The Queensland Government submission to the Senate Inquiry into the Australian Telecommunications Network “As a country we should aim to be more than adequate!” August 2002 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 1 The Senate referred the inquiry into the Australian Telecommunications Network to Committee and sought its report by 21 February 2003. The terms of reference 1 are: (a) the capacity of the Australian telecommunications network, including the public switched telephone network, to deliver adequate services to all Australians, particularly in rural and regional areas; (b) the capacity of the Australian telecommunications network, including the public switched telephone network, to provide all Australians with reasonable, comparable and equitable access to broadband services; (c) current investment patterns and future investment requirements to achieve adequacy of services in the Australian telecommunications network; (d) regulatory or other measures which might be required to bring the Australian telecommunications network up to an adequate level to ensure that all Australians may obtain access to adequate telecommunications services; and (e) any other matters, including international comparisons, which are deemed relevant to these issues by the Committee. 1 http://www.aph.gov.au/Senate/committee/ecita_ctte/tele_network/Index.htm Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 2 Executive Summary Australia is at a crossroads. We can choose to keep up with our first world peers or choose to be adequate. The time to make that decision is now. To date the focus on telecommunications adequacy has been an attempt to show that "she'll be right mate" and as a result it is being argued we as a country can afford to lose control of a public asset that is central to Australia's future success. As a country we have not agreed what future we want or need. For convenience, this future is being defined in terms of today's technologies and of low-level notions of adequacy. Australia's international competitors are not doing the same. This submission provides recommendations, which are hoped will provide the Commonwealth Government with guidance on this important issue. They are listed below as they form a summary of this report. 1. A plan is needed which maintains and enhances Australia’s position regarding telecommunications use among its first world peers. This plan needs to take a holistic view of telecommunications making best advantage of all tiers of government as well as the infrastructure and content industries. 2. Any consideration of the sale of Telstra must be deferred until the Commonwealth Government can establish a telecommunications competition regime, which supports the long-term interests of Australian’s and the effective operation of the share market. 3. Statistical reports for the Customer Service Guarantee need to reflect real service levels in relation to business and social needs, as straight statistical analyses can be misleading. 4. Mobile services cannot be considered adequate while all bounded localities and major highways and strategic roads do not have full mobile coverage. Also, mechanisms are needed to provide cost effective roaming between carriers' networks. 5. A choice be made to adopt converged digital solutions in the future to maximize utility, minimize overall costs and make Australia a more competitive country, 6. Australia's definition of adequacy for data services include an ability to carry a wide range of content, including television. This definition needs to focus on functionality rather than pure bandwidth and needs to be reviewed on a regular basis. 7. Unnecessary legal constraints on the transmission of content be removed. 8. Further support be provided to the development of Australian digital content, including applications, to improve efficiency and effectiveness of Australians. 9. Use of converged solutions be fostered to provide a sound basis for the uptake of broadband services. 10. Regular public reporting is needed for the “000” emergency service to provide the public with a level of confidence that calls to 000 will be effectively carried to State provided health and emergency services. 11. Substantial funds need to be allocated to ensure our education, research and health sectors continue to be leading users and developers of high bandwidth applications. 12. Australia needs to find a solution, which results in appropriate investment in infrastructure, while facilitating competition of value added services. This solution needs to combine the efforts and assets of all levels of government. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 3 13. The full Customer Access Network be declared not just the copper wire. 14. Any future subsidization of telecommunications projects needs to support equity as well as converged infrastructure solutions. 15. The Commonwealth Government allocates regular budget funding to manage its telecommunications responsibility. Items would include funding for mobiles and broadband services. 16. The Commonwealth Government institute a range of measures aimed at improving the competitiveness of the telecommunications industry in Australia. 17. The Commonwealth Government enhance the Customer Service Guarantee and the process for managing the Universal Service Provision to provide converged services and all existing telecommunications services in the future. 18. Australia needs telecommunications which are more than adequate to remain internationally competitive. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 4 Table of Contents 1. Introduction ................................................................................................................. 7 1.1. The cost of competition ...................................................................................... 8 2. Network Capacity to deliver adequate services to all Australian’s .......................... 10 2.1. Adequacy of Standard Telephone Services ...................................................... 10 2.2. Adequacy of Mobile services............................................................................ 11 2.3. Adequacy of Data Services ............................................................................... 12 2.4. Adequacy of Television and Radio Services .................................................... 14 2.5. Adequacy of 000 Infrastructure Services .......................................................... 