3. Multi-carrier mobile infrastructure

Overview

3.1As outlined in the previous chapter, much of regional and remote Australia is serviced by a single mobile carrier, or none at all. The Committee heard about arange of models for multi-carrier mobile network infrastructure with potential application for regional and remote locations. Models include passive site sharing, active sharing, neutral host models, and roaming.

3.2The chapter includes a discussion of evidence relating to the complex technical andcommercial considerations involved in the rollout of these models, as well as a possible role for government policies and programs in establishing appropriate incentives and regulatory conditions for their uptake.

Network sharing and multi-carrier models

3.3The Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA) explained multi-carrier models are varied:

Multi-carrier mobile networks can adopt a range of technological approaches with different degrees of sharing between providers and different implications. The main variables in the models are the degree to which infrastructure is shared and how sharing is undertaken. The sharing can relate to passive infrastructure like sites, towers and shelters, or active infrastructure, including the radio access network (RAN), associated radiocommunications spectrum, and network electronics.[1]

3.4Nokia, which provides the technology that enables mobile network sharing and has experience with more than 50 shared networks globally, said network sharing will become a necessity for most mobile network operators (MNOs) as ‘they face soaring 5G and 6G deployment costs as the need for expanded coverage, new network technologies and network capacities increases’.[2]

3.5Nokia’s submission outlined the models for network sharing as being divided into two broad categories: active sharing and passive sharing. Savings accrue from split-site rental and reduced acquisition costs under passive sharing arrangements; whilst active sharing results in further cost savings given the base station, controllers and site are shared; and even spectrum can be shared. However, Nokia noted other alternatives, such as geographic network sharing or national roaming:

It does not always have to be the MNOs that provide the network, a network provided by a third party for use by one or more MNOs is referred to as a neutral host network.[3]

3.6The Australian Communications Consumer Action Network (ACCAN) also provided a summary of infrastructure supporting multiple mobile carriers and its views on the benefits and costs of each model (see Table 3.1).

Table 3.1Summary of infrastructure supporting multiple mobile carriers

Source: Australian Communications Consumer Action Network (ACCAN), Submission 4, p. 6.

3.7DITRDCA outlined that by sharing infrastructure, carriers seek to reduce their costs and increase the reach of their footprints:

However, the savings from sharing need to take account of additional costs it causes, such as system interoperation and partitioning, particularly as sharing become more sophisticated.[4]

3.8Notwithstanding potential cost savings, DITRDCA believed sharing solutions may ‘not be economically attractive for carriers in some locations’:

For example, if the coverage provided by the sharing arrangement is significantly isolated from the rest of a carrier’s network, it may not be commercially attractive for the carrier to offer services using the system. Carriers strongly favour contiguous coverage over deploying isolated islands of coverage.

… Additionally, for very small markets it may be uneconomic for the carriers to split the market share. This may discourage carriers that expect to only receive a small share of market from offering services at a given location. The revenue from expected market share may be substantially smaller than cost of offering services at the location.[5]

3.9DITRDCA said these locations may require ‘high levels of funding to make it commercially attractive for multiple carriers to offer services, compared to locations in thicker markets’.[6]

3.10Evidence received about different multi-carrier models is outlined below.

Passive or site sharing

3.11Mr Jason Horley of Indara Digital Infrastructure (Indara) explained passive infrastructure sharing as primarily the ‘building of the tower, provisioning of power to the tower site and ensuring there's good access, often via an access track’:

Then the “active” is generally the equipment that is being lit up by power. So it'll be the antennas, the radio units and the transmission equipment. Historically, that's been left to the carrier to deploy and manage…

Indara believes that passive infrastructure sharing is a superior deployment model in areas where the mobile market is commercially competitive. We believe that because it enables carriers to deploy their own technologies, such as 5G and 6G, and also to compete in how they use the spectrum bands that they acquire, most of which are specifically licensed to them.[7]

3.12Nokia explained in passive sharing the physical site and site-related passive elements, such as facilities, towers, feeders, antennas, power supplies, back-up systems and air conditioning may be shared:

