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I have been a regular user of the NT domestic shortwave service for a number of years when travelling in parts of remote Australia and the . I am appalled by the ABC’s ill-informed decision to terminate this service and wish to see the service reinstated.

While I support the principle behind the bill being considered, I hold some concerns as to the inflexibility of some provisions. I have offered my thoughts on the various provisions of the bill later in this submission.

I will principally address the domestic shortwave services given that is my area of experience, but I will also touch briefly on the international shortwave service.

History/Context For many decades until the introduction in 1986 of the NT Shower service referred to in this bill, the Northern Territory was principally served on shortwave by VLW which broadcast ABC Regional Radio to and the NT from a transmitter site in Perth.

A coverage map produced by Telecom Australia (the body then responsible for ABC transmission services) can be found in Appendix 1 which clearly shows that most of Australia could receive ABC domestic . Mediumwave services largely filled in the gaps. Nevertheless the service received from VLW was not considered satisfactory for a range of reasons - largely to do with the expanding development of the Territory - so the need for a specific NT shortwave service was identified.

Following a decade of deliberation the three NVIS (Near Vertical Incidence , also known as Shower) transmitter sites were constructed and put into service throughout 1985 and 1986. The initial cost of the service was $4.2 million (approximately $11 million today). VL8A , VL8T Tennant Creek and VL8K Katherine were each intended to provide a primary service range of 450km from a 50kW transmitter1. The Central Australian Aboriginal Media Association (CAAMA) made use of the transmitters alongside the ABC2.

These transmitters were in service until the mid-2000s when they were successively taken out of service for replacement with newer models. During this time Radio Australia (Shepparton) relayed NT programmes to NT listeners. Those new transmitters remained in service until the 31st of January 2017, where they were switched off at noon NT time.

This switch-off came after a 6th of December 2016 press release announcing the ABC’s plan to terminate all their remaining shortwave services – both Radio Australia’s International service and the Northern Territory domestic shower service.

The closure of the domestic service has left a large void for people in Northern and Central Australia wishing to receive news and entertainment while on the move.

Overview of problems The ABC Domestic Shortwave Shower services were transmitted from three transmitter sites in the NT. The powerful transmissions could be heard in all corners of the Northern Territory plus remote parts of WA, QLD, SA and even NSW, despite the ABC’s argument that the service is only good for 200km reliably3. In my experience, the Alice Springs signal was readily heard as far away as the Flinders Ranges at all hours – it had to be, for there is no other radio service in that part of SA.

The ABC contends that the VAST satellite service provides an adequate replacement to shortwave radio. However, this is not the case. Many people in remote Australia are constantly on the move, and it is clear that a satellite system installed in a fixed location is of no help to someone who is away from their living room most of the time.

A shortwave car head unit, which can be obtained for around $120, provided high quality listening in a moving vehicle. VAST can not be received in a moving vehicle – nor on a boat without equipment costing tens of thousands of dollars.

In the name of progress a portable and cheap radio has been replaced with a dish, television, set top box, metres of cables and half an hour of technical setup time.

1 ‘New ABC radio set to go on air’ 1986, Centralian Advocate, 22 January, p. 22. 2 ‘One Of The Mob’ 2016, television program, Australian Story, ABC TV, 4 July. 3 http://about.abc.net.au/press-releases/shortwave-radio/ Mental health problems are already a major issue in remote areas, especially amongst pastoralists. Suicide rates amongst farmers are twice the national average4. The isolation experienced in remote areas is confronting – and I say this as a tourist who can leave at any time. To lose the only useful link you have with the outside world on a daily basis would be devastating. Having the radio on in the background – even just knowing that there is a radio signal there – is a great comfort when in these remote areas.

Former listeners to the shortwave service have been advised to download podcasts, buy satellite phones and radio scanners, listen to 4WD transmissions and Royal Flying Doctor Service “broadcasts” – all in an effort by the ABC to shirk its fundamental duty as the premier national broadcaster.

The argument that shortwave is nearly a century old and thus should be closed down does not stand up to scrutiny. Mediumwave transmision (also using AM) predates shortwave but I can’t see the ABC rushing to dispense with their city and rural audiences any time soon.

The ABC has been in a financially tight place for a number of years now which undoubtedly did not help those making this decision. Nevertheless there is no sign of the money saved from this switch-off actually being saved to make up for a budget shortfall – all evidence suggests that it will be spent on new services to capital cities and FM relays throughout the Pacific. I would wager that most capital city residents would more than happily forgo these new services if they were made aware of how the money became available for them.

