ICPA QLD - Public Submission RTIRC 2015

2015 Regional Telecommunications Review

2015 Regional Telecommunications Review Secretariat Department of Communications GPO Box 2154 CANBERRA ACT 260

SUBMISSION

Submission made on behalf of:

Isolated Children’s Parents’ Association Queensland Inc. (ICPA Qld Inc.)

Contact Details:

Secretary ICPA Qld Inc. Mrs Kate Twist

This submission contains no material supplied in confidence and may be placed on the 2015 Regional Telecommunications Review website

The Isolated Children’s Parents’ Association Queensland Inc. (ICPA Qld Inc.) represents the interests of over 1200 rural and remote Queensland families. It consists of forty-six branches throughout remote and regional Queensland. ICPA Qld Inc. seeks to gain equitable access to educational opportunities for isolated children.

Member families may live in rural, regional or remote towns and have access to Preparatory to Year 6/10/12 schools and a variety of early childhood education and care facilities depending on the 2015 Regional Telecommunications Review Submission population. Isolated families may have no daily access to educational services and enrol their school-aged children in Schools of Distance Education or make arrangements which require their children to live away from home to access appropriate schooling.

ICPA Qld Inc. would like to comment on the questions posed in the Regional Telecommunications Review issues paper, and have also included two attachments:

(1) Member’s comments and case studies

(2) The ICPA Qld Inc. Telecommunications Position Paper

As an overview, ICPA Qld Inc. is extremely concerned with both the state of our existing telecommunications systems, and the possibility of further problems with services due to lack of adequate capacity and insufficient future planning.

Over the last couple of months, many members who use satellite internet have commented on the significant decrease in their internet data speeds. This frustrating situation has coincided with the release of internet-streamed movie programs such as Netflix, and is demonstrating the inadequacy of the current satellite systems. The progression and widespread adoption of on-line technologies is utilising more bandwidth than ever before.

Sadly this progression is not only by-passing those students who study via Distance Education, it is further minimising their already very limited access to the internet. The significant decrease in internet data speeds is exacerbating issues with what is already an overloaded system which cannot cope with the demands of modern on-line technologies. Geographically isolated families who struggle to educate their children in 21st Century are being further marginalised and their children’s education further compromised.

Comments by the Parliamentary Secretary for Communications, Mr Paul Fletcher, indicate acknowledgement by the Federal Government of the very real potential for congestion issues with the NBN Long Term Satellite Solution (LTSS). While this will be addressed to some extent by controlling the size and price of download plans to limit data usage, the provision of education via the internet to rural and remote students must not be compromised. Given the rapid escalation of data usage with the emergence of new technologies, if the system is inadequate upon commencement, on-going issues over the life of these satellites seem assured.

There have been indications that The Federal Department of Communications is considering using NBN LTSS and Wireless infrastructure to provide USO (Universal Service Obligation) fixed telephones in areas which the Department terms Legacy USO areas. The implications of such a move certainly causes concerns.

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?

Submission compiled by

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission

Residents of regional Australia have a far greater reliance on telecommunications than those in urban areas due to the following points:

1. Many students are dependent on distance education due to the lack of reasonable daily access to “conventional” schools. Telecommunications are vital for all distance education delivery, from early childhood programs such as e-kindy through to external tertiary education services.

2. Service delivery by “face-to-face” means is often not available in regional, remote and isolated areas. Where adequate data speeds and capacity are available, such support as speech-language pathology services can be made available via digital means. During the 2014 ICPA Queensland State Conference several motions were carried asking for trials of web-based delivery of speech-language pathology services. While obviously totally dependent on access to reasonable data speeds, a Queensland trial delivering speech- language pathology services on a web-based platform is well underway. Currently there are seven rural and remote schools participating with thirteen students receiving support through a telepractice platform. A total of thirty-eight sessions had been provided through Education Queensland’s iConnect or through Queensland Health’s telehealth facility by mid- June.

3. Early Childhood education in Queensland has undergone rapid change in recent years. Participation in educational programs in the year prior to prep has tripled since 2009, although “universal access” goals are still not achievable in many remote and isolated districts. Where population densities preclude standard models of service delivery, distance education based e-kindy is often the only alternative.

4. Social contact is normally limited due to the tyranny of distance. Telecommunications services are vital in helping overcome the debilitating effects of isolation. Times of hardship can be compounded during extreme seasonal weather conditions.

5. Safety is dependent on telecommunications services when isolation and distance from medical assistance are a reality. The ability to report an emergency in a timely manner can mean the difference between life and death. During, and for some days following wet weather events, poor infrastructure often prevents travel for many regional residents which further exacerbates the safety of life issue.

6. For effective functioning of business, regional residents must be connected to robust and reliable telecommunications systems. While urban businesses have the benefits of proximity to banks, suppliers and customers, many regional businesses do not.

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission Q2. For those users already connected to an nbn network service, has the service met your expectations?