15 3. Network Capacity to provide all Australians with reasonable, comparable and equitable access to broadband services. ............................................................................ 16 3.1. Backbone Network............................................................................................ 17 3.2. Customer Access Network (the famous last mile) ............................................ 18 4. Current and Future investment requirements to achieve adequate services. ............ 20 5. Measures needed to achieve adequacy ..................................................................... 21 5.1. Competitive measures ....................................................................................... 21 5.2. Changes to the Universal Service Obligation and Customer Service. .............. 22 6. Other Matters ............................................................................................................ 23 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 5 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 6 1. Introduction Adequate2 – Equal to the requirement or occasion; fully sufficient, suitable or fit. The Besley Inquiry concluded3, "Australians generally have adequate access to a range of high quality, basic and advanced telecommunications services comparable to the leading information economies of the world". The question we must ask is, adequate for what purpose and for how long? Other nations look at telecommunications as an enabling infrastructure for future economic and social development. Unfortunately at a national level, the major focus has been how can we maximize the profits from the sale of our telecommunications asset once adequacy of services can be asserted. Another major question is how will adequacy be maintained and how will our definition be evolved over time? The simple reality is that service levels are improving, but not universally, and Australia is slipping further behind its first world peers4. To date Commonwealth’s programs to improve services have been tightly targeted, often requiring significant community participation and pain to achieve much needed service improvements. Networking the Nation and the Television Black Spots are examples of such programs. Changes to Australia's telecommunications infrastructure will take a while to take hold. The press releases produced by the Commonwealth detailing multimillion-dollar expenditures are only the start of a very long implementation for many projects. Adequacy can only be measured once sustained improvements have been achieved. Either individually or collectively Australians’ cannot afford to fund the separate services (eg phone, Internet and Television) offered by the telecommunications industry. Collectively these services just do not provide sufficient value to justify expenditure of scarce discretionary funds. Australia needs to set a unifying vision that brings telecommunications into perspective and guides both industry and the consumer alike. A plan is needed which maintains and enhances Australia’s position regarding telecommunications use among its first world peers. This plan needs to take a holistic view of telecommunications making best advantage of all tiers of government as well as the infrastructure and content industries. Delbridge A, Bernard JRL, Blair D, Peters P, Butler S; “The Macquarie Dictionary – Second Edition”; The Macquarie Library pty ltd; 1992; p 19. 3 Telecommunications Service Inquiry; “Connecting Australia”, Commonwealth Department of Communications, Information Technology and the Arts 200o, p10. 4 http://www.oecd.org/pdf/M00020000/M00020255.pdf 2 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 7 1.1. The cost of competition After ten years of competition, 99 percent of revenue5 is concentrated in only eight firms. Telstra earned 76% of this revenue. Optus Mobile Pty Ltd and Optus Networks Pty Ltd combined represent the next largest company with just over 14% of the total revenues. The remaining five firms earned just over nine percent of revenues. Of these eight firms, One-Tel has gone bankrupt; and Optus (Mobile Pty Ltd and Networks Pty Ltd) and AAPT have been the subject of takeovers by Singapore Telecommunications and Telecom New Zealand respectively. Never the less the Commonwealth Government continues to advocate competition as the way forward. Competition is having a savage impact on the share market. Of the 67 telecommunications firms currently listed on the Australian Stock Exchange6 most have substantially lost share value. 95 % of equipment and service providers, 75% of Network Operators and 92% of the "other telecommunications" sector have made losses in share price averaging over sixty percent since listing, or over the past ten years, which ever is shorter. The table below numerically summarises this result. Further details relating to the performance of specific firms are listed in Attachment 1 Industry Sector Number of firms Equipment and Services Network Operator Other Telecommunications 46 8 13 Number of firms who have lost substantial share value since listing or over the past ten years which ever is shorter. 44 6 12 The "tech bubble" provides an explanation for this phenomenon. A preferred explanation is the Australian telecommunications market is fiercely monopolistic with few real national competitors. It is considered further concentration of industry revenues, overall declining share growth and low or no dividends will continue to emasculate the industry and reinforce Telstra as the dominant player. Telstra as the Universal Service Provider funds $215 million of the total estimated Universal Service Obligation cost of $280 million7. This contribution is more than the revenue earned by all but the five top carriers. The simple scale of this contribution limits the extent to which other carriers can provide an alternative Customer Access Network. The table below summarises the details of major contributors. 5 Based on Australian Communications Authority Eligible Revenue Assessment 2000-2001. Based on 2000-01 financial data available on the Australian Stock Exchange web site. 7 Based on Australian Communications Authority Eligible Revenue Assessment 2000-2001. 