The mobile backhaul of the site may also be shared. The main benefits of this approach are lower site lease, construction and site operational costs. While passive sharing calls for independent investment by the MNOs for most of the radio and backhaul equipment, it gives each MNO full control of their network parameters. Passive sharing is considered the simplest form of network sharing because operators can fairly easily share sites and still maintain their autonomy and strategic competitiveness. But the cost savings associated with passive network sharing is more limited compared to more involved methods of network sharing. Often passive sharing is the first step towards more complex network sharing arrangements.[8]

3.13DITRDCA explained this less-complex approach to sharing, also known as co-location, was used extensively in Australia:

There is a high level of passive tower sharing on which radiocommunications equipment is co-located. This has been supported by the facilities access regime in the Telecommunications Act 1997 [Cth]. Co-location can reduce rollout and operating costs, avoid unnecessary duplication of infrastructure and avoidsomeplanning issues.[9]

3.14DITRDCA noted co-location was more common in major cities and inner and outerregional areas with tower sharing rates between 35 per cent to 85 per cent depending on the carrier, stating that ‘co-location rates drop in outer regional and very remote Australia’.[10]

3.15Mr Greg Preuss from Optus said the change in ownership of infrastructure assets to companies such as Indara and Amplitel had resulted in improved site sharing:

… there's more space on towers at a higher aperture, which gives better coverage. … And there are commercial arrangements between the carriers and these infrastructure providers now that allow us to access the sites in a more streamlined fashion to deploy our active equipment and get coverage to these areas.[11]

3.16Mr Jon Lipton of Amplitel said the provision of mobile telecommunication services requires the installation of both passive and active assets:

As a passive infrastructure provider, which is Amplitel, we typically are responsible for the grass, steel and the concrete. That includes the physical tower, the foundations and access tracks. It's the passive elements only. Our customers, including Telstra, are generally responsible for the active assets.[12]

3.17According to Commpete Inc., passive sharing of existing infrastructure is useful but only to a limited extent, particularly in regional and remote areas, ‘where it’s not economically viable to duplicate infrastructure’, and where Telstra’s incumbency benefit ‘has been boosted by the co-funding process to date’.[13]

3.18As noted in Chapter 2, Mr O'Leary of the Australian Competition and Consumer Commission (ACCC) believed the emergence of infrastructure providers such as Indara or Amplitel should help encourage more co-location by rival MNOs.[14]

3.19Mr Mevan Jayatilleke of One Wifi & Infrastructure questioned the effectiveness of the passive co-location model at encouraging competition:

Passive co-location is a blunt instrument and we don't think that is the way forward particularly for public funds and funding single carrier networks. In every market there should be three different operators, and they should have choice to go with the operator they prefer.[15]

Active RAN sharing

3.20Active RAN (radio access network) sharing refers to the active layer of the network, which consists of antennae, transceivers, base stations, and backhaul networks and controllers being shared. Nokia explained:

There are two main types of active RAN sharing, these are Multi-Operator RAN (MORAN) and Multi-Operator Core Network (MOCN). The difference between MORAN with MOCN is whether the air interface/spectrum is dedicated (each MNO maintains its own frequency band) or shared (both MNOs pool some/all of their spectrum bands). Parts of, or the entire mobile backhaul and core network may also be shared. This type of network sharing requires joint decision-making on investments and operational aspects between MNOs either directly or using a joint “network” company that sits between both MNOs. MNOs may also choose to split the deployment of Active RAN networks geographically.[16]

3.21Mr Horley outlined how Indara may extend its core business of sharing passive infrastructure to also providing the active electronics required by MNOs:

… we see this benefit of being able to extend the services we currently provide from passive and into active electronics and then being able to offer an integrated service to the MNOs but also one that will provide better service to communities, because all MNOs will be able to connect but also we'll be able to connect third parties, such as wireless internet service providers, to use those sites.[17]

