1. Introduction

Background

Australia’s digital transformation and mobile service demand

1.1Digitalisation has enabled data to be collected, transferred, and analysed, and goods and services delivered at rapid speed and at historically low cost. It has also enabled convenient access to e-commerce; e-health; entertainment; socialising; smart-home control and remote links to workplaces and government services. These activities are now occurring more frequently via mobile devices.

1.2The world’s digital and data transformation surged ahead during the global pandemic, laying the foundations for future disrupting technologies and potential productivity gains and economic prosperity. However, evidence to this inquiry and conclusions in the Productivity Commission’s March 2023 report, 5-year Productivity Inquiry: Australia’s data and digital dividend highlighted that there are factors in Australia which may inhibit these gains, some of which may be offset through Government intervention.[1] Of significance, ‘inadequate internet’ was cited as a key factor which could limit business uptake of new technologies[2]; and this impediment is particularly salient in regional Australia. The Commission’s report stresses that:

Digital infrastructure, particularly in regional and remote Australia, is required to deliver productivity-enhancing access to low-cost and reliable internet for local businesses and workers, and increases social inclusion by ensuring that regional and remote Australians can access quality essential services and expertise that are increasingly available online.[3]

1.3The demand for mobile connectivity has continued to grow in line with the acceleration of on-line news, e-commerce, e-service delivery and interaction with government. However, demand for mobile services is not being met in rural, regional and remote parts of the country.

Mobile coverage and connectivity in regional Australia

1.4There are various drivers of mobile connectivity demand. Significantly, reduced entry level cost of mobile devices and service charges, the rise of digital identification and wallets, and, particularly since the Covid-19 pandemic, increased digital consumption in both private and public spheres.[4] Workers are now more mobile and people who relocated from cities to regional and rural areas during the pandemic demand improved non-urban mobile coverage and connectivity.

1.5Mobile connectivity is generally very good in metropolitan and bigger regional towns because there is plenty of commercial opportunity for carriers to profit from large customer bases. Consequently, Australians living and working in built-up areas have greater mobile carrier choice. Sparsely populated areas of the country offer riskier commercial environments and carriers therefore require incentives to offer services.

1.6Mobile coverage is an issue for those living in non-urban areas as well as mobile customers in peri-urban locales and urban customers who travel beyond built-up centres. Service congestion at peak periods or holiday seasons can impact access to workplaces, business data and transactions, and emergency services. This in turn impedes the growth of rural and remote regional economies.

1.7The Committee heard of the economic importance of connectivity for local councils to deliver services and to support tourism and the need for remote rural farms to attract labour and have technological functionality.[5]

1.8Evidence from remote First Nations Australian communities highlights the inequality in coverage and connectivity across Australia.[6] This particularly affects safety, health, education and connection in First Nations homelands experiencing a digital gap.[7] Closing the Gap on digital inclusion is critical to First Nations people as highlighted in Target 17 of the 2023 Closing the Gap Implementation Plan: that by 2026, Aboriginal and Torres Strait Islander Australians will have equal levels of digital inclusion.[8]

1.9Expanding mobile coverage and competition in regional, rural and remote Australia is an ongoing objective of Australian Government policy and programs. The 2022 federal budget ‘committed $400 million to further expand mobile coverage and improve resilience in regional Australia’.[9]

1.10Australians in regional and remote locations wish to access reliable and continuous mobile connectivity but face market impediments to service delivery owing largely to the relatively small number of consumers spread over a vast land mass—with various topographic challenges.[10] As such, in remote parts of the country there is extremely limited, to zero, terrestrial signal infrastructure available, and where provided, no carrier competition. This was emphasised by Mr Ewan’s comments about the Universal Service Guarantee (USG)[11] not applying to mobile services:

I think the USG report in 2021 highlighted that only one-third of Australia’s land mass was covered by mobile services at that time. As you’ve heard, most Territorians and most people in remote communities are using mobile devices for connectivity.[12]

