WWDA Submissionto the Regional Telecommunications Inquiry


In mid 2002, the Australian Government announced a Public Inquiry into the adequacy of telecommunications services in rural, regional and remote Australia. This is WWDA’s submission to that Public Inquiry. The Submission was prepared by Sue Salthouse and members of WWDA’s Telecommunications Working Party. Copyright WWDA 2002.


Summary

WWDA believes that considerable improvements still need to be made in many aspects of Telstra services in remote, rural and regional Australia.

It further believes that these improvements must be completed before the Government changes it relationship with Telstra. The criterion that a demonstration of ongoing improvement with various initiatives within a reasonable timeframe IS NOT SUFFICIENT. The initiatives should be complete.

WWDA further believes that consideration of safeguards for women with disabilities (and all people with disabilities) have been ignored. This needs to be rectified, and adequate safeguards put in place to guarantee essential telecommunications services for people with disabilities. This applies especially to those in low income groups.

WWDA believes that Telstra has an unequal competitive advantage with respect to other carriers. The Government must also consider how to address this inequity.

WWDA believes that other carriers should only be endorsed when their conditions of operation, especially with respect to their obligation to people with disabilities, are the same as applied to Telstra.


About Women With Disabilities Australia (WWDA)

Women With Disabilities Australia (WWDA) is the peak organisation for women with all types of disabilities in Australia. WWDA was established in 1994, and became incorporated in 1995. It is a federating body of individuals and networks in each State and Territory of Australia and is made up of women with disabilities and associated organisations. The national secretariat is located in Tasmania. WWDA is run by women with disabilities, for women with disabilities. It is the only organisation of its kind in Australia and one of only a very small number internationally.

WWDA is inclusive and does not discriminate against any disability. WWDA seeks to ensure opportunities in all walks of life for all women with disabilities. In this it aims to increase awareness of, and address issues faced by, women with disabilities in the community.

WWDA seeks to ensure the advancement of education of society to the status and needs of women with disabilities in order to promote equity, reduce suffering, poverty, discrimination and exploitation of women with disabilities. WWDA is unique, in that it operates as a national disability organisation; a national women’s organisation; and a national human rights organisation.

WWDA is a national voice for the needs and rights of women with disabilities and a national force to improve the lives and life chances of women with disabilities.

The objectives of the Association are:
(a) to actively promote the participation of women with disabilities in all aspects of social, economic, political and cultural life;
(b) to advocate on issues of concern to women with disabilities in Australia; and
(c) to seek to be the national representative organisation for women with disabilities in Australia by:

  • (i) undertaking systemic advocacy;
  • (ii) providing policy advice;
  • (iii) undertaking research; and
  • (iv) providing support, information and education.

WWDA is managed by a National Executive Committee, which is made up of women with disabilities and which is elected each year at the Annual General Meeting. The members of WWDA are actively involved in the decision making processes of the organisation. All programs and activities conducted by WWDA are in direct response to the identified issues and concerns of women with disabilities in Australia.

WWDA is at the forefront of support and advocacy, with, and on behalf of, women with disabilities in Australia, both individually and collectively. WWDA’s major roles, functions, and activities include (but are not restricted to):

  • Provision of direct practical assistance and advocacy to individual women with disabilities;
  • Provision of systemic advocacy for women with disabilities collectively;
  • Research and policy development;
  • Project development and implementation;
  • Addressing the issue of empowerment and women with disabilities, both individually and collectively;
  • Quality Improvement

Disparities affecting women with disabilities

At present, the Australian Bureau of Statistics estimates that people with disabilities constitute just over 19% of the population. Women with disabilities (wwd) make up slightly more than half of the population of people with disabilities in Australia.

Within this sector, wwd are half as likely as their male counterparts to complete secondary education. They are less likely to be in paid employment than other women, men with disabilities or the population as a whole. Even if they find employment, 51% of wwd earn less than $200 per week, compared to 36% of males with disabilities. Only 16% of wwd earn over $400 per week, compared to 33% of men with disabilities.

Unfortunately, wwd are also more likely to be subjected to physical, emotional and sexual violence than their male counterparts, other women or the general population. In addition, they are more likely to be institutionalised.

Thus wwd are more likely to be socially and economically isolated than men with disabilities.