3.22Mr Peter Bolger from Pivotel explained why he believed active sharing was a rational approach for tower infrastructure companies, saying ‘the cost doesn’t actually increase by going to active sharing’ but rather ‘the cost decreases for active over passive sharing’.[18]

3.23Mr Gary Bhomer also from Pivotel conceded there have been concerns raised by some MNOs about active sharing of infrastructure around the level of service quality or the kind of service that an MNO can provide their own users:

It is more a control issue. If I am Telstra, for example, I don't want somebody else to have control over the network experience that my customers are going to get. So they want to retain control over that.[19]

3.24Despite this, he said, there was still an opportunity to provide a ‘vastly improved service’ using active sharing in areas that would otherwise be uneconomic.[20]

3.25DITRDCA said that international experience suggests RAN sharing approaches may not be suitable in all situations, and highlighted RAN sharing ‘typically has more limited capacity compared to situations where each carrier deploys its own base station equipment’:

For example, Vodafone and O2 announced in 2018 that they were scaling back of [sic] their United Kingdom RAN sharing arrangement. They noted in areas of very high data traffic, a shared network may buckle under the strain and have a negative impact on quality of service. This is less of a concern where RANsystems are deployed in thinner markets.[21]

3.26Dr Robert Joyce from Nokia said the company had global experience providing its technology to more than 50 shared networks, and, in the Australian sense, three MNOs would not pose a problem:

We deploy shared networks; up to six physical operators can be shared on our towers. It is always a question of capacity, but the radio equipment we produce nowadays is built so that it can provide the power that would be required in such a scenario across three or more operators.[22]

3.27Mr Ian Miller from the Australian Radio Communications Industry Association (ARCIA) explained the merits of allowing sharing in regional and rural areas when Telstra’s network may be under strain:

Certainly, from a business point of view, if they had access to the two services, it could mean that, when one is absolutely jam packed with people …if businesses were able to step across onto Optus or TPG it would mean they would retain a service. That's where sharing services would open it up.[23]

Neutral host model

3.28Nokia explained the neutral host model is one in which the network is built and potentially operated by a third party, with MNOs buying coverage/capacity through a network-as-a-service model:

This approach typically required the MNOs to allow the Neutral Host operator access to their spectrum. This approach is sometimes referred to as a Single Wholesale Network (SWN) and this type of network could be built with some type of private-public partnership in which the network is operated by a neutral host and then multiple parties use the network.[24]

3.29Nokia believed the proliferation of neutral host model deployments was an element in the ongoing transformation of the landscape, driven by factors including MNOs divesting network assets, private capital being invested in infrastructure, and government funding to reach underserved regions.[25]

3.30Mr Jayatilleke of One Wifi described their company as Australia's leading 5G mobile neutral host provider:

Our proposition is predicated on shared network principles, specifically active mobile network sharing under a neutral host model. We believe the mobile active neutral host service will better address mobile black spots and is the only model that will truly close the digital divide at the lowest marginal cost. It will also reduce carbon footprint, facilitate competition and offer real choice for the Australian consumer. As a neutral party, we are the first in Australia to bring the mobile active neutral host model from concept to reality.[26]

3.31One Wifi believed its neutral host model is the best model for improving mobile coverage in regional Australia:

… active neutral host model is the only truly viable model that can provide the best outcomes in terms of ensuring ubiquitous and affordable mobile service throughout regional Australia. It also facilitates access on an equitable basis and addresses the needs of all stakeholders and industry participants.[27]

3.32Mr Jayatilleke recalled consulting widely with multiple network operators interested in the New South Wales Regional Active Sharing (RAS) program (discussed below) to better understand their technical requirements and overcome any reluctance. He said that they agreed on the ‘commercial’ and ‘technical’ models to deliver a service while preserving their ‘autonomy and market agility’.[28]

3.33Mr Jayatilleke said there was a thorough design, engineering, and consultation process.