6 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 8 %cumulative total % totall (2) The eligible revenue for the financial year is $15,668,077,205.00 $215,200,911.79 $1,493,650,378.00 $20,515,275.68 $1,435,164,437.00 $19,711,971.76 $873,687,500.00 $12,000,090.64 $349,080,452.00 $4,794,617.14 $159,585,252.00 $2,191,902.13 $146,259,122.00 $2,008,867.84 (3) The levy debit under section 67 of the Act Carrier TELSTRA CORPORATION LIMITED OPTUS MOBILE PTY LIMITED OPTUS NETWORKS PTY LIMITED VODAFONE PACIFIC LIMITED AAPT LIMITED ONE.TEL GSM 1800 PTY LIMITED PRIMUS TELECOMMUNICATIONS PTY LIMITED HUTCHISON TELECOMMUNICATIONS (AUSTRALIA) 76.60% 7.30% 7.02% 4.27% 1.71% 0.78% 0.72% 76.60% 83.91% 90.92% 95.20% 96.90% 97.68% 98.40% $1,689,766.24 0.60% 99.00% $20,453,345,825.00 $280,926,537.00 99.00% 99.00% $123,026,374.00 Information released by the Australian Telecommunications User Group (ATUG) indicates Telstra earns over 95% of the industry profit 8. This is a sad indictment on competition and the telecommunications industry generally. In positions of similar market power, the United States Government has used Anti-Trust legislation to break the company into appropriate parts to reinvigorate competition. The Commonwealth should be considering a similar course of action with Telstra. Should Telstra be fully privatised, it will represent over 9% of Australia’s equity market and will be the largest firm in Australia in terms of equity capital. It is clear that Telstra now intends to capitalize on its market power and maximise its revenue stream. It is suggested the twelve-month contracts for Internet access, selective bundling and price increases are all intended to lock-in customer revenues and limit opportunities for competitors. It is recommended that any consideration of the sale of Telstra be deferred until the Commonwealth Government can establish a telecommunications competition regime, which supports the long-term interests of Australians and the effective operation of the share market. 8 http://www.atug.com.au/article.cfm?newsid=129&newstype=1 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 9 2. Network Capacity to deliver adequate services to all Australian’s Telecommunications Service Inquiry research9, indicates Australians who live in metropolitan and regional centres enjoy good telecommunication services and are generally satisfied with them. However, a significant proportion of those who live and work in rural and remote Australia have concerns regarding key aspects of services, which, at this stage, are not adequate. Their concerns relate primarily to: the timely installation, repair and reliability of basic telephone services; mobile phone coverage at affordable prices; and reliable access to the Internet and data speeds generally. 2.1. Adequacy of Standard Telephone Services The statistics in the March 2002 Telecommunications Performance Monitoring Bulletin10 when taken on face value look promising. An extract of the Queensland Statistics is contained in Attachment 2. Many of these statistics show satisfactory performance against the Customer Service Guarantee of at least 95 percent or higher. The statistics also show higher performances in rural and remote areas. In other words, Telstra demonstrates it can meet relatively undemanding standards. Unfortunately the Customer Service Guarantee defines a differential service, which does not adequately reflect the real service levels required by consumers. Satisfaction is based on low standards which favour carriers rather than consumers. More remote Australians have a to be satisfied with worse service. The table below shows guaranteed connection times that are between three and six times worse; and repair times three times worse for Australians living in remote locations. Location Urban11 Major rural13 Minor rural14 15 Remote Connection time Available cabling (capacity) or other infrastructure that carrier can use Within five working days of customer request *Within 10 working days of customer request *Within 15 working days of customer request Within 15 working days of customer request Time of repair No available cabling (capacity) or other infrastructure that carrier can use Within one month of customer request Within one month of customer request Within six months of customer request Within six months of customer request for new applications Within one full working day12 after being notified of a fault Within two full working days after being notified of a fault Within two full working days after being notified of a fault Within three full working days after being notified of a fault * reduced from 30 working days in June 2001 The Untimed Local Calls in Extended Zones tender and the recommendations in the Telecommunications Service Inquiry when fully implemented have the capacity to substantially improve the adequacy to telephony services in Australia. Telecommunications Service Inquiry; “Connecting Australia”, Commonwealth Department of Communications, Information Technology and the Arts 200o, p10. 10 http://www.aca.gov.au/publications/performance/2002/csg032002.rtf 11 Areas in Australia with a population greater than 10,000 people 12 Note: working days are Monday to Friday and do not include public holidays 13 Areas in Australia with a population between 2,500 and 10,000 people 14 Areas in Australia with a population between 200 and 2,500 people 15 Areas in Australia with a population less than 200 people 9 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 10 As it will take some time for these changes be effective and statistically valid, it is difficult to argue services have substantially improved to the point they could be certified as adequate. Statistical reports for the Customer Service Guarantee need to reflect real service levels in relation to business and social needs, as straight statistical analyses can be misleading. 2.2. Adequacy of Mobile services There have been improvements in mobile phone coverage in Australia. Information provided to the Australian Communications Authority16 indicates, a large proportion of the population, is now serviced by one or more mobile phone carriers. This information is summarised in the table below. Carrier Telstra GSM Telstra CDMA Optus GSM Vodafone GSM Hutchison CDMA Period ending March 2002 Population covered by network per cent 95.40 97.46 94.30 92.00 96.00 While appreciating the close association between population and profitability, the real measure of adequacy in an Australian context needs to be geographic coverage. In a recent press release, Queensland Minister of Innovation and Information Economy Paul Lucas summarised the difficulties with mobile phone coverage in Queensland. He indicated: "I'm not complaining about the coverage of our towns and cities, I’m talking about mobile phone coverage of our major western highways,”. “Talk to the 60,000 tourists who travel to Birdsville and through the Diamantina Shire each year about the gaps in mobile coverage on the highways. “Ask the businesses who have to use our western highways to travel to Mt Isa, Charleville and Longreach. Additional geographic coverage has been recently announced through the federally funded “Regional Mobile Phone Program”. Announcements indicate that ten small Queensland coastal communities and three western towns will shortly benefit from mobile coverage as will Queensland roads. Coverage on Queensland highways will be extended by a total of 817 km spread across 11 highways. While this expansion of coverage is most welcome it represents an average of just 74 km per highway. Attachment 3 indicates the vast expanses of Queensland highways which will continue to lack mobile coverage in spite of these initiatives. 