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 eastwest 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 4WD 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 onsite 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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