… which we all participated in and successfully completed—the MNOs, the MNIPs, fixed wireless providers and so on. We agreed the principal tenants in that round, and we have moved towards forming service contracts with MNOs and fixed wireless providers on a 'RAN as a service' basis.[29]

3.34The consolidation of the structure, power, backhaul transmission and active network equipment can save up to 50 per cent in upfront cost under a neutral host model, compared with passive sharing only, according to One Wifi:

The sharing of RAN and backhaul transmission also represent significant ongoing cost savings. The savings are amplified in regional Australia due to expensive high capacity backhaul.[30]

3.35However, Mr Jayatilleke conceded the possible downside of the neutral host model was it ‘could end up being a white elephant in that no-one connects’:

But if you look at it from a rational behaviour perspective… the cost to participatein a regional market is very high. If the costs were to be in line with market expectations, the decision becomes a simpler one about participation. We speak with confidence now only because of having gone through that process. We believe there is an absolute commercial construct for every geographical market that would be palatable for all the MNOs.[31]

3.36Commpete stated that emerging active neutral host models appear promising:

The potential to allow multiple operators to utilise the same electronics and infrastructure should increase the rate of return on investment if utilisation can be maximised.[32]

3.37Commpete argued that active neutral hosting has many ‘natural advantages’ inregional areas and could improve competition and increase efficiencies in infrastructure usage. The organisation highlighted examples of neutral host models in overseas jurisdictions and a trial in New South Wales, discussed later in this chapter.[33]

3.38Field Solutions Group (FSG) said it saw a market opportunity for neutral host capability to be more cost effective with a focus on connectivity in rural, regional and remote Australia.[34] Mr Andrew Roberts, Chief Executive Officer of FSG said he expected that new FSG towers and networks would be finished by March 2024 and ‘they will be active sharing-ready or neutral hosts’:

Our vision is: don't build a tower next to another tower; build one tower and put one set of radios on it, as that is cheaper, and it needs to use less power.[35]

3.39With a grant under the Regional Connectivity Program (RCP), Mr Roberts explained how FSG was able to find a business case for developing mobile infrastructure and a fixed wireless network in regional and rural areas such as Moree in New South Wales, where the much larger telecommunications companies would not.[36]

3.40Residents and business owners offered prime locations to FSG for new towers or other locations for transmission equipment to assist FSG to improve poor mobile coverage.[37]

3.41FSG also explained it was running an active neutral host trial in partnership with Optus, under the Mobile Black Spot Program (MBSP).[38] Mr Roberts said the year‑long trial in regional Queensland was ‘Australia's first neutral host trial that is fully supported by the federal government’ and would allow people ‘to use an FSG phone or an Optus phone’ in that part of the network.[39]

3.42Despite the thinner markets in regional, rural and remote Australia compared to the metropolitan market, Mr Roberts shared how FSG derived income from its active sharing model:

When we move to our active sharing model and a carrier wants to come on, they pay a fee for the facility to, say, access a tower; then there's a baseline with just a minimum fee that's charged; then there's a usage component, say, when someone surfs the internet or makes a call; then we get paid.[40]

3.43Ms Elyssa Rollinson, Chief Commercial Officer of BAI Communications, outlined thatBAI owns and operates a broadcast transmission network which delivers TV and radio to over 99 per cent of the population of Australia. BAI has also seen ‘very rapid growth overseas over the past decade building and operating telco networks in the US, the UK, and Canada, as a neutral host’:

We hope that the Australian market will follow the path of the international MNOs in seeing the significant benefit of sharing networks, both passive and active. … BAI believes that, where public investment is placed into regional connectivity, the funds should be used both efficiently and effectively and deliver a broad range of connectivity outcomes and solutions for communities.[41]

3.44Ms Rollinson wished to draw a parallel between the television and radio broadcast industry and the telecommunications industry, highlighting a number of similarities:

Both typically require ... passive components and then they require active network assets like transmitters. The broadcast industry for decades has realised that it makes sense to share not just the passive infrastructure but also some of the active components. They recognise the lower cost of doing that and the lower community impact of not having multiple towers around.[42]