1.11An alternative raised in the inquiry to using fixed tower infrastructure in remote locations was satellite connections via Geostationary Equatorial Orbit (GEO)[13], Medium Earth Orbit (MEO) or Low Earth Orbit (LEO)[14] satellites to an individual or community satellite dish. They are all used in telecommunications, for example, MEO satellites can be used to drive smartphone geolocation. An individual LEO satellite has limited telecommunications capability because as they move so quickly ground tracking is hard; but they are suitable if launched in a group constellation.[15]

1.12The Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA) noted in its submission that these services were considered ‘an adjunct or counterpoint’ to mobile terrestrial infrastructure, not a replacement.[16] The Committee heard of benefits in extremely remote communities, but also impediments to this option, including high fixed and variable costs to individual consumers but also an incomparable experience to mobile services delivered through the terrestrial network.[17]

1.13The global re-investment in space technology in recent years led to the Australian Civil Space Strategy 2019-2028[18] and the establishment of the Australian Space Agency (ASA) in July 2018. The ASA’s Communications Technologies and Services Roadmap 2021-2030 provides a ten-year strategy to support industry growth. LEO satellites are a priority component of the strategy.[19] The Committee notes with keen interest the establishment by the Government of the Low Earth Orbit Satellite Working Group, which first met in February 2023.[20] The working group has been tasked with providing feedback on some of the issues the Committee has broached throughout this inquiry, including what role LEO satellite technology is likely to play in the delivery of telecommunications services to rural, remote and Indigenous Australian communities.

Addressing market failure

1.14Australian governments at the federal and state level have sought to ameliorate market gaps through resource allocation and investments and incentive programs to expand mobile coverage and connectivity to all Australians. Effective mobile operation and access requires suitable available radio spectrum and efficient management of it—critical as data demands multiply—and physical infrastructure construction and maintenance. These elements become harder to secure as services move beyond urban footprints.[21]

Radiofrequency spectrum

1.15The radiofrequency spectrum is a finite resource. As such, the allocation of spectrum for mobile devices is planned and managed by the Australian Communications and Media Authority (ACMA). The effective allocation of spectrum affects service quality (coverage and speed) and cost.[22] Allocation of the appropriate radio spectrum for mobile transmission is considered in Chapter 2, Spectrum availability, as are mobile infrastructure development and management options for Mobile Network Operators[23] (MNOs).

1.16As technology has advanced the fifth generation of mobile network technology, 5G, has commenced deployment and 3G is being wound down. Mobile devices which are 5G compatible can utilise the higher frequency microwave band of the radio spectrum which can generate extreme speed and significantly greater data transmission.[24] This bandwidth also reduces signal delay and can sustain larger volumes of devices in any given area.[25] 5G technology will support mobile applications with far-reaching potential, having impacts in both the private and public domains. It is, however, currently mainly available in limited areas, where compatible towers have been constructed.[26]

Ground infrastructure

1.17Most Australians are currently connecting through the 4G network (and to a much lesser extent, 3G transmission).[27] However, the Australian Competition and Consumer Commission (ACCC) reported that all three MNOs continued to make large investments in their 5G rollout and deployment had started to shift from city‑centric to regional areas in 2022.[28] The primary issue raised with the Committee is the scarcity of transmitters of any kind in remote rural and regional Australia to enable foundation coverage and connectivity, as unpacked in Chapter 4 on poor coverage, and in Chapter 5 on the ‘digital divide’ in remote Australia.

1.18Another potential Government intervention raised in evidence is the application of auto-switching of carriers when roaming across terrain with sparse infrastructure. This was also raised as a feasible mandated regulatory requirement during a declared emergency or natural disaster. The Committee’s exploration of these suggestions, including potential impacts on commercial incentives and competition are outlined in Chapter 3, Roaming-based network sharing (standard continuous connectivity) and Chapter 6, Emergency roaming arrangements.