The ABC clearly does not understand the limitations and benefits of certain technologies – or rather does not want to – and so leaves its most loyal and isolated listeners in total silence with less than 2 months notice. This is not a closure of “duplicative services” – it is a closure of the only radio service available in vast swaths of the Northern Territory and other parts of remote Australia.

At this point in time there is no alternative technology available in Australia to replace the service that was provided by the NT Domestic Shortwave.

Transitional Measures & HF Radio The ‘transitional measures’5, released on the last full day of shortwave transmissions – presumably to placate an unexpected hounding in the media – serves little practical benefit. One of the measures offered was a digital booklet which consists of screenshots of data already readily available through the ABC’s website6. One of the others was to donate VAST satellite systems to RFDS bases and 4WD radio network bases (which presumably includes VKS-737, VKE-237, Reid’s Radiodata and similar).

It should be noted at this point that there are two main types of two-way HF radio services available for the general public – the RFDS-based “Outpost” and the private HF radio networks such as VKS-737.

The Radiocommunications Licence Conditions (Outpost Licence) Determination 2015 provides for 11 RFDS bases as “Outpost Assigned” stations. These are located at Alice Springs (NT), Broken Hill (NSW), Carnarvon (WA), Charleville (QLD), Derby (WA), Kalgoorlie (WA), Kuranda (QLD), Meekatharra (WA), Mount Isa (QLD), Port Augusta (SA) and Port Hedland (WA). At the time of writing the ACMA has approximately 3000 “Outpost Non Assigned” licences registered across Australia which allow the licence holder to communicate with the Outpost Assigned bases and with other Non Assigned users.

Until the turn of the century the Outpost Non Assigned licence also provided for access to School of the Air frequencies and Telstra’s Radphone and Seatex services7. Radphone provided telephone interconnect and Seatex provided radio services. Around this time the long-running Outpost station VJY (St John Ambulance Darwin) closed down, leaving the RFDS as the sole Outpost Assigned licence holder and Alice Springs as the only NT base.

The Outpost radio service operates under the Licence Conditions Determination referred to above and it would be fair to say that it provides a very limited service today to what it once offered in decades past. That gap has largely been filled by the other, traveller-based, radio networks.

To communicate on any of these networks requires a significant capital investment. A good secondhand radio will be at least $500-$1000. A new model is several thousand dollars. You will also need an antenna which can range from

4 http://www.abc.net.au/news/2008-08-19/farmers-suicide-rates-double-national-average-study/482170 5 http://about.abc.net.au/statements/abc-shortwave-closure-transitional-measures/ 6 http://reception.abc.net.au 7 https://web.archive.org/web/19980131223252fw_/http://www.aca.gov.au:80/support/pubs/info/outpost.htm $250 to $1000 depending on the type. On top of this you will have a licence fee to the ACMA (outpost licence) or one of the 4WD networks.

The 4WD networks can be very powerful when used fully (with telephone interconnects, SMS and email messaging, GPS position logging, general conversation and base operators who can obtain information for you) but based on my experience I doubt any network is remotely capable of making use of any VAST system in any useful and timely manner – especially when you consider that the base operators are located all over the country and are dialling in to any base by telephone8.

Frankly the suggestion smacks of arrogance and I would find it difficult to believe anyone relevant was consulted before this offer of VAST equipment was foisted upon them.

Based on the ABC’s claims of a 200km NT service coverage area, one RFDS base will receive a VAST system, even though it doesn’t need it being located in a town of 25,000 people (Alice Springs). Even if the NT shortwave service area is the whole NT, plus parts of WA, SA and QLD (as has been readily evidenced) you’d only reach a couple. A total farce. The 4WD networks don’t see much benefit either – VKS-737 has 2 bases in the NT (Alice Springs and Darwin) and HFoZ appears to be the only other network with a base in the NT. As addressed above it’s useless as the base operator could be thousands of kilometres away and the bases are already in AM/FM/ capable regions.

If the 4WD networks obtained ABC emergency information (be it from VAST or otherwise) it would be up to the operators to record, trim and find some method of getting this audio down a phone line into the base station – a totally unreasonable burden. VKS737 provides their sked times to members only, so even if I had a single-sideband radio receiver I could be sitting for many hours with static blasting out of the speaker waiting for any transmission. Even then there’s no guarantee I might hear it given that the maximum transmitter power of the 4WD networks is 100 watts. The NT showers had 50,000 watts each and were available around the clock with a public schedule.