3.45However, TPG Telecom’s Mr Trent Czinner questioned how much of a role neutral host operators can have in improving regional mobile coverage:

… their ability to deliver multicarrier outcomes is limited. Demand for neutral hosts and towers is derived from MNOs, and the economic decision to invest in a site is not significantly different whether the tower is built by an MNO or a neutral host. The capital cost of the tower is moved to the neutral host, but the capital cost of the equipment and ongoing operating cost remains borne by the MNO.[43]

3.46Mr Czinner said, in relation to the economics of a neutral host operator building a tower in a regional setting, even if towers were to be built ‘we would still not want to pay… to join a site where we have no customers and very few would travel to that area for us.[44] He stressed the ‘very high ongoing costs’ involved which included electricity payments, transmission and equipment maintenance, as well as ‘highrentals’ for neutral host providers.[45]

3.47Mr Grahame O’Leary from the ACCC described a few of the complex issues faced by different MNOs when sharing mobile infrastructure under the neutral host model, including the different coverage patterns and markets prioritised by MNOs:

You have to have agreements and you have to have technical compatibility between systems. That tower has to be in the place where you want that tower to be, and that's not necessarily the same for all three mobile network operators. … There are a lot of things that have to come into place first before that kind of model really gets up.[46]

3.48Ms Tara Morice also from the ACCC conceded even if a neutral host infrastructure provider was supplying the tower and equipment, the MNO still needed to generate sufficient revenue in a thin market, saying ‘you’d have to pick up market share … to warrant that investment’.[47]

3.49Mr O’Leary believed it was early days for the role of neutral host site operators in Australia:

I think they're very much in the role of a niche operator at the moment. They don'thave substantial scale like the mobile network operators have or the mobile network infrastructure providers… Effectively when you look at the infrastructure providers, the tower [companies], they're not much different from the neutral hostmodels. They just do it for the passive infrastructure.[48]

3.50Mr Luke Coleman from Vocus Group highlighted how the Challenge Network, which it acquired in 2023, operates private mobile networks, which can be applied to building mobile networks for public use:

What we are proposing… is, effectively, a wholesale first model as a carrier-neutral provider. We would provide the infrastructure, being both the passive components of the tower and the active components of the wireless equipment and the network electronics, and that would be open on an equivalent basis to any mobile network operator.[49]

Roaming-based network sharing

3.51Nokia said roaming-based network sharing allows customers of one operator to roam seamlessly onto a ‘host’ operator’s network and potentially vice-versa. While national roaming is sometimes seen as an alternative to network sharing, according to Nokia, especially where one MNO may have a larger coverage footprint than the other, it noted:

In the roaming-based approach, operators do not share any of the network infrastructure and customers simply “roam” onto the roaming network as is done when customers “roam” abroad. From an operator’s perspective it has several disadvantages, one being that some not all services offered in the home network may be available in the roaming network and also roaming customers may see their phones displaying the name/logo of the roaming network when these customers are roaming.[50]

3.52National roaming can also be used as a means of achieving agreed geographical splits between sharing operators, according to Nokia, with each operator deploying its own network and using its own spectrum within its given area. In cases where national licences are issued, not all the available spectrum can be used unless byprior agreement.[51]

3.53ACCAN warned the roaming model had the potential to undermine commercial incentives to improving network coverage and provides the least amount of control and flexibility to guest MNOs, preventing competition with respect to speed, network quality and transmission rates:

For example, given the thinner profit margins in remote areas, roaming may be more suitable as all equipment and spectrum is shared, making it the least costly model of deployment. Due to limited population density, there will be less risk of network congestion. In more populous areas, a form of active sharing may be more appropriate as it reduces risk of network congestion, whilst at the same time reducing costs of deployment.[52]

3.54According to the DITRDCA, while Core Network sharing may be seen as analogous with roaming, where a carrier acquires rights to use another carrier’s network to provide services, there are ‘differences in approach’:

All sharing solutions depend on a high degree of cooperation between carriers, with active solutions involving even greater cooperation. The commercial model supporting a sharing solution also needs to be considered.[53]