1.19The Australian Government’s Mobile Black Spot Program (the MBSP) is the most significant of the infrastructure focussed funding programs, operating since 2015.[29] The MBSP is supported by co-contributions from state and local government and mobile operators. The program’s intent is to encourage roll-out of physical infrastructure to extend the reach of mobile services into geographic areas where the market may otherwise not consider it commercially viable. Amplitel, Australia’s largest tower infrastructure company, acknowledged that in the absence of co‑funding initiatives, a new tower site ‘ultimately comes down to an assessment of the relevant business case’[30] and that ‘rural regional and remote areas are often not commercially viable without government co-funding’.[31] Indara Digital, which owns and operates 4,400 ground and rooftop assets, concurred.[32]

1.20The merits of the national MBSP to improve coverage, its evolution—and potential improvements—are explored in Chapter 2, Suggested changes to funding programs.

1.21Two other federal programs specifically targeted at boosting regional telecommunications connectivity are the Better Connectivity Plan for Regional and Rural Australia (BCP) and the Regional Connectivity Program (RCP) (a component of the former and originally an outcome of the 2018 Edwards Review[33]), both facilitated through DITRDCA. The Department states that:

Improvements in digital connectivity deliver some of the most tangible and widespread benefits across a huge range of areas including economic and social participation and equality, access to online government, health and education services, and public safety including on roads and during disasters and emergencies.[34]

1.22The BCP is a key initiative of the regional telecommunications agenda providing $656 million in the 2022-23 Budget ‘over five years to improve mobile and broadband connectivity and resilience in rural and regional Australia’.[35] The initial funding allocations prioritise $400 million to boost multi-carrier mobile coverage on regional roads, improve coverage in under-served communities and increase both resilience of services and public safety communications facilities. Of particular relevance to the inquiry is the $30 million allocation for on-farm connectivity and $20 million to conduct an independent audit of mobile coverage to better identify black spots to guide investment priorities.

1.23The next biggest funding allocation in the BCP was $200 million for the RCP competitive grants program (round three) to invest in place-based digital connectivity infrastructure projects in regional communities (both mobile and broadband) plus covering round seven of the MBSP stream which delivers new handheld mobile coverage to regional, rural and remote communities.[36]

1.24Co-investment schemes with a single carrier are active in some Australian jurisdictions, included in Chapter 2, and the NSW Government has developed a model to encourage greater multi-carrier infrastructure sharing (this approach is highlighted in Chapter 3).

Infrastructure options

1.25There are demonstrated benefits which can accrue to communities and carriers utilising multi-carrier mobile infrastructure networks, significantly, more choice and increased competition for consumers.[37] The Australian Communications Consumer Action Network (ACCAN) warned of the dangers of a sole MNO operating in a geographic area having ‘the potential to exercise monopoly power’.[38] However, the majority of Australian mobile infrastructure currently in service, including in built-up areas, is operated by a single carrier.[39] This is partly legacy investment of Telstra and also because MNOs other than Telstra are reluctant to service commercially thin regional markets.

1.26The Committee received evidence about the New South Wales (NSW) Government’s $400 million investment in the Regional Digital Connectivity program to ‘ensure families and businesses across regional NSW have access to faster and more reliable digital networks’.[40]Additionally, the 2023 NSW Connectivity Strategy is designed to achieve metropolitan equivalent connectivity levels for regional NSW, irrespective of the carrier contracted. In 2022 the $30 million Active Sharing Grants Program was created to overcome the problems with the ‘one tower, one carrier model’[41] and to deliver the competitive and cost sharing advantages of a multi-carrier system in regional NSW.[42]The program is planned to seek co-investments and partnerships with the Australian Government, telecommunications carriers, infrastructure investors and research organisations for the construction and operation of mobile coverage solutions in NSW.[43] This is discussed more in Chapter 3.

1.27The Committee has explored the economic feasibility and public benefits of deploying multi-carrier towers in preference to single carrier as a mechanism to encourage more competition in the regions and better coverage. The background to advancing a multi-carrier model in regional and remote Australia, the evidence received and Committee conclusions, are covered in Chapter 3. The Committee considered innovative ways to undertake co-investment and incentivise multi-carriage terrestrial infrastructure in the bush where the customer base is relatively very low.

1.28Inquiry feedback indicated community support for multi-carrier infrastructure, yet the significant successful international models explored in evidence—the United Kingdom and New Zealand private/public co-contribution models—don’t compare well to the Australian context of a very large and predominantly sparsely inhabited land mass. These paradigms are considered in Chapter 3, International examples.

Related government inquiries and reviews

1.29Expanded establishment of mobile infrastructure in regional Australia has been a particular priority of the Australian Government over the past few years. This has been reflected in the number of reviews and inquiries undertaken covering the subject in that time.

1.30Thereport, 2021 Regional Telecommunications Review—A step change in demand was tabled in February 2022.[44] It is the fifth and most recent report of the Regional Telecommunications Independent Review Committee. It was tasked with understanding the barriers people in regional communities faced using digital technologies and services. One of its four findings was that supply side issues, including backbone fibre and spectrum access were also barriers to competition in these markets.[45] It recommended, inter alia, that the Government continues to support provision of new mobile coverage and to consider funding vehicles ‘which leverage private sector co-investment’.[46]

1.31The Productivity Commission’s latest 5-year Productivity Inquiry report, Volumes 1-9 was tabled in March 2023. It explains the reforms which comprise the Government’s policy agenda. Volume 4, Australia’s data and digital dividend focuses on the productivity benefits of increasing digitisation and the key factors to support this. The report particularly highlights the expansion of digital infrastructure into regional and remote Australia as a priority, finding that (Finding 4.8):

Inadequate internet in regional areas limits productivity gains and lowers social inclusion.[47]

1.32The ACCC’s inquiry into mobile telecommunication towers for mobile telecommunications and radiocommunications in regional areas—and the feasibility of mobile roaming during natural disasters and emergencies—concluded on 30 June 2023.[48] The report of its preliminary findings on its Regional Mobile Infrastructure Inquiry was finalised in April 2023.[49] The inquiry considered the costs of establishing towers and associated infrastructure, and land access charges and how these relate to fee structures for mobile carriers who wish to access towers to provide services.

1.33The scope of the ACCC inquiry appears to be limited to a regional context, however the Ministerial Direction to the ACCC specified the public inquiry was to consider access and infrastructure in regional, rural, remote and peri-urban areas.[50] The Committee’s inquiry received considerable evidence beyond the regional scope specified in its terms of reference. The Committee received submissions from and heard evidence about Australians in regional, rural and remote locations. In Alice Springs the majority of witnesses represented remote communities. For completeness, the Committee has reflected non-urban feedback in Chapter 4 and has covered the significant digital divide in remote Australia in Chapter 5.

Recent parliamentary inquiries

1.34In the 2020 report of the Committee of the 46th Parliament, The Next Gen Future, which inquired into 5G deployment, adoption and applications in Australia, recommendation 5 states:

The Committee recommends that carriers consider multiuser infrastructure sharing to ensure that rural and regional consumers benefit from 5G services in a timely manner and ensure adequate coverage across all 5G spectrum bands.[51]

1.35The same Committee report supported, in its third recommendation, that the Australian Government encourage co-location of facilities and equipment fit for 5G, and a review of carrier arrangements for 5G infrastructure sharing.

1.36In November 2020 the Government responded to the Committee’s 14 recommendations, supporting recommendation 3 and noting the implications for co‑location of 5G equipment on infrastructure. Recommendation 5 was supported ‘in principle’, stating that although the co-location of infrastructure is a matter for carriers, that there are mechanisms in the regulatory framework to encourage this approach. The Mobile Black Spot Program was cited as one mechanism where base stations funded by the Australian Government have led to competition through carriers co‑locating.[52] The response concludes that it is ultimately a commercial decision of carriers as to how they progress 5G infrastructure roll-outs, and the management of spectrum.