Any suggestion that the Bureau of Meteorology HF voice services might be of any use leaves one incredulous. The artificial voice comes on every hour and provides marine weather information of absolutely no consequence whatever to someone out the back of Yuendumu or Finke. The signal is not particularly good inland and you need a single- sideband receiver – not often found in normal shortwave radios. It is very difficult to believe that this recommendation was made by anyone who had ever listened to a BoM transmission.

Listener Complaints The ABC has often repeated the claim that “less than 20 from those located within the affected area” have made complaints, but has been very sure to never specify what they consider to be “the affected area”. Is it the falsified 200km range? Is it the NT? Is it the whole of remote Australia? Does it include offshore regions?

A quick browse through suggests that more than 20 people have had their complaints lost in the ‘black hole’ of the ABC complaints department. Myself included – my original complaint, submitted using their web form9 on the 7th of December 2016 is still awaiting a reply. At least 6 people protested the closure at the Alice Springs transmitter site10 and dozens of submissions have been presented to this Senate Committee – most with a personal story. Hundreds more have expressed their anger and disappointment on social media, talkback radio and through media interviews. There is none so deaf as those who will not listen.

Promotion of service I only found out about the NT domestic service by chance while browsing a shortwave frequency website. I was in the process of charting out a list of the most appropriate Radio Australia frequencies, languages and azimuths for a trip where I was going to be out of range of mediumwave stations – even at night. I had been a prolific user of the ABC’s Reception Advice website11 in locating MW and FM transmissions through the postcode or town/suburb search. No mention has ever been made of the Domestic Shortwave service on the frequency finder even though it would be trivially easy to bring it up as a potential service for any NT address entered.

There is little evidence of the shortwave service being regularly mentioned on air – the station was always identified as “783 ABC Alice Springs” in my listening. However, I have no doubt that the presenters knew they were broadcasting to all corners of their Territory.

8 http://www.vks737.on.net/skedshow.html 9 http://www.abc.net.au/contact/complain.htm 10 ABC TV News (NT) 31/01/2017 11 http://www.abc.net.au/reception/freq/ I have found many travellers bemoaning poor radio reception in the remote regions of Australia who were unaware of the existence of the NT shortwave service – even if their radio was shortwave capable. Evidently the shortwave service was better known than the ABC currently admits, but not as well-known as it should have been. The ABC has a large network of signs around the country advising people to tune to their local mediumwave frequency in an emergency – A set of signs advertising the relevant shortwave frequencies at strategic locations in the NT would not have been amiss.

ABC Radio coverage after shortwave closure and the Tropical Bands The new ABC coverage estimator using Google Maps12 also made no mention of the NT Shower service, however it does provide an excellent avenue for the general public to perform mediumwave and FM coverage area calculations. Using the coverage files available for download I measured the service area of all ABC Local Radio mediumwave and FM transmitters in a number of states and the Northern Territory. The landmass covered is as follows:

Northern Territory: 3% (three) Western Australia: 31% : 32% : 70% : 82%

It is outrageous to suggest that the NT enjoys “a number of duplicative services” on the basis that listeners could choose between either VAST or shortwave across 97% of the NT landmass. A similar argument could be made against a number of high power mediumwave stations in regional centres.

Following the shortwave closure, I have experimented with external antennas in an attempt to increase signal levels on mediumwave stations. While this worked to some degree (notwithstanding the practical difficulties and electrical storm safety concerns involved with stringing 50m of wire in the air) it had the effect of amplifying both the station and all the atmospheric noise. The static crashes of a lightning storm over a thousand kilometres away wiped out the weak broadcast signal, which rather goes to my next point.

The International Union indicates that the frequency bands 2300-2495kHz, 3200-3400kHz and 4750-5060kHz (the ‘Tropical Bands’) are to be used for domestic broadcasting in tropical regions13. In ITU Region 3 (Oceania and Asia) the tropical zone is between 35 degrees south (approximately in line with Adelaide) and 30 degrees north (approximately in line with Nepal). The ABC holds an ACMA ‘Broadcasting - HF Domestic Service’ licence for a frequency in each band at all three NT transmitter sites, although I do not know if the 3MHz frequencies have ever been used in general service.