3.55Mr Trent Czinner of TPG Telecom (TPG) would welcome regulated domestic roaming but noted the challenge would involve the ‘government requiring the largest network in Australia to be open for access to others that wish to roam’:

The complexities of that will be the regulatory process to get us there and the access prices agreed to access that network. That is something we asked the ACCC to consider in 2016. They did follow a process to look at that and decided not to regulate it. At that time, it was to be regulated as open access under the Competition and Consumer Act; that was the proposal.[54]

3.56Optus has agreed to trial domestic roaming in regional Queensland with neutral host FSG.[55] Mr Andrew Sheridan from Optus declared the company did not support mandated roaming because of concern it would ‘undermine further investment, particularly in regional networks’. As a result, he said, roaming would not encourage increased coverage or address gaps in coverage.[56]

3.57Mr Sheridan also referred to the ACCC’s consideration of the issue in 2017–18:

One of the reasons we said we didn't think it was a good idea was because wewere embarking upon a significant regional investment program of around $1billion of investment to both upgrade, improve and extend our coverage in regional areas and bring real competition and choice to the regional communities. Roaming wasn't mandated. The ACCC thought that it had significant problems and actually would lead to worse outcomes for communities and businesses.[57]

3.58Since that ACCC decision, Mr Sheridan said Optus had gone forward with that investment, which would have not occurred had roaming been mandated.

We've brought increased competition and choice and improved quality of service to many regional locations. … If roaming had been mandated, we would have had no incentive to make that further $1 billion worth of investment. Then communities don't get that sort of virtuous cycle of improved investment.[58]

3.59Mr Sheridan also noted the ACCC’s concerns that roaming could lead to a move away from national mobile pricing to specific regional pricing.[59]

3.60The Committee heard from community members in regional areas about the benefitsof roaming to address gaps in connectivity between different MNOs. For example, Ms Jan Ferguson of the Outback Communities Authority in South Australia told the Committee:

If that connectivity could be more fluid, if they could share their infrastructure, itwould by default actually then increase your coverage and you'd have more consistent coverage for all, for business and for emergency services purposes.[60]

3.61Telstra Corporation’s Principal of Networks Mr Andrew Briggs noted that phones with dual SIMs were an alternative option, which did not involve roaming.[61]

Limits to potential benefits of infrastructure sharing

3.62Sharing mobile infrastructure is ‘one way to deliver better connectivity to regional Australia’[62] and is generally something Telstra supports:

In many locations throughout the country Telstra and other MNOs are already achieving efficiencies and seeking to reduce visual and environmental impacts by co-locating their equipment. We also see a lot of potential for improved regional outcomes from commercially negotiated active sharing arrangements.[63]

3.63However Telstra claimed the potential efficiencies that can be achieved from infrastructure sharing were limited.[64]

3.64For this potential to be realised, first the infrastructure needs to be ‘in the right spot’[65] from the perspective of multiple MNOs, according to Telstra.

In Telstra’s experience, mobile network design is far more complex than MNIP’s and Neutral Host providers often appreciate. When selecting the location for a new site, our network engineers carefully consider a range of factors such as call traffic movement, capacity balancing and interference management. If a tower isn’t built in a location that an MNO can make practical use of in terms of their existing network locations; their spectrum; their network equipment and the preferences of their target customer base, then that tower is unlikely to be of much benefit to the MNO and potentially could degrade existing services.[66]

3.65Telstra warned any obligation upon the MNO to nevertheless utilise this infrastructure could involve the MNO incurring ‘unnecessary costs and potentially having to forgo more efficient and effective ways to improve their mobile offering, which would not be in the best interests of end-users anywhere in Australia’:

… the infrastructure needs to be designed and built upfront so that it can be shared by multiple MNOs. Especially in more remote locations, this is not always practical or cost effective:

• many remote deployments (which are a long way from the nearest fixed infrastructure) use satellite backhaul. This is very costly, and reserved capacