have never experienced before (except when away from home and
able to access an alternative, fast internet connection.)
First and foremost they will be able to communicate via mobile telephone all the time instead
of when they happen to be away from home and able to access a mobile signal. The
availability of mobile signal is something which many of our city peers take so much for
granted. Something as simple as being able to send a quick photo via Snapchat to a home sick
child at boarding school will have the ability to alleviate much stress and discomfort both for
the child and the parents.
Our branch members will be able to utilise all the apps and various other functions available
via an iPad or other such tablet device. The ability to download distance education
curriculum materials will be greatly enhanced. Work Place Health and Safety will obviously
improve with mobile telephone access to 000. There are a number of agricultural applications
(such as telemetry for stock watering facilities) which rely on mobile telephone signal.
The possibilities are really limitless as new technologies are being developed on an almost
daily basis. It is impossible to either qualify or quantify to what extent new applications and
services that utilise mobile networks for voice and data will have the potential to transform
the way our branch members live and work. Provision of access to a mobile network will go
some way towards allowing geographically isolated residents to participate more fully in the
21st Century’s digital world.
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?
slow internet speeds causing drop outs (also applies to those on Next G) due to
congestion issues
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
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Members of our ICPA branch (who do not reside in a mobile service area) have experienced
the following barriers in expanding or operating their businesses and accessing services such
as health or education?
2015 Rural Telecommunications Review
Submission
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restricted internet plans
internet plans which do not deliver promised upload and download speeds
inability to successfully download distance education curriculum materials
inability to access webinars etc.
inability to utilise apps and other functions available on iPads and other table type
devices
inability to utilise video conferencing services for health and/or education issues
inability to complete some Government forms (e.g. Centrelink) which are only
available on line as the internet connection is too slow
inability to use some integrated forms of accounting software programmes which
cannot function without appropriate internet speeds.
To date, none of our branch members have been able to change or modify the Speed of Light
and thus to some degree rectify the latency issues which cause slow data transfer. Coupled
with issues caused by congestion, successful use of the internet becomes, at times,
impossible.
Perhaps this quote from one of our branch members provides an appropriate summation of
the situation. This particular member is on a Next G network and when I called for in-put into
this submission from branch members she responded:
“Rather ironical I know, but my internet is far tooooo slowwww to access the links to
actually read what it's all about!”
Efforts have been made to work as successfully as possible within the very limited
parameters available to us and these include:
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Down loading information between midnight and day light when congestion seems to
be less. However since the introduction of internet-streamed movie programs such as
Netflix, this has become a lot less effective
exporting information and sending same via snail mail on a USB drive – VERY
SLW
turning off automatic updates to programmes such as the MS Windows operating
platform and downloading such updates when located in a regional centre such
Longreach for example. This of course means taking a laptop computer on the journey
which is not too difficult. For those using desk top machines, this is a cumbersome
and annoying imposition and necessities utilising a network once in town as most
desk top machines are not Wi-Fi compatible.
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
Members of our branch need access to reliable (preferably mobile) telephone and data
services which are affordable and commensurate with the needs of 21st century families. Why
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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)?
2015 Rural Telecommunications Review
Submission
should our branch members have their internet usage curtailed by compulsorily restricted data
plans etc. which have needed to be initiated to compensate for poor planning in regard to
estimated data usage by rural and remote consumers?
“Any download plan limitations need to cater for the following;
Education: It is imperative that education related internet use is considered as an
addition to the cap for any “fair use” policy, with an additional allowance per
student. Tertiary students studying externally will need a larger additional
allocation.” (2)
(2)
ICPA Queensland Council Inc. Telecommunications Position Paper June 2015
It so happens that as I write this submission, I am in Adelaide. What a smorgasbord of media
is available. The choice of data plans, movies to download, apps to utilise and so on is
enormous. When compared to the absolute lack of choice and substandard service which I am
able to access from my home, it is of little wonder to me that rural and remote families
perpetually struggle with technology issues. We are indeed a marginalised cohort of
Australia’s population, despite the enormous contribution made to the nation’s GDP by the
agricultural sector as a whole.
Given that the likelihood of the majority of our branch members ever being able to access
fibre is nil, such services will ideally be provided by a combination of wireless and mobile
technology.
For those members who may still have to rely on satellite for the provision of internet it is
essential that the current congestion issues experienced by users of the nbn iss do not also
plague subscribers who will be serviced by the nbn ltss.
Questions should be also asked regarding the reliability of the nbn ltss:
“The NBN ISS (Interim Satellite Service) operates in the Ku Band (12 – 18Ghz) and
experience and published data show that it is very susceptible to weather related issues.