16 http://www.aca.gov.au/publications/performance/2002/mobileinternet032002.rtf Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 11 Even when these improvements are fully implemented, the adequacy of services will still fall well below that required for total coverage on highways and will need to be assessed against the real requirements of citizens living in regional and rural Australia. Central to this adequacy will be an ability to roam across the multiple mobile telephone infrastructures in a way that is transparent to customers. From a Queensland Government perspective, mobile services will not be considered adequate while all bounded localities and major highways and strategic roads do not have full mobile coverage. Mechanisms to provide cost effective roaming between carriers' networks also need to be instituted. 2.3. Adequacy of Data Services The adequacy of data services should be measured by their ability to provide a substitute carriage for a wide range of content including television. Data services have the capacity to simplify the infrastructure at customers' premises and subsequently the costs for content providers. It is this benefit and the range of services that can be converged into a bit stream that will determine the competitiveness of Australia in a global context. To date Australia has not focussed on converged solutions on a common infrastructure. It has forced consumers to pay for separate services on separate infrastructures. The end result of this divergent approach is most likely to be evidenced in remote Australia, where services are provided through three separate satellite dishes on a roof, one for phone services, one for television services and one for the Internet. This approach is strongly entrenched and maintained by separate Commonwealth Government subsidies and it also provides the Commonwealth with a range of revenue raising opportunities. An example of this complexity is listed in the table below. Commonwealth Subsidy programs Telephone Mobile phones Television Radio Internet (data services) Print Media USO subsidy; Untimed Local Calls in Extended Zones; USO contestability pilots Networking the Nation; Mobiles on Highways; Mobile phone coverage for towns with a population of 500 or more; regional mobile program. Television Blackspots Fund for customers and the Remote Area Broadcasting Subsidy for providers. Digital Data Services Obligations; Networking the Nation; Internet Assistance Program; BARN; Advanced Networks Program; National Communications Fund. Commonwealth Source Carrier licenses Revenue Spectrum sales. Eg 3G Spectrum sales and licenses. Spectrum sales and licenses. Licenses License fees. Australia as a whole needs to choose converged solutions as a way forward. Countries such as Canada, USA and Korea have been planning for such approaches for a number of years. In stark comparison, while these countries were establishing the basis for Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 12 ubiquitous broadband communications, Australia and the Howard Government were focussed on narrow band communications as part of Digital Data Inquiry. The final political decision resulting from this Inquiry was a step forward (a single channel ISDN terrestrial solution or one way satellite service where no terrestrial service was available). Unfortunately consumers saw no real benefit and the much-debated cost blowouts in the Digital Data Inquiry never eventuated. The Telecommunications Performance Report17 indicates the ACA has no information suggesting that the residential take-up of ISDN has changed substantially since the Digital Data Inquiry 1998 – i.e. a total of 200 residential customers and only 8000 consumers outside metropolitan areas. In terms of the one-way satellite service, Telstra only supplied 366 special digital data services in 2000–01, compared to the 84 services that were part of Telstra ’s digital data cost claim in 1999–00 (see table below). Telstra’s total claim for the satellite service was only $335,552 for 2000–01. State/Territory Number of special digital data services – one way satellite service NSW/ACT Vic/Tas WA SA/NT Qld Total 30 June 2000 29 10 14 5 26 84 30 June 2001 142 81 39 46 58 366 To put the above table into context, based on populations, it is estimated approximately 53,000 Queenslanders would be eligible for this service. The take-up has been less than a fraction of a percent. Australians are active users of technology, where there are real benefits. This is evidenced by the take-up of phone-banking and widespread use of mobile phones. Clearly the currently legislated data service packages being presented to Australians do not provide real utility or value for money. As part of the sweetener18 for the Untimed Local Calls in Extended Zones19 tender, Telstra offered a range of lower cost two-way satellite services, which have the capacity to provide low-end broadband services. While not wishing to downgrade the utility of the offer, it is once again a single-service single-infrastructure solution rather than a convergent solution. Telstra has been progressively presenting Australians living in the extended zones with this offer, indicating substantial saving (eg $1400 for a 18 month contract comprising a 64kbps connection with a free 300Mb download limit) will be made if ordered in the eight-week offer period. Despite the closely managed approach to marketing, it is understood take-up may be as high as twenty percent. The costs are summarised in the table below. 17 http://www.aca.gov.au/publications/reports/performance/2000-01/chap05.pdf The service was not requested as part of the Commonwealth tender for Untimed Calls in Extended Zones. 19 Remote customers not living in towns. 