Development in Information and Communication Technologies (ICT) should offer wwd release from their social isolation and open pathways for education, training and employment. However, their economic situation precludes many from taking advantage of ICT. Women with disabilities have been recognized as a target disadvantaged group, which needs pro-active assistance to bridge the Digital Divide.(1)

In 1999, WWDA undertook a study of telecommunications use by women with disabilities in Australia (2). In this study, it was found that wwd placed a high value on the standard phone as a means of maintaining links with family and friends. They placed an extremely high value on having access to the Internet. However, only 34% of respondents had such access. Those who did, used it for contacting family and friends (26% of total reasons given), for research and distance education (22%), to find employment (17%), e-commerce (10%), and a myriad of other uses (25%).

A follow-up survey of remote, rural and regional wwd was undertaken in 2001. The report of this survey (3) forms the basis of information for this submission. It has been supplemented with information submitted during the past 2 weeks from constituents who subscribe to ‘wwda-discuss’ online discussion list.


WWDA Telecommunications Group

In is important for the ICT needs of wwd to be brought to the attention of policy makers and corporations involved in ICT. In 1999 WWDA was supported by a grant from the Department of Communications, Information Technology and the Arts (DCITA), to enable members to be representatives on a number of telecommunications advisory bodies.

WWDA’s continues to be supported by the Commonwealth through the Telecommunications Consumer Representation Grant program of DCITA. The WWDA members who undertake this work form the WWDA Telecommunications Group. At present the Group has 8 members.

WWDA currently has a representative on each of the following:

  • Australian Communication Industry Forum (ACIF) Consumer Advisory Group, and
  • ACIF Disability Advisory Board;
  • Telstra Disability Forum, and
  • Telstra Disability Equipment Program Consumer Advisory Group;
  • Telecommunications Disability Consumers Representation (TEDICORE) Group.

Three Group members undertake this representation. In addition, 3 members have been involved in research into Digital Divide initiatives, and a fourth is undertaking research into the role ICT plays in the development of virtual communities used by wwd.


Response to Terms of Reference

4.1 Extent of improvements following Telecommunication Service Inquiry

4.1.1 Reliability of Basic Telephone Services (TOR 2)
Women with disabilities in rural, remote and regional Australia (the target area) do not place great faith in the reliability of basic telephone services. Anecdotal evidence in the WWDA 2001 survey was that quality of services fluctuated according to weather conditions and the amount of water saturation in soil in the area of cables.

Despite the fact that the Besley Inquiry considered that regional centres had reasonable access to telephone services, this is not the opinion of wwd living in these centres. (Fifty percent of respondents to the WWDA 2001 survey lived in regional centres.)

For wwd, the basic telephone service often needs to be augmented by the addition of assistive equipment. In the target areas it is felt that access to any assistive equipment is poor and has worsened since 2000.

The Telstra Shopfront in Darwin holds very little assistive equipment available under the Telstra Disability Equipment Program (DEP) for demonstrating to clients. The Telecommunications Group representative in that city feels that staff there has very little knowledge of disabilities, or the likely needs for equipment which people with disabilities may require. Nor do they show interest in solving the problems of people with disabilities.

It is sobering to contemplate how much more difficult it is for wwd away from a regional centre to obtain information, help or equipment.

This diminution of service offered to people with disabilities at Telstra Shopfronts is declining in both the target and metropolitan areas, as more shopfronts are privatised to franchisees.

It is extremely important that a viable, functional DEP be maintained for wwd in both the target and metropolitan areas.


4.1.2 Timely Repair of Services (TOR 1 and 2)
Women with disabilities in the target area feel that service repair is not timely. The instigation of the Priority Assistance Service (PAS) in mid-September 2002 is important. It will be essential for the Government to guarantee that such a service is maintained.

WWDA would like to register its great concern that the PAS has been set up with no formal arrangement in place outlining Telstra’s obligations when they are the secondary carrier of a service.

The primary carrier may not have a mechanism in place to respond to a request for PAS registration (4). WWDA has not seen any statement of the time frame allowable for passing information about faults from the primary carrier to Telstra.

If Telstra is to remain responsible for telecommunications infrastructure, it is essential that these links be formalised, and that the time taken to pass information from primary to secondary carrier (ie. Telstra) be virtually simultaneous. WWDA is alarmed that there is no clear agenda as to who would own, repair the phone service infrastructure if Telstra were to be privatised.

WWDA also registers its concern that the Interim Telephone Service supplied where necessary (satellite phone of CDMA mobile) may not be useable by people with particular disabilities, or compatible with their assistive equipment.


4.1.3 Reliability of basic telephone services (TOR 2)
Respondents to the 2001 survey reported unreliability of their basic telephone service, with ‘outages’ occurring after high rain, in high wind and with lightning strikes.