The NBN Long Term Satellite Service is operated in the Ka Band (26.5 – 40Ghz) and unless
it is very well designed, the service will be even more susceptible to weather related issues.
(Water is a brick wall at these frequencies that is why weather effects the performance of
satellites)
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(3) Yaraka/Isisford Branch ICPA Explanation to Motion carried at ICPA (Aust) Inc. Federal
Conference held in Launceston 2014
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NBN has never published the expected operating Availability data for the Tropical and Sub
Tropical areas of Australia.” (3)
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
2015 Rural Telecommunications Review
Submission
As stated in Question 3, it is essential that this cohort of our branch members DO NOT have
their fixed telephone service provided via satellite.
Q11. Do we need to continue to guarantee the standard telephone service for all (or only
some) consumers, and if so, to what extent?
Given the increasing level of unreliability of aging communication systems such as HCRC
and the high level of dependency of residents in rural, regional and remote areas of Australia
on efficient telecommunications networks, it is essential that the Universal Service
Obligation (USO) continue to guarantee standard telephone services.
This is also very important:
“Another area of concern is the increasing use of Mass Service Disruption (MSD) notices by
Telstra. The use of MSD’s removes the requirement for Telstra to meet the service restoration
targets set by the Customer Service Guarantee (CSG) scheme and removes the rights of
customers to claim CSG payments.
The original intention was for MSD’s to cover major weather / disaster events. However, the
telephone network has been allowed to fall into a state of disrepair. MSD’s have been
increasingly used for what would have previously been considered a normal event that
required Telstra to meet the service restoration targets set by the CSG (Customer Service
Guarantee) scheme.” (4)
(4)
ICPA Queensland Council Inc. Telecommunications Position Paper June 2015
Q12. Are there new or other services, the availability of which should be underpinned by
consumer safeguards?
Given that a number of our branch members rely on the internet to effectively facilitate the
delivery of the Distance Education curriculum this internet service should operate under some
kind of guarantee similar to the fixed line telephone Universal Service Obligation type
guarantee. Not only do our members utilise the internet for the provision of education, it is
also an integral part of day-to-day business function (albeit impeded by slow data transfer
speeds, drops out and the like) so if the internet is “down” then there is no access to internet
banking, emails and so on. Geographic isolation means that there is no alternative means of
communication available. So, without question, YES, the delivery of internet should be
underpinned by consumer safeguards such as a USO type arrangement.
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association
Page
Owing to geographic isolation, safely of life issues, the provision of education via telephone
and the internet, the necessity for business use of the internet, impassable roads during wet
weather events etc. geographically isolated subscribers (i.e. over 95% of our branch
members) should be given the highest possible priority for repairs to disruptions of service,
especially telephone services.
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Q13. What standards should apply to your services? How might they best be enforced?
2015 Rural Telecommunications Review
Submission
Telstra should be compelled to honour the USO and should face heavy penalties for not doing
so. As mentioned previously, Telstra should not be allowed to “hide behind” Mass Service
Disruption notices in an attempt to conceal “Shortages of trained staff, lack of availability of
parts and failure to carry out essential maintenance have reduced the reliability of outback
services, with repair times blowing out at times to three to four weeks.
It would appear that Proactive Maintenance programs which would have resolved some of
these issues before they affected end users have been shelved and replaced by a “complaints
only” response.
Worryingly there also appears to be no planning in place to resolve the on-going problems
with the existing terrestrial based equipment.” (5)
(5)
ICPA Queensland Council Inc. Telecommunications Position Paper June 2015
In concluding I would like to quote from an address by Mr E.C. (Bunny) Powne M.B.E. Life
Member ICPA Queensland Council Inc., Life Member ICPA Federal Council Inc. and Life
Member ICPA Bollon Branch.
In his address to ICPA Queensland Inc.’s 40th State Conference in 2011 Mr Powne said, “In
1978 ICPA was asked at a National Conference in Canberra what were ICPA’s priorities
…….. and the answer given was: “ICPA has three priorities - First: A Telephone. Second: A
telephone that works, and Third: A telephone that works all the time.”
It seems that now, some thirty-seven years later, the priorities of Yaraka/Isisford Branch of
ICPA on whose behalf I have written this submission have expanded to not only continue to
include the above reference to a fixed line telephone service but can also be expanded to
include:
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First – internet
Second – internet that works and is affordable
Third – internet that works all the time
Submission compiled by
Mary Killeen
Branch President
Yaraka / Isisford Branch
Isolated Children’s Parents’ Association