18 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 13 Table 2 – Comparison of costs for 2-way Satellite Internet Service Satellite Characteristics Speed down / up (kbps) Download limit Installation Hardware Monthly access fee Total for 18 Months Low-end 8 Week Telstra offer to extended zone customers 33/33 8 Week Telstra offer to extended zone customers 64/64 Costs after expiry of offer to extended zone customers 64/64 150Mb Free Free $16.95 $305.10 300Mb Free Free $57.20 $1029.60 300Mb $699.00 $699.00 $57.20 $2427.60 Costs to standard zone customers ADSL Service Low-end 256k down 64k up 64/64 256/64 300Mb $699.00 $699.00 $120.00 $3558.00 300Mb $249.00 Free $59.95 $1328.10 The way this offer was implemented has created significant inequity in rural Australia. Australian's living in the small towns, servicing the more remote telecommunications customers in Extended Zones, are disadvantaged. They have the same base infrastructure and telecommunications needs as their neighbors in Extended Zones, but are being asked to pay the full costs. The zoning system, which is an artifact of a bygone era, effectively excludes these Australians from an affordable service that is ubiquitously available. Australians in these towns are being asked to pay an additional $2500 for the 64kbps 300Mb free download service. The data services becoming available are a substantial improvement over the services previously available. Unfortunately they fall short of Australia's need for an affordable, ubiquitous broadband service. It is recommended that: a choice be made to adopt converged digital solutions in the future to maximize utility, minimize overall costs and make Australia a more competitive country; and Australia's definition of adequacy for data services include an ability to carry a wide range of content including television. 2.4. Adequacy of Television and Radio Services The quality of the content on Australia's Free-to-Air radio and television is considered to be of a very high standard and should be the envy of the citizens of other countries. The Television Blackspots program aimed at improving television coverage at the edges of the network is to be commended. Lack of a converge solution, however has created significant pain for communities which need to effectively install rebroadcast facilities. For consumers, the use of broadband is three-fold: improving personal effectiveness, education and entertainment. Research indicates entertainment is driving the uptake of broadband in other jurisdictions. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 14 Unfortunately the very entertainment content, which could be used to drive customer take-up of broadband services, is technology constrained by legislation. An example of this is a limitation, in the Copyright Act 1968 where an exemption to copyright is available for the radio broadcast of services to the print handicapped but not if the same content is audio streamed across the Internet. A further example has been the constraining of the content of Datacasting to the point where the industry could not develop an appropriate business model, which would allow it to effectively participate in a spectrum auction. This protecting of the interests of existing broadcasters and their licensing revenues has effectively excluded many Australians from experiencing the early benefits of the Information Economy. These limitations have also constrained the demand for new digital televisions and set top boxes. Prices still remain high, as purchase volumes are low. For Australia to be successful it needs to focus on improving the quality and availability of the content, which will flow over a range of broadband technologies. It is recommended: Unnecessary legal constraints on the transmission of content be removed; Further support be provided to the development of Australian digital content including applications to improve the efficiency and effectiveness of Australians; and Use of converged solutions be fostered to provide a sound basis for the uptake of broadband services. 2.5. Adequacy of 000 Infrastructure Services Regular public reporting is needed for 000 emergency services to provide the public with a level of confidence that calls to 000 will be effectively carried to State provided health and emergency services. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 15 3. Network Capacity to provide all Australians with reasonable, comparable and equitable access to broadband services. The Queensland Government supports the view that all Australians need reasonable, comparable and equitable access to broadband services. It is agreed that a common service level for broadband is a good start Agencies such as the Organisation for Economic Cooperation and Development (OECD) have defined broadband in terms of the threshold speed of 200 kilobits per second (Kbps) or more.20 The United States Federal Communications Commission has legislated for a minimum digital data service for its citizens at this benchmark.21 The Canadian Broadband Task Force research indicates the common usage of the term "broadband" ranges from a low of 200 Kbps to as high as 30 Mbps in the countries that they studied22. The Task Force agreed it would be more useful to define broadband in terms of what it could do for Canadians and as a result have defined "broadband" as a high-capacity, two-way link between an end user and access network suppliers capable of supporting full-motion, interactive video applications. The Queensland Telecommunications Strategy being developed by Department of Innovation and Information Economy defines data services in a similar way, but has taken a conservative position by designating a speed of 256Kbps as the baseline. The difficulty with such a position however, is that it tends to focus on the citizens, not all of society. Australian businesses and the Research, Education and Health Sectors have significant broadband needs and are major contributors to this country's future. Technically every Australian citizen and business can have access to entry level Broadband services now. Satellite services cover all of Australia and can fill the gaps in terrestrial broadband network coverage. The real question is affordability and whether prices are being kept artificially high to constrain the usage of a relatively scarce resource. Unfortunately the current pricing regime seems to imply that a scarce resource is being protected. It is hoped this is not the case. Health, Education and Research centres have significant telecommunications needs. The Advanced Networks Program and the National Communications Fund are programs aimed at satisfying this need. From a Queensland perspective substantial improvements are still needed before services to this sector can be considered adequate. From an adequacy perspective, the network is best described in terms of the backbone network and the Customer Access Network. 