Feedback from members of ICPA Qld Inc. has only been regarding the nbn interim satellite service (nbn iss). This has been most unsatisfactory, with service delivery falling far short of promised speeds. Data plans have been reduced, without a comparable cost reduction. Data speeds have slowed significantly, with some members reporting the inability to do such activities as internet banking due to poor performance. It must be remembered many regional residents have only the one internet system for all of their education, social and business needs, while urban users would typically have an internet service at their workplace for business separate from their home/social internet service all of which have much greater usage allowances at a much lower cost per GB.

Many members have reported inability to download required distance education content, particularly where there are several students at the one premises. Lack of data capacity in current plans consistently results in consumers exceeding their monthly data allowance whilst participating in distance education.

An additional education internet allowance sufficient for the needs of all students studying via distance education is imperative. This allowance must be allocated in conjunction with any other data plan.

Recent changes, where internet service providers are suspending rather than shaping some services, show no regard for education service delivery.

Satellite service consumers normally have no other access to data downloads, such as wireless hot spots or via mobile phones. Due to isolation they generally rely on the internet for communication at a far greater level than their urban counterparts

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?

ICPA Qld Inc. has members throughout the state. Please refer to our attached Telecommunications Position Paper.

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?

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?

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission Access to the internet with reasonable data capacity and speeds is essential in modern society. Given both the inadequacy (i.e. restricted data allowance) of the proposed satellite system to meet current and suppressed demand for data transfer, and the trends in the growth of this demand, an expansion of the mobile telephone network is essential. Technologies such as 4GX will allow the transfer of consumers away from the satellite network, which will assist in relieving congestion on the satellite network.

Provision of mobile service is extremely important to enhance safety. Many of the areas outside of the mobile footprint are also quite isolated from other services, and subject to greater impacts from weather events due to poor road infrastructure.

Q6. Not applicable.

Q7. Not applicable.

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

Australians who live and work within the coverage area of mobile networks have become accustomed to a vast range of benefits with the ability to access services, greater social interaction, a whole range of increased business opportunities and a vastly strengthened mantle of safety. Lack of these services is a barrier to attracting and retaining young people to the 70% of this nation that does not have mobile telephone coverage. This lack of coverage compromises the prospects for business expansion and employment opportunities.

The future direction of service delivery in many fields is focused on mobile devices and apps. If rural and remote regions are to avert a social tragedy caused by rapidly declining populations, equitable and affordable mobile telecommunication service provision is absolutely essential.

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?

Many ICPA Qld Inc. members on the nbn iss have reported extremely slow speeds as well as capped plans (e.g. 20GB peak usage). These restrictions are extremely problematic for those operating a business in a regional, rural or remote area. Many outback residents use online bookkeeping programs (e.g. MYOB AccountRight or Phoenix Live) to ensure streamlined accounting practices and adequate records are kept. Slow data speeds and limited plans are making this online option impossible for many. Face to face communication with metropolitan based accountants is periodic at best.

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission Internet banking is also not available for many due to timeouts caused by slow speeds. The need to wait for off-peak usage periods is extremely unproductive and has major implications on the cash flow of a business as well as the relationships with creditors.

Poor telecommunications limits the potential to diversify into off farm enterprises. It is also a major deterrent to the adaptation and utilisation of new high tech farming and agricultural innovations. In a nutshell, it severely limits industry growth.

Families who access their schooling via distance education are greatly affected by telecommunication issues. Due to slow speeds and capped plans for those on satellite internet, downloading curriculum materials is lengthy and costly. Class lessons are reliant on the web conferencing program iConnect and members report constant drop outs and the inability to log on to the program. The majority of school lessons are at peak times. Many students are unable to use the webcam feature on iConnect to communicate with their teacher due to the high upload/download data requirements. Some students are also reliant on the telephone for voice during these class lessons and can therefore not participate if the phone is out.

For students requiring allied health therapy (e.g. speech language pathology), platforms like telehealth, iConnect and Skype are becoming more accessible where face to face contact with a therapist is not possible. Optimal data speeds are necessary for online therapy. Many members are hundreds of kilometres away from a high speed, reliable data connection and therefore are unable to utilise this service.

Residents who are reliant on radio based telephone services (High Capacity Radio Concentrator) are reporting telephone outages for extended periods of time due to equipment faults and lengthy repair times. Many of these same residents have no access to mobile telephone services. Therefore landline telephones are critical for business, education and health. Many of these outages happen in the wet season when it is difficult for technicians to access the site due to impassable unsealed roads. It is at this time that residents would be at their most vulnerable if a medical emergency was to occur.

At present there is no way personally to overcome these communication barriers for those affected other than to work within the limitations of the internet and telephone services available. The disadvantage this places on business operation as well as health and education must be addressed. Population in small communities is on the decline. Poor telecommunications is a significant deterrent to entry into the regions at all, especially for the younger generation who have high technological expectations. An internet service which is so far removed from anything that would be acceptable in urban areas, coupled by lengthy telephone outages, make the standard of living in many of these outback areas exponentially incomparable.

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission Q10. What communication functions (for example, speed, mobility, reliability, data, etch) would best suit your needs, noting the limitations of each technology (for example, mobile, wireless, satellite, fibre)?