The Tropical bands are so called because they are shortwave bands principally intended to be used as an alternative for longwave and mediumwave domestic broadcasting in tropical regions. This is because atmospheric interference from thunderstorms in the tropics at those lower frequencies significantly reduces coverage and signal quality. Currently there are in excess of 100 stations utilising the Tropical Bands worldwide, and many hundreds more broadcasting domestically on international shortwave frequencies (above 5900kHz)14.

Arguments that shortwave is not a reliable technology for broadcasting in the Northern Territory do not stand up to scrutiny. All evidence suggests that it is by far the most reliable technology currently available.

I will touch briefly on the International service, noting that this submission is already quite lengthy.

The main target area of Radio Australia’s shortwave transmissions, and indeed its programming in general, was and is to the South Pacific. While the cyclonic activity and other natural disasters that frequently occur in the region have been raised, the relative political instability in many countries in that region has had comparatively little coverage.

Notwithstanding all the other difficulties of satellite systems (such as cyclonic winds, rain fade and cost) it should be considered that a satellite system is nearly impossible to hide from authorities. Internet usage can be monitored and it is easy to block sites or completely terminate connections.

A shortwave radio on the other hand can fit in the palm of the hand and be bought very cheaply (basic units can be had from $10 Australian dollars). It is easy to hide and is untrackable and untraceable. In the developing world they are still a common item and are not likely to be seen as suspicious. 12 http://reception.abc.net.au/ 13 http://www.itu.int/en/ITU-R/terrestrial/broadcast/Pages/Bands.aspx 14 http://www.dswci.org/dbs/ This is not some mere historical consideration – as recently as 2009 the Radio Australia FM retransmitters in Fiji were ordered to be switched off during the constitutional crisis15. Meanwhile, shortwave signals from abroad were reaching everyone in the country. Is it wise for Australia to have no voice at such a time? China is maintaining and expanding its shortwave transmissions which cover most parts of the globe. Radio New Zealand International has reduced, but not completely cancelled, its Pacific shortwave service. The BBC World Service does not maintain a general worldwide shortwave service as it once did but it still has well over 200 shortwave transmissions in a range of languages scheduled – mostly targeting parts of the world where there is limited press freedom or where listeners have limited resources.

In the event of a natural disaster taking out local infrastructure (such as electricity generators, antenna masts and satellite dishes) shortwave will be the only thing that gets through. During cyclones in Queensland the ABC has advised listeners to tune to Radio Australia shortwave frequencies in case their local station goes out. Listeners in the path of cyclones in far north WA have been advised to tune to NT Shortwave frequencies in case their local transmitter fails. Radio Australia on shortwave had long been a trusted source of emergency information throughout the Pacific.

Consideration of Australian Broadcasting Corporation Amendment (Restoring Shortwave Radio) Bill 2017 After reviewing all the evidence available it is clear that the decision to terminate the shortwave service is absolutely indefensible (particularly in regards to the domestic service, but also internationally) and it must be reversed without delay. Some criticism may be levelled at the bill for infringing too much on the ABC’s independence – I see it as an unfortunate, but necessary step to ensure their programming (the content of which is not to be dictated) can reach those otherwise forgotten listeners.

Efforts to legislate specific methods of transmission in the past have been successful. The Parliamentary Proceedings Broadcasting Act 1946 requires that the ABC broadcast the proceedings of one of the houses of the Commonwealth Parliament through a mediumwave transmitter in the capital city of each state (and the city of Newcastle in NSW).

Never in the history of the ABC, be it the Commission or the Corporation, has there been such a substantial loss of radio coverage. The Inland Shortwave Services (Appendix 1), which were closed in the 1980s and 1990s, did so after mediumwave and NT shower transmissions adequately covered most of the Australian continent. Following this decision approximately 1,400,000km2 of coverage has been lost in the Northern Territory. If you disregard political boundaries (as shortwave radio does) that figure can comfortably be doubled.

Parliamentary involvement is more than justified following a move such as this. I will address my thoughts about the bill in two sections.

Domestic services: (1) The Corporation must maintain 3 domestic shortwave radio transmission servicesA for the Northern Territory which: (a) cover the same areas of the Northern Territory as the Corporation’s shortwave radio transmission services covered on 30 January 2017B; and (b) broadcast the proximate local radio serviceC.