About the inquiry

1.37On 12 September 2022, the Minister for Communications, the Hon Michelle Rowland MP, asked the Committee to inquire into and report on the experiences, opportunities, and challenges for co-investment in multi-carrier regional mobile infrastructure.

1.38The terms of reference for the inquiry (contained in the front pages of this report) required the Committee to consider the cost, feasibility and public benefits associated with the deployment of infrastructure supporting both single and multiple mobile carriers. The Committee was also required to consider community views on these different approachesand to examine examples of successful multi-carrier outcomes and their applicability in the Australian context.

1.39The terms of reference stipulated that matters relating to national security were out of scope for the Committee.

Conduct of the inquiry

1.40The Committee issued a media release on 28 September 2022 announcing the inquiry and calling for written submissions to be received by 10 November 2022. The Committee also invited submissions from telecommunications industry bodies, localgovernment associations, academics, and community organisations.

1.41In announcing the inquiry, the Chair said the Committee was particularly interested in hearing from businesses, organisations and individuals living in communities located in regional, rural, and remote areas of Australia.

1.42The inquiry received 43 submissions and 10 supplementary submissions, which are listed at Appendix A. The Committee also received 4 exhibits, which are listed at Appendix B.

1.43The Committee held 17 public hearings, listed in the table below, at which witnesses appeared in person and via videoconference and teleconference. Witnesses are listed at Appendix C.

Source: Committee records

Structure of this report

1.44This report outlines the evidence received to the inquiry and the Committee’s views and recommendations.

1.45Reflecting the critical nature of mobile connectivity, particularly in regional and remotecommunities, the Committee received a significant amount of evidence about poor coverage andother impediments to telecommunications access in many areas around Australia, and about the impact of intermittent or non-existent services.

1.46The lack of telecommunications services in First Nations Australian communities, particularly those in remote areas of Australia, was highlighted as a particular concern. Concerns were also raised about the impact of intermittent or non-existent services on law enforcement and the response to emergencies and management of natural disasters such as flood and bushfires.

1.47As such, while the report examines the technical and economic aspects of investment in multi-carrier regional mobile infrastructure, it also outlines community views on these and other issues—and considers suggestions for improvements to telecommunications services received in evidence to the inquiry.

1.48The remainder of the report is structured as follows:

• Chapter 2 outlines the current Australian mobile telecommunications context and key elements of the system including the radiocommunications spectrum and key terrestrial infrastructure. Overwhelmingly, towers have been occupied in regional and rural areas by a single carrier. This legacy situation is explored.
• Chapter 3 considers aspects of developing multi-carrier mobile infrastructure in the regions, currently more prevalent in urban areas. Costs, benefits and limitations of this pro-competition model, and government co-location incentives, are considered. Examples of active multi-carrier mobile infrastructure systems, both overseas and domestically, as well as related issues such as roaming-based network sharing, are evaluated.
• Chapter 4 reviews a wide range of evidence received on the experiences ofregional communities with respect to communications services, as well as community and industry sector views on the potential benefits of multi-carrier mobile infrastructure.
• Chapter 5 discusses access to telecommunications services in remote Australia, particularly in remote First Nations Australian communities, and examines measures to improve access, affordability and reliability. The potential role for LEO satellite-based services in remote communities is examined.
• Chapter 6 discusses the communications requirements of emergency services agencies in natural disasters and emergencies, and how this could be better supported, including using LEO satellite-based services.

Footnotes

[1]Productivity Commission (PC), 5-year Productivity Inquiry: Australia’s data and digital dividend, Inquiry report—Volume 4, Report no. 100, March 2023, p. iv.

[2]Including use of artificial intelligence, the internet of things, robotic automation and big data analytics.

[3]PC, 5-year Productivity Inquiry: Australia’s data and digital dividend, Inquiry report—Volume 4, Report no. 100, 7 February 2023, p. iv.