20 http://www.microsoft.com/australia/docs/TechPolicyBlueprint2002.pdf p35 US Government;” US Telecommunications Act of 1996 – SEC. 706. Advanced Telecommunications Incentives”. 22 http://broadband.gc.ca/Broadband-document/english/executive_summary.htm 21 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 16 Australia needs to adopt a definition of broadband, which focuses on functionality rather than pure bandwidth. This definition needs to be reviewed on a regular basis and needs to be implemented through a mechanism such as the Universal Service Obligation. Substantial funds need to be allocated to ensure our education, research and health sectors continue to be leading users and developers of high bandwidth applications. 3.1. Backbone Network In December 1998, the Commonwealth Government established the National Bandwidth Inquiry23 to examine the outlook for communications bandwidth and pricing over the next five years. This report found that there is likely to be adequate bandwidth in the backbone network on most routes to meet the majority of demand scenarios. It also reported that prices are expected to fall in all areas over the period considered in the report, with decreases in wholesale prices of 30-50% per annum expected on the more competitive and thicker routes. Queensland Government, concerned that regional Queensland would not share in these price reductions, instigated a project to establish a competitive fibre backbone along the Queensland Coast. Analysis by the Department of Innovation and Information Economy indicates cost savings of approximately 60 percent, are now available given the Reef Network is in place. The Queensland Government is currently progressing its SmartNet project, which uses aggregated demand from government and the community to provide improved data services and infrastructure in Northern Queensland, as well as the data services for Queensland schools. Over the past five years, the Queensland Government has generated infrastructure initiatives valued over $200 million to respond to the needs of rural and regional Queenslanders for equitable access to telecommunication services. Independently the Commonwealth Government has invested a similar total. While recognizing telecommunications is a constitutional Commonwealth Government responsibility, future investments need to be progressed cooperatively to maximize the benefits for Queensland and Australia as a whole As an observer, it would appear Telstra is unwilling to offer discounts until competitive infrastructure is fully commissioned and providing real competition. From this it is concluded that Australia has to endure the payment of duplicated infrastructure before it can expect significant price or efficiency benefits to flow from Telstra. This is an untenable situation as Australia seeks to effectively compete on a global stage. Australia needs to find a solution, which results in appropriate investment in infrastructure, while facilitating competition of value added services. This solution needs to combine the efforts and assets of all levels of government. 23 http://www.noie.gov.au/projects/information_economy/bandwidth/ Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 17 3.2. Customer Access Network (the famous last mile) In Australia broadband services are provided through technologies including cable, satellite and Digital Subscriber Line (DSL). It is understood that the Commonwealth’s stance is affordability will come, as more vigorous competition starts to occur in the Customer Access Network24 (CAN). From the analysis in Section 1.1, it is evident competition is very fragile and is unlikely to produce a timely benefit for Australia. Telstra's cable network passes 2.1 million homes along the eastern coast of Australia. Optus offers services to potentially 2.2 million homes in Brisbane, Sydney and Melbourne – 70% of which are also within Telstra's reach.25 To date the services over these, largely duplicate, infrastructures have yet to return the billions of dollar in investment. Current losses estimated by Budde Communication are in the order of $4Billion26. The determination of the USO costs was a significant endeavor by the Commonwealth Government in 2000. An assessment of costs of using future looking technologies in the Customer Access Network was considered and formed a key plank for a low determination of the cost of the Universal Service Obligation (USO). 27. Subsequently the USO contestability pilots were established as a mechanism to test the business models, commercial interests and utility of these technologies28. It is understood that while a framework for contestability has been established, few services have actually been provided. The Commonwealth has made a $150m investment to improve the Customer Access Network in the Extended Zones29. This investment in Telstra services provides improved phone services and a minimum 14.4kbps data service. Support through the Commonwealth and Telstra funded Internet Assistance Program will assist most Australians to achieve a 19.2kbps service. Unfortunately this benchmark falls woefully short of the levels required and those set by our first world peers. The telecommunications industry has piloted a number of alternative wireless Customer Access Technologies, unfortunately few have been offered as actual products. It is hoped these new technologies will be offered to Queensland as part of the State Government's SmartNet initiative30 which is currently out to tender. Telstra has been protective of the Customer Access Network and has effectively delayed competitive access to this essential infrastructure for the provision of broadband services such as DSL. Changes in Telstra's network architecture, which move fibre closer to the curb, have also had the effect of limiting competitors' access to the copper needed to provide DSL services. 24 Usually the copper wires that connect telephone subscribers to their local exchange. http://www.oecd.org/pdf/M00020000/M00020255.pdf; page 21 26 Paul Budde Communication Pty Ltd; “Australia - Pay TV - Industry Developments 1996 – 2000”, p 8. 