A. Consideration has been made in previous years to terminating the Shower services and serving the NT from one shortwave transmitter – potentially located at Radio Australia Shepparton. As there is only 2 programme feeds in the NT there is no need to have more than 2 transmitters, provided that they have adequate coverage. B. Does the ABC actually know what areas of the Northern Territory their shortwave service covered? Their map in Appendix 2 demonstrates a coverage area of between 300km and 500km. The Centralian Advocate published that the coverage area was 450km. The ABC’s shortwave closure information page advises that the coverage area is 200km. Evidence heard in recent months suggests that the signal was readily heard much further out than that. C. Will “proximate local radio service” mean proximate to the transmitter? There is no requirement for the transmitter to be sited in the NT.

Consider an alternate approach: (1) The Corporation must maintain a domestic shortwave broadcasting service which: 15 http://www.radionz.co.nz/international/pacific-news/183105/fiji-interim-regime-cuts-fm-rebroadcasts-of-radio-australia (a) provides primary coverage across an area not less than 450 kilometres radially from: (i) the town of Katherine in the Northern Territory; and (ii) the town of Tennant Creek in the Northern Territory; and (iii) the town of Alice Springs in the Northern Territory.

(2) The programme broadcast in each primary coverage area must be a simulcast of the Corporation’s radio programme recognised as the primary local radio programme in each centre.

(3) Subsection 2 does not limit the Corporation from broadcasting any programming via a shortwave transmitter maintained for the purposes of this section provided that: (a) use of the transmitter provides a practicable method of reaching the intended audience; and (b) the programming relates to an emergency; or (c) the programming covers a live event of national or local significance.

Subsection 1 provides that the ABC must maintain a domestic shortwave broadcasting service which covers three distinct areas – each a 450 kilometre radius around the central town.

Subsection 2 provides that the programme to be broadcast across these primary coverage radii must be sourced from the ABC Local Radio network as broadcast in the town at the centre of each radius – i.e. a shortwave broadcast targeting the Alice Springs radius should be a simulcast of the programming on 783kHz. If Alice Springs and Tennant Creek share the same programming one transmitter can be used to serve both coverage areas.

Subsection 3 provides that the shortwave service transmitters may be used to broadcast programming other than the relevant Local Radio service, so long as the transmitter will reach an appropriate audience. For example, the emergency programming provision could be used to broadcast Western Australian cyclone programming into the Kimberley should the need arise. The “live event” provision serves to allow coverage of major events (e.g. elections) to be broadcast to shortwave listeners with no other radio service to choose from, even if ABC Local Radio is not broadcasting the event in question.

International Services: (2) The Corporation must maintain an international shortwave radio transmission service for Papua New Guinea and parts of the PacificA which: (a) uses at least 3 transmittersB; and (b) broadcasts the Corporation’s international service; and (c) broadcasts programs in languages appropriate for the countries to which they are broadcast.

A. Greater detail must be put into what “parts of the Pacific” actually are. Consideration could be given to charting out a region containing the relevant target countries and legislating the boundaries. Another option would be to list all the target countries. Alternatively, a requirement such as “covers the same areas as on 30th January 2017” could be employed. A map of Radio Australia’s primary shortwave service area from 2014 until its closure can be found in Appendix 3. B. I am unconvinced that Radio Australia must be forced to operate 3 transmitters. Prior to the shutdown the same programming was available through each transmitter. Provided that the ABC can maintain a satisfactory level of service in the target regions I see little need to require a minimum number of transmitters.

Summary I support the bill in principle, however I hold some concerns about the specific requirements placed on the Corporation. I ask the committee to consider my domestic services section proposal to make the requirements on the ABC clearer and to give them greater flexibility into the future.

I am not an operator or shortwave enthusiast, nor do I presently own any HF transceivers or sell shortwave radios. The only interest I have in the topic is a desire to ensure a basic service provision in those very remote regions of Australia like I once enjoyed. Surely just one radio service for all is not too much to ask.

The NT domestic shortwave service provided a high quality signal into all parts of remote Northern and Central Australia and was terminated without regard to those listeners who relied upon it as their only regular contact with the rest of the world. All efforts must be made to ensure the restoration of this essential service. Appendix 1

Source: Committee of Review of the Australian Broadcasting Commission, 1981, The ABC in review: national broadcasting in the 1980s. (The Dix Report) Appendix 2

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Source: ABC presentation to the Coordination Conference (HFCC), 2015 http://www.hfcc.org/doc/HFCC_REP_2015-003-B15-Radio_Australia_presentation.pptx Appendix 3

Source: ABC presentation to the High Frequency Coordination Conference (HFCC), 2015 http://www.hfcc.org/doc/HFCC_REP_2015-003-B15-Radio_Australia_presentation.pptx