In some areas, eg. the mid North coast of NSW, frequent lightning strikes make the basic telephone service unreliable. Yet measures to counteract this frequent climatic occurrence in this region have not been put in place.

In addition, some rural areas experience too-frequent ‘drop-outs’, which necessitate re-dialling. These inflate the call costs of the basic telephone service. This adds to the disadvantage experienced by subscribers in the target area. This poor service may result from the inadequate (single copper wire) landline connections.

A WWDA contributor to this submission, from the Upper Murray area, reports that the phone service remains poor, with time delay, echoes and noise on the line. The time delay lengthens the time of STD calls, which are therefore costly in time and dollars.

In addition, ‘local calls’ in area (eg. from Corryong to Cudgewa, Nariel and similar) are charged at metered rates, again increasing overall cost of the basic phone service.

WWDA reiterates that it is essential for local call zones to continue to be established in all rural areas.

Some residents of rural areas have attempted to overcome inadequacies of the basic telephone service by purchasing satellite phones. These are too costly for most wwd to buy, and have the difficulties of incompatibility with assistive equipment alluded to in the section above.

WWDA registers its concern that ‘reliable basic telephone service’ is a subjective term, and the Government could deem a service to conform to this recommendation, whilst the user deems its ‘reliability’ to be inadequate.

WWDA registers its concern that the only recommendations from the Besley Inquiry which are under consideration are those affecting delivery of services to rural Australia. Services in metropolitan areas leave much to be desired.

A member of the WWDA Telecommunications Group in Canberra reports that a basic telephone service was not repaired for 22 days. There was only one interim contact from Telstra and no explanation as to the reason for the outage, or the likely length of time to repair. There had been no further contact, during the outage. The Customer Service Guarantee/Charter (CSG/C) in metropolitan areas is to repair a fault within one working day of the report of a fault.

A CDMA mobile phone was supplied as an Interim Telephone Service. It arrived with instructions on how to install a satellite phone away from possible electromagnetic interference! There was no facility for diversion to an answering service.

There was no explanation about how calls would be charged using a mobile phone as the Interim Telephone Service; no contact from the primary carrier at all after the phone was reported out of order; after 5 days the offer of Interim Telephone Service came from Telstra.

As the phone serviced a business, the losses were potentially high.

This example is included to demonstrate the inadequacy of basic telephone services in metropolitan areas.

The installation of basic telephone services must be made at a reasonable price.


4.1.4 Reliability of public payphone service (TOR 2)
The provision of adequate, accessible public payphones in target areas (and metropolitan) Australia is essential.

WWDA registers its concern that this has not been considered as a criterion for assessment of Telstra’s delivery of adequate services in the target area.

In general, public payphones are not accessible to people with disabilities. Their design needs improvement. The time taken for their repair is long. In addition, the provision of TTY public payphones is inadequate, particularly in target areas. The time taken for their repair is often protracted.

The WWDA Telecommunications Group representative in Darwin has been monitoring the maintenance of the public payphones in that city for some years. It is her opinion that maintenance levels are deteriorating.

The WWDA member in Toowong Shire has already approached the Telstra Disability Services Manager and the Minister for DCITA about inaccessibility, poor positioning and poor maintenance of public payphones in the Shire. This submission can be made available to the Inquiry on request.

WWDA registers it concern that public payphones be judiciously installed, be accessible for people with disabilities and be maintained in an efficient and timely manner.

WWDA believes that the installation of public payphones in indigenous communities must be completed.


4.1.5 Assistive Equipment (TOR 2)
The Disability Equipment Program needs to be adequately serviced in rural areas.

  • people with disabilities need to have accessible DEP outlets within a reasonable distance from their home;
  • a range of assistive equipment needs to be on display;
  • staff need to be trained in the functioning of the equipment;
  • staff need to have basic understanding of the needs of particular disabilities; and
  • where repairs have to undertaken in regional centres or capital cities, substitute equipment needs to be available on loan.

4.1.6 Adequate mobile coverage at affordable prices
In rural areas, for the 2001 WWDA Survey, wwd cited poor mobile coverage and unreliable service.

A reliable mobile phone service is essential for people with disabilities, as it is relied on as a device to contact help in time of emergency.

This is especially relevant in rural areas, where it will not be possible to rouse a neighbour. For people on low income, the cost of maintaining a mobile phone is prohibitive, and the basic telephone service must be relied on. In both cases, reliability of service is essential.