Both voice and data communication systems need to be reliable, affordable and mobile. The capacity of these systems should not restrict education, business, safety, or social needs.

Development of new technologies is extremely focused on residents who have communication services that meet all of the above criteria. Mobile apps now exist for numerous uses, and offer speed, convenience and affordability that has resulted in virtually universal adoption by those within the wireless footprint.

The needs of residents outside of this service area are not well met, as service providers often do not appear to consider the needs of this minority; e.g. some government forms can only be completed on line. People reliant on data delivery via satellite often do not have the capacity to download, complete and return these forms, and there is no option to print and mail them. With the ever increasing global push to become a paperless society, this demographic is being left behind.

With the limited capacity and latency problems of satellite systems, these should only be considered as a solution of last resort. The recent announcement of 499 extra base stations nationally through the Australian Government’s Mobile Black Spot Program is commendable, but needs further expansion.

Technology utilised with the nbn ltss has not been adopted previously with Australian environmental conditions. The use of much higher link frequencies in the nbn ltss compared to existing Internet Satellites has the potential for users to experience a greater number of weather disruptions. Existing satellite systems already have a poor record in this area. North American experiences report outage times of up to ten days per annum, which causes concerns.

Many next G towers urgently require upgrading to ameliorate congestion problems and allow for unrestricted data plans. Consumers do not have choice of carrier, having no option other than expensive Telstra plans for internet. Next G fixed telephone services currently do not enjoy the protection of the Universal Service Obligation (USO). Given recent changes to the USO legislation, these services should now be supported by this mandate, as the impediment (having the ability to choose a carrier) has been removed.

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

Reliable telecommunications are absolutely critical for safety, education, business and social use. Without an on-going service guarantee, many regional subscribers would experience exacerbated outage times that would negatively impact on the above-mentioned issues. The right of Australians to have a telephone connection is worth little if that service is not reliably maintained within set

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission time frames. Australians who do not reside within mobile coverage areas should be the highest priority for fault rectification. While other forms of communications are not underpinned by a Universal Service Obligation guarantee, standard telephone services must remain within mandated repair times. Reliable communication is absolutely vital.

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

Education delivery in the modern era is critically dependant on the availability of a reliable internet service with sufficient speed and data capacity for both lesson delivery and participation. Given the lack of accessible service delivery via face-to-face means, digital service delivery should be underpinned by a Universal Service Obligation type guarantee. Governments throughout Australia are encouraging digital communication, investing in web-based service delivery for health, education and numerous other fields. Many consumers have retained a dial-up internet account as a safeguard, even though HCRC telephone systems have extremely poor data speeds.

Telstra has revealed plans to cut off the dial-up internet services of its consumer customers by the end of the year. Stuart Bird, director of fixed broadband and bundles at the telco, announced the plans in a blog entry on the Telstra website.

“With the expanded availability of ADSL/ADSL2/VDSL, cable, fibre, wireless and satellite broadband solutions, including over the National Broadband Network, and the continued decline in the use of dial-up, we have decided to retire dial-up internet services for the small number of our consumer customers who still have them,” Bird wrote. These services will be retired by December 2015, he said.

Given the very high dependence and total reliance on a single mode of data delivery, guaranteed repair times and minimum standards are essential for digital service delivery.

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

Equitable standards of services should exist for all Australians, irrespective of their location. Telephone service reliability has deteriorated in many remote or isolated regions. Another area of concern is the increasing use of Mass Service Disruption (MSD) notices by Telstra. The use of MSD’s removes the requirement for Telstra to meet the service restoration targets set by the Customer Service Guarantee (CSG) scheme and removes the rights of customers to claim CSG payments.

The original intention was for MSD’s to cover major weather / disaster events. However, the telephone network has been allowed to fall into a state of disrepair. MSD’s have been increasingly used for what would have previously been considered a normal event that required Telstra to meet the service restoration targets set by the CSG (Customer Service Guarantee) scheme.

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer 2015 Regional Telecommunications Review Submission Regulation and enforcement of the Universal Service Obligation Customer Service Guarantee should be enhanced to ensure prompt repairs of disrupted services.

Historically many internet service providers have sold contracts promising data speeds that have not been consistently or reliably achieved. There appears to be little regulation of the industry to ensure service providers deliver their end of what is a contractual arrangement. However, consumers are still expected to pay for a level of service they are not receiving. Competition has failed to address this problem and a pro-active regulatory authority should enforce consumer safeguards.

ICPA Qld Inc. appreciates the opportunity to participate in this review. Equity of Access to Education for all Students who live in Rural and Remote Australia can only be enhanced by recognition of, and amelioration of, the barriers caused by lack of appropriate access to 21st Century communication systems.

Andrew Pegler (State President ICPA Queensland Inc.) in conjunction with: Members of ICPA Queensland Council Jeffrey Little – ICPA Queensland Inc. Information Communication Technology Advisor Kylie Camp – ICPA Queensland Inc. Portfolio Research Officer