27 http://www.aca.gov.au/consumer/reports/fwltpaper.pdf 28 http://www.dcita.gov.au/Article/0,,2_1-4_15191,00.html 29 http://www.dcita.gov.au/Article/0,,2_1-4_107669,00.html 30 http://www.iie.qld.gov.au/telecommunications/projects_subpages/nth_qld/nth_qld.html 25 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 18 In order to provide an appropriate Customer Access Network it is recommended that: the full Customer Access Network be declared not just the copper wire; and any future subsidization of telecommunications projects needs to support equity as well as converged infrastructure solutions. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 19 4. Current and Future investment requirements to achieve adequate services. The recent history of telecommunications infrastructure development in Australia is a sorry tale of wasteful duplication. In areas of demand, such as south-east Queensland, infrastructure with very low utilisation levels is being duplicated because it is cheaper to duplicate facilities than to participate in inter-connect arrangements. Some may argue that duplicated infrastructure represents productive investment. In fact, infrastructure investment that imposes excessive costs on telecommunications users represents wasteful investments and an inappropriate use of scarce investment resources. Budde Communications31 estimates that $5 billion is all that is needed to kick-start broadband, mainly to ensure that everybody in Australia can profit from this development. He considers a fully privatised Telstra will find it very difficult to find the money to rationalise broadband investments in economically unviable regions. It is recommended that the Commonwealth Government allocate regular budget funding to manage its telecommunications responsibility. Items requiring regular budget support should include: Subsidies to maintain mobile and extend mobile coverage; Contributions to the Universal Service Fund for broadband services; Funding to ensure bandwidth is not an impediment for Australia's world-class researchers, education and health providers. 31 http://www.budde.com.au/TOC/TOC2743.html Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 20 5. Measures needed to achieve adequacy The Commonwealth Government has used the privatisation of major airports32 as an example of where legislation and regulation can be used to effectively manage a sector. Unfortunately, apart from privatisation there are hardly any other parallels. Generally airports consist of one infrastructure provider who is interested in doing business with customer service providers. To be effective, this analogy would be similar to designating Telstra as an infrastructure provider with a charter and motivation to share facilities on a commercial basis with competitive customer service providers. Also under such an arrangement Telstra would not be permitted to “sell seats on planes” i.e. sell services directly to consumers. Never-the-less telecommunication regulation is likely to remain more complex for some time to come. The need for adequate controls will become increasingly important. Measures suggested by the Queensland Government are outlined in the subsections on: Improved competitive measures; and Changes to the Universal Service Obligation and Customer Service. 5.1. Competitive measures The Queensland Government believes33 a more proactive approach to competition is needed. A summary of the specific competition recommendations made, by the Queensland Government, to the Commonwealth Government, in response to the Productivity Commission’s Final Report on Telecommunications specific competition Regulation, is listed below: ACCC needs to ensure cost effective broadband access by Australians is not constrained through gaming; Impediments to competition need to be regularly identified and removed; Mobile roaming, portability and the Customer Access Network need to be declared; Review of information provision and reporting requirements be expedited; Access pricing must be realistic and not permit preferential downstream pricing (transfer); Industry development planning process needs to change into a more useful process; Regular reviews and renewal of carrier licences; and Industry self-regulation needs addition support and a refined frame of reference if it is to be effective. In addition the Queensland Government recommends: the ACA ensuring the parameters for the numbering plan and the integrated numbering databases are an Australian Public Assets not carrier assets; Ownership and management of charging zones should be vested in an independent body rather than the dominant carrier; and Customers owning phone numbers and other identifiers. 32 http://www.abc.net.au/am/s591363.htm Qld Response to the Recommendations of the Productivity Commission’s Final report on Telecommunications Specific Regulation, February 2002 33 Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 21 Institute a range of measures aimed at improving the competitiveness of the telecommunications industry in Australia. 5.2. Changes to the Universal Service Obligation and Customer Service. The Customer Service Guarantee was discussed in some depth in section 2.1. It is considered to the most appropriate mechanism on which to build Australia's move to broadband and global competitiveness. The customer service guarantee needs to define Australia's minimum telecommunications requirements, not just for the phone, but also for Internet, broadband, mobile phones, Television etc. It needs to look at these services in a converged way. The process for managing these services is already well established as part of the Universal Service provision. To date only carriers contribute to the costs of the Universal Service Obligation (see section 1.1). The funding model needs to be extended such that the Commonwealth Government as part of its responsibilities, Internet Service Providers, Broadcasters and content providers can also provide their contribution. Enhance the Customer Service Guarantee and the process for managing the Universal Service Provision to provide converged services and all existing telecommunications services in the future. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 22 6. Other Matters In comparison, to the Australian Government, the Canada Government has maintained a greater focus on Broadband technologies and their implementation. This focus has been consistent since the early 1990's and is now producing results. 34 The most recent program of work instigated in January 2001, was the establishment of Canada’s National Broadband Task Force. This Task Force's principal mandate was to map out a strategy for achieving the Government of Canada's goal of ensuring that broadband services are available to businesses and residents in every Canadian community by 2004.35 The Task Force has completed its work, and its report estimates progressing the broadband access objective, in partnership with other stakeholders, will cost between 2.7 and 4.6 Billion Canadian dollars. Our research indicates the Japanese, Korean and Danish Government have all made similar commitment to planning and implementation. Australia needs to aim to be more than adequate! 34 35 http://strategis.ic.gc.ca/SSG/ih01501e.html http://broadband.gc.ca/Broadband-document/english/executive_summary.htm Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 23 Revenues ($million) POCKETMAIL GROUP COMMSOFT GROUP NSW NSW 11-Jan-00 19-Sep-00 $2.90 $3.90 3 4 -97.84% TEE -96.94% DCS TELE-IP LIMITED DCS TECHNOLOGIES VIC WA 5-Jan-00 16-Dec-99 $3.10 $0.40 5 6 -95.94% WSG WESTEL GROUP LIMITED -95.80% SKG SKYNETGLOBAL LIMITED NSW NSW 13-Feb-95 15-Nov-00 $5.40 $2.90 7 8 -95.47% MAQ MACQUARIE CORPORATE -95.38% MBX MBOX.COM LIMITED NSW WA 27-Sep-99 2-Mar-00 $219.40 $0.20 9 10 -94.31% VXS -94.23% OTT VOXSON LIMITED OPEN TELECOMM. Qld NSW 17-Dec-99 3-Dec-99 $3.90 $88.10 11 12 -94.17% PIE -94.03% ETT PIENETWORKS LIMITED ELECTRONIC TRANS. WA NZ 7-Apr-00 23-Feb-00 $2.00 $1.40 13 14 -93.80% FLO -93.79% TLE FLOWCOM LIMITED TELE2000 LIMITED NSW NSW 8-Sep-00 4-Apr-00 $13.60 $2.10 15 16 -93.50% OBJ -93.48% EFN OBJECTIF TELECOMM. EFTNET TECHNOLOGIES NSW WA 30-May-00 23-Nov-99 $3.80 $1.30 17 18 -93.43% TLO -92.90% SCG TELCO AUSTRALIA SMART COMMUNICATIONS NSW NSW 7-Dec-98 17-Aug-00 $2.20 $25.40 19 20 -91.66% SWT SWIFTEL LIMITED -91.64% FOC FOCUS TECHNOLOGIES WA Qld 2-Jul-92 29-Jul-99 $0.50 $0.10 21 22 -90.61% SRT STARTRACK COMM. -90.37% PWT POWERTEL LIMITED WA NSW 9-Jul-92 24-Aug-98 $1.50 $48.00 23 24 -89.72% ESV -89.33% BBB NSW WA 8-Sep-00 13-Jun-00 $43.90 $129.50 25 26 -87.50% AVC AUSTRALIAN VISUAL -87.04% MOB MOBILE INNOVATIONS Qld NSW 1-Nov-00 25-Jun-99 $13.80 $63.00 27 28 -86.38% DVT -86.21% TNY DVT HOLDINGS LIMITED TENNYSON NETWORKS NSW VIC 13-Jan-99 10-Jul-92 $75.20 $3.30 29 30 -85.29% NTC -83.86% PCO NETCOMM LIMITED. PRACOM LIMITED NSW VIC 6-Dec-99 15-Dec-98 $17.40 $219.60 31 32 -83.61% CLA -82.50% QTL CLARITY INTERNATION. QUADTEL LIMITED NSW NSW 11-Oct-00 30-Apr-96 $44.90 $8.90 33 34 -80.45% PHO -78.39% STE PHONEWARE LIMITED STRATATEL LIMITED VIC WA 2-Oct-97 8-Dec-00 $12.00 $0.50 35 36 -74.55% CCO -73.33% BRE CIRCLECOM LIMITED BREATHE GROUP VIC VIC 20-Jul-92 18-Sep-92 $20.40 $20.10 37 38 -71.20% WAL -70.83% TML WAVENET INTERNATION. TIMEMAC SOLUTIONS WA WA 17-Mar-00 28-Oct-99 $0.70 $0.00 39 40 -65.93% PAH -51.99% CLT PAHTH TELECOM. CELLNET TELECOM. WA Qld 9-Nov-99 17-Nov-99 $12.50 $247.50 State ASX code Company name -98.25% PKT -98.23% CSG Share growth 1 2 Industry description Date from which assessment is based Attachment 1 - Australian Listed Companies share performance36 Equipment, Services 36 ESERVGLOBAL LIMITED B DIGITAL LIMITED Derived from ASX Data. Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 24 Date from which assessment is based Revenues ($million) VIC 19-Dec-00 $11.50 IINET LIMITED AUTRON CORPORATION WA VIC 20-Sep-99 13-Jan-99 $19.90 $181.20 44 45 -15.05% CDR 2.58% ERG COMMANDER COMMUNICA. ERG LIMITED NSW WA 1-Dec-00 29-Jun-92 $146.30 $263.90 46 182.49% NTG NATIONAL TELECOMS NSW 14-Dec-00 $50.40 DATAFAST TELECOMM. UECOMM LIMITED VIC VIC 7-Oct-99 11-Sep-00 $6.10 $30.50 $9.20 $418.60 State ASX code Company name SIRIUS TELECOMMUN. -32.73% IIN -20.35% AAT Share growth -33.93% SIU 42 43 Industry description 41 Network Operator 1 2 -96.40% DFT -94.24% UEC 3 4 -89.74% AMM AMCOM TELECOMM. -86.52% HTA HUTCHISON WA NSW 8-Dec-99 17-Aug-99 5 6 -23.51% TLS -20.33% SGT TELSTRA CORPORATION. SINGAPORE TELECOMM. VIC NSW 27-Oct-98 $18,679.00 10-Sep-01 $10,710.00 7 8 145.61% SOT 178.29% TEL SP TELECOMMUNICATION TELECOM CORPORATION NSW NZ 10-May-01 17-Jul-92 $8.00 $4,501.00 Other Telecommunications 1 2 -97.96% SPK -95.74% IVK SPIKE NETWORKS INVESTIKA LIMITED NSW NSW 23-Jul-99 17-Sep-99 $5.00 $0.50 3 4 -91.18% CXL -90.00% MRY CENTRAL EXCHANGE MONTERAY GROUP WA VIC 21-Dec-99 3-May-99 $0.00 $0.20 5 6 -87.50% SOU -87.14% PUL SOUTHPOINTE LIMITED PULSAT COMMUNICATION WA VIC 28-Mar-96 27-Oct-99 $1.20 $0.60 7 8 -83.75% QAD -81.24% ITC QUADRANT IRIDIUM IMPRESS VENTURES WA WA 17-Aug-99 26-May-99 $0.10 $0.20 9 10 -80.51% CTI -76.32% EZY CHARIOT INTERNET EASYCALL INTERNAT. SA Singapore 23-Dec-99 16-Feb-98 $15.70 $12.80 11 12 -75.00% QUE QUESTE COMMUNICATION -74.26% NWL NEW TEL LIMITED WA WA 11-Nov-98 8-Jun-99 $0.80 $30.30 WA 7-Dec-00 $1.20 13 3.91% QPX QPSX LIMITED Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 25 Attachment 2 - Summary of carrier performance in against the Customer Service Guarantee in Queensland37 exempt not met March 2002 met exempt not met December 2001 met exempt met not met Table Optus' quarterly In-place performance for the New services percentage of Faults repaired connections provided within the timeframes specified in the CSG Standard September 2001 exempt met Infrastructure Availability not met June 2001 100 0.1 99 0.9 89 11 0 100 0 0 99 1 3 94 6 0 100 0 0 99 1 2 91 9 0 100 0.2 1 93 7.5 3 87 13 0 3 5 Telstra's quarterly In place performance for the percentage of inplace connections provided within the timeframes specified in the CSG Standard 95 5 - 96 4 - 97 3 - 97 3 - Telstra's quarterly performance for the percentage of new service connections provided within the timeframes specified in the CSG Standard 91 92 92 90 90 90 96 92 96 97 97 97 99 92 96 94 93 96 87 9 8 8 10 10 10 4 8 4 3 3 3 1 8 4 6 7 4 13 < < < < < < < < < < < < < < < - 92 92 92 91 91 91 97 87 96 96 97 96 92 91 92 94 93 96 90 8 8 8 9 9 9 3 13 4 4 3 4 8 9 8 6 7 4 10 - 93 7 97 3 93 7 92 8 96 4 92 8 96 4 92 8 95 5 96 4 98 2 96 4 99 1 99 1 99 1 89 11 87 13 93 7 93 7 ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` 92 96 92 91 95 91 95 94 95 96 99 96 98 95 97 87 82 94 94 8 4 8 9 5 9 5 6 5 4 1 4 2 5 3 13 18 6 6 # # # # # # # # # # # # # # # # # # # with infrastructure All areas, without infrastructure All areas, with & without infrastructure Urban with Urban without Urban with and without Major Rural with Major Rural without Major rural with and without Minor rural with Minor rural without Minor rural with or without Remote with Remote without Remote with or without Telstra's quarterly All areas performance for the Urban percentage of faults Rural repaired within the timeframes specified Remote in the CSG Standard 37 http://www.aca.gov.au/publications/performance/2002/data032002.rtf Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 26 Attachment 3 – Mobile coverage Queensland Government Submission to the Senate Inquiry into the Australian Telecommunications Network 27