A WWDA member at Elands, on the mid North coast of New South Wales, reports that the area is out of mobile range.

In the Upper Murray, there are many ‘black spots’. It seems that antennae have been badly positioned. Other carriers have poorer coverage than Telstra.

This last observation highlights an anomaly which is not being addressed in the current inquiry or by the Government.

When Government funding is used to upgrade the services which Telstra provides, it gives Telstra a competitive advantage which may never be recouped by other carriers.

Conversely, other carriers have been allowed to enter into areas of service delivery without the same conditions being applied as for Telstra.


4.1.7 Reliable Access to the Internet (TOR 3)
In the 2001 WWDA Survey, 50% of respondents said that use of the Internet was ‘extremely important’ to them. A further 15% valued the Internet as ‘quite important’. Respondents reported that the cost of using the Internet was high. In many areas connection costs were charged at STD rates.

Government and Telstra undertakings in relation to the internet need to be completed. These include:

  • the delivery of a minimum of 19.2 kilobyte per second modem connection speed throughout Australia needs to be completed; and
  • the introduction of Telstra Bigpond Home (to enable Internet connection costs to be achieved for the cost of a local call) needs to be completed.

Fluctuating power supply can be a danger to, and affect the performance of equipment. This means that robust expensive safeguards need to be installed.

Downloads in many areas continue to be slow and drop-out of Internet connections are frequent. Many respondents to the 2001 WWDA survey said that broadband access would have offered a better product for Internet connection.

On the mid North coast of NSW, connection to the Internet is still charged at STD rates, download speed is slow. Both these factors contribute to high costs for use of the Internet. The area is not remote, is close to high population centres, and access to it is not difficult.


4.1.8 Legislated Safeguards (TOR 4)
WWDA believes that the Universal Service Obligation (USO) and CSG/C are no longer protecting the interests of consumers in regional Australia. This has occurred because other carriers have been allowed to enter the field without the safeguards being in place.

Other carriers do not have Disability Action Plans (with the exception of Optus). Nor do they have DEP’s. Without these, there is no pro-active assistance given to wwd. There is no training of staff to deal with people with disabilities, no training about assistive equipment available; no training in how to use such equipment, etc. All this means that the assistance other carriers can give to people with disabilities is limited.

In turn, this means that people with disabilities have little choice as to the carrier they can use.


4.1.9 Telecommunications Industry Ombudsman (TOR 4)
WWDA believes that an established complaints mechanism needs to be maintained.


4.2 Comparative Performance of Telstra, rural vs metropolitan

WWDA asserts that the performance of Telstra, in all its services, is worse in rural areas than in metropolitan areas. However, its performance is not good in either area.

  • With the PAS, the repair time guarantee for the target areas is double that for the metropolitan area, even though faster repair is more needed in the former. This is because the lead time for emergency vehicles to arrive at a rural location is greater too;
  • Mobile coverage is lower in rural areas, and dropouts are more frequent;
  • The establishment of local call zones has meant a small gain toward parity with the cost of a basic telephone service in metropolitan areas. Where local call zones exclude the local regional centre, the gain has been miniscule (this needs to be completed); and
  • The cost of basic phone/fax/Internet per month for one WWDA member in Alice Springs is $150-$180 per month.

4.2.1 Local Presence (TOR 5)
Local presence is extremely important for wwd.

As outlined elsewhere in this submission, having access to assistive equipment in a Disability Equipment Program is of utmost importance if the telecommunications system is to function optimally for a person with a disability. Any facility which houses assistive equipment must be staffed by people competent in its use and with some knowledge of disabilities and how to interact with people with disabilities.

Local presence is important for all carriers.

Ongoing commitment to running the local presence/s must be met by the corporations, either individually or cooperatively, and the costs incurred should be spread across all subscribers rather than attributed to the actual area where the facility is located.

Alternatively, use could be made of existing community/health services, where the corporations supplied the equipment, and supported the appropriate training of staff.


4.2.2 Sharing in future telecommunications benefits (TOR 6)
WWDA believes that there should equitable distribution of costs of ICT services across both metropolitan and rural/regional Australia. It further believes that future telecommunications developments should be shared equitably across all sectors of the community, and that disadvantaged groups should be subsidised, where necessary.

WWDA believes that the Government should regulate all carriers in all areas (both rural and metropolitan) to deliver an equitable service. WWDA believes that costs should be distributed so that the high population centres can subsidise the cost of providing services to areas of low population density.