[4]The Australian Communications and Media Authority (ACMA) reported that between 2015 and March 2022, the proportion of Australians who only have a mobile for home voice calls had more than doubled: <https://www.acma.gov.au/publications/2022-10/report/how-australians-make-voice-calls-home> viewed 17October 2023. More females were watching online videos at home using mobile phones (52 per cent in 2022, up from 47 in 2021); and in 2022 those living in metropolitan areas were more likely to use mobile phones (55 per cent compared to 46 per cent in regional areas) to watch video content at home than those in regional areas. This indicates the strength of regional demand. Refer ACMA, Communications and media in Australia series: How we watch and listen to content, February2023, pp. 2–6.

[5]National Farmers’ Federation, Submission 20, p. 2; Refer Chapter 7, p. 1.

[6]Central Land Council (CLC), Submission 41, p. 1.

[7]New South Wales (NSW) Government, Submission 25, p. 4.

[8]Mr Ewan Perrin, Northern Territory (NT) Government, Committee Hansard, 16 May 2023, p. 23. Referring to: National Indigenous Australians Agency (NIAA), 2023 Closing the Gap Implementation Plan, Outcome 17, February2023. <www.niaa.gov.au/resource-centre/indigenous-affairs/commonwealth-closing-gap-implementation-plan-2023> viewed 21 August 2023.

[9]Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), Submission 23, p. 3.

[10]Indara Digital Infrastructure, Submission 24, p. 15 notes that ‘Challenging terrain can increase the cost of a tower by up to a factor of two’; Mr Andrew Ricketts, Submission 29, p. 6 notes reception issues due to hills; similarly noted in Dr Helen Haines MP, Submission 17, p. 3.

[11]The Universal Service Guarantee (USG) updated the Universal Service Obligation (USO) in 2021. DITRDCA: <www.universal-service-guarantee-usg-3september2021.pdf> viewed 10 October 2023.

[12]Mr Ewan Perrin, NT Government, Committee Hansard, 16 May 2023, p. 23.

[13]GEO satellites follow Earth’s orbit (West to East) sited above the equator at an altitude of 35,786 kilometres. As such, they appear stationary in the sky. They focus on a specific point on Earth, useful for telecommunications.

[14]LEO satellites orbit between 160–1000 kilometres altitude by using a tilt mechanism, thus can follow alternative routes to the Earth’s equatorial rotation. MEO satellites are similar, having various orbits, but higher altitudes.

[15]European Space Agency (ESA), Types of orbits, viewed 21 August 2023: <https://www.esa.int/Enabling_Support/Space_Transportation/Types_of_orbits#GEO>

[16]DITRDCA, Submission 23, p. 3.

[17]CLC, Submission 41, p. 2.

[18]Department of Industry, Science and Resources (DISR), Australian Civil Space Strategy 2019-2028, 1 April 2019. < https://www.industry.gov.au/publications/australian-civil-space-strategy-2019-2028> viewed 17October 2023.

[19]Australian Space Agency (ASA), Communications Technologies and Services Roadmap 2021-2030, 1December 2020. <www.industry.gov.au/publications/communications-technologies-and-services-roadmap-2021-2030> viewed 21 August 2023.

[20]Minister for Communications, The Hon Michelle Rowland MP, ‘New satellite working group charts way forward for telco industry’, Media release, 15 February 2023.

[21]DITRDCA, Submission 23, p. 3.

[22]House of Representatives Standing Committee on Communications and the Arts, The Next Gen Future: Inquiry into the deployment, adoption and application of 5G in Australia, March 2020.

[23]Telstra, Optus and TPG.

[24]Only 5G can operate in the highest frequency band of mobile spectrum; 5 and 4G share the upper-midband, and 5, 4, 3 and 2G the lower midband and low frequency bands. 5G will operate with extended coverage but lower speed and data volumes in spectrum bands <1GHz but second and third generation devices won’t operate in bands >3.5GHz. Spectrum for 5G in the lower midband may thus be reallocated to spectrum allocated for 3G.

[25]House of Representatives Standing Committee on Communications and the Arts, The Next Gen Future: Inquiry into the deployment, adoption and application of 5G in Australia, March 2020, p. 1.

[26]5G transmission has a more limited range than its lower band counterparts so requires more infrastructure.

[27]ACMA, Submission 3, p. 5. 4G is available to 99 per cent of the Australian population, with 5G available to 80per cent of the population.

[28]Australian Competition and Consumer Commission (ACCC), Communications Market Report – 2021-22, December 2022.

[29]The MBSP has delivered 1,297 new mobile base stations across Australia after generating a combined investment of $875 million since inception. <https://www.infrastructure.gov.au/media-communications-arts/phone/mobile-services-and-coverage/mobile-black-spot-program> viewed 16 August 2023.

[30]Amplitel, Submission 15, p. 5.

[31]Amplitel, Submission 15, p. 5.

[32]Indara Digital Infrastructure, Submission 24, p. 4.

[33]The first legislative independent telecommunications review was chaired by Mr Sean Edwards in 2018.

[34]DITRDCA <https://www.infrastructure.gov.au/media-communications-arts/better-connectivity-plan-regional-and-rural-australia> viewed 19 August 2023.

[35]DITRDCA <https://www.infrastructure.gov.au/media-communications-arts/better-connectivity-plan-regional-and-rural-australia> viewed 19 August 2023.

[36]The RCP grants program rounds 1 and 2 generated $413 million to deliver 223 regional, rural and remote projects. DITRDCA <https://www.infrastructure.gov.au/media-communications-arts/internet/regional-connectivity-program> viewed 18 August 2023.

[37]Competition in regional and rural areas is anticipated if a new MNO to the area can piggy-back off legacy infrastructure and where further infrastructure roll-out and network maintenance costs are shared.

[38]Australian Communications Consumer Action Network (ACCAN), Submission 4, p. 3.

[39]Indara Digital Infrastructure, Submission 24, p. 3; DITRDCA, Submission 23, p. 9.

[40]NSW Government, Submission 25, p. 1.

[41]DITRDCA, Submission 23, p. 14.

[42]NSW Government, Submission 25, pp. 1–2.

[43]NSW Government, Submission 25, p. 2.

[44]Australian Government, Regional Telecommunications Review, 2021 Regional Telecommunications Review—A step change in demand, February 2022, p. 19.

[45]Australian Government, Regional Telecommunications Review, 2021 Regional Telecommunications Review—A step change in demand, February 2022, p. 19.

[46]Australian Government, Regional Telecommunications Review, 2021 Regional Telecommunications Review—A step change in demand, February 2022, p. 11.

[47]Productivity Commission (PC), 5-year Productivity Inquiry: Australia’s data and digital dividend, Inquiry report—Volume 4, Report no. 100, March 2023, Finding 4.8, p. 37.

[48]At the time of writing, the final report was not publicly available. ACCC website, viewed 17 October 2023.

[49]ACCC, Regional Mobile Infrastructure Inquiry, Report on preliminary findings, 18 April 2023.

[50]ACCC, Regional mobile infrastructure inquiry 2022‑23, Ministerial Direction, 31 March 2022. <https://www.accc.gov.au/inquiries-and-consultations/regional-mobile-infrastructure-inquiry-2022-23/ministerial-direction> viewed 28September 2023.

[51]House of Representatives Standing Committee on Communications and the Arts, The Next Gen Future: Inquiry into the deployment, adoption and application of 5G in Australia, March 2020, p. x (Rec. 7).

[52]Australian Government response to the House of Representatives Standing Committee on Communications and the Arts: ‘The Next Gen Future’, Inquiry into the deployment, adoption and application of 5G in Australia, 12 November 2020. <https://www.aph.gov.au/Parliamentary_Business/Committees/House/Communications/5G/Government_Response>viewed 18 August 2023.