WWDA believes that there should be a regular review process of all service levels and initiatives. This should apply to all carriers. The mechanism for doing this can be imbedded in licence conditions, CSG/C, and Service Obligations which should apply to all carriers.

WWDA believes that new initiatives and developments in ICT should be made available to rural/regional Australia according to predetermined feasibility/economic guidelines stipulated by the Government.

WWDA believes that subsidies should be considered to promote environmentally sustainable technologies, eg. solar powered public phones. It is also important that subsidies be available for the purchase of assistive equipment which will enable women with disabilities equitable access to ICT.

WWDA believes that positive action should be taken to provide environmentally sustainable telecommunications technologies to indigenous communities.


4.3 Continuance of Safeguards

WWDA reiterates that it is essential that initiatives, instigated in response to the recommendations of the Besley Inquiry, is delivered in both rural and metropolitan areas.

WWDA believes that the special needs of women with disabilities (and all people with disabilities) should be a primary consideration about changes to telephone services, and to telephone charges. Women with disabilities have a higher reliance on telecommunications than other sectors of the community. Moreover, they have a higher likelihood of being economically disadvantaged, so that concessional rates are justifiable.

  • removal of a basic telephone service, when an unrelated Telstra product account is unpaid or overdue, must not be allowed, especially for people with disabilities;
  • even where ‘bundling’ of an account has been done, removal of the basic telephone service when the account is unpaid or overdue, must not be allowed, especially for people with disabilities;
  • application of rules with respect to delivery of services, or their removal where accounts are unpaid or overdue, must not be done without consideration of the circumstances of the person using the service, eg. a person in terminal stages of an illness should not have a phone service terminated;
  • the DEP must be maintained or expanded, not reduced in the type/volume of equipment it supplies. The need for assistive equipment will rise as the percentage of aged people in the population rises. The incidence of disability rises with increasing age;
  • staff must have training with DEP equipment, and in the needs of people with disabilities;
  • rent charges must be kept at reasonable levels, especially for people with disabilities on low income;
  • the PAS service must be maintained and monitored for improvement;
  • the ‘000’ – ‘no response’ service must be maintained and monitored for improvement;
  • sharing of transmission towers by other carriers should be considered, to minimise the environmental impact of numerous towers, and to enable competitive services for other carriers, particularly in rural areas;
  • the set up of local call zone areas needs to be continued and improved;
  • cost equity between rural and metropolitan services needs to be achieved;
  • the provision of untimed local calls needs to be guaranteed.

WWDA believes that actions initiated in target areas in response to the Besley Inquiry should be complete, and not ‘in train’, before any changes to Telstra’s operation are considered by Government.


4.4 Ensuring Equitable Access

When Government funding is used to upgrade the services which Telstra provides, it gives Telstra a competitive advantage which may never be recouped by other carriers.

Conversely, other carriers have been allowed to enter into areas of service delivery without the same conditions being applied as for Telstra.

In target areas, for wwd to obtain eligibility to the DEP requires a visit to a doctor for verification of a need. This may entail a visit to a regional centre, which can be time-consuming and costly.

Now, an almost identical certification will be needed to register for the PAS.

WWDA believes there are few assurances of equitable access in place at present. Steps must be taken to rectify this situation.


Conclusion

WWDA believes that considerable improvements still need to be made in many aspects of Telstra services in remote, rural and regional Australia.

It further believes that these improvements must be completed before the Government changes it relationship with Telstra. The criterion that a demonstration of ongoing improvement with various initiatives within a reasonable timeframe IS NOT SUFFICIENT. The initiatives should be complete.

WWDA further believes that consideration of safeguards for women with disabilities (and all people with disabilities) have been ignored. This needs to be rectified, and adequate safeguards put in place to guarantee essential telecommunications services for people with disabilities. This applies especially to those in low income groups.

WWDA believes that Telstra has an unequal competitive advantage with respect to other carriers. The Government must also consider how to address this inequity.

WWDA believes that other carriers should only be endorsed when their conditions of operation, especially with respect to their obligation to people with disabilities, are the same as applied to Telstra.


Endnotes

(1) Digital Divide is a term coined to describe the inequity, or gap, which separates disadvantaged groups from the rest of the population in their ability to gain access to ICT.

(2) “Telecommunications and Women with Disabilities”, WWDA May 1999.

(3) “Telecommunications Use by Women with Disabilities in remote, rural and regional Australia”, WWDA July 2001.

(4) WWDA is also concerned that other carriers have been allowed to begin operation without licence conditions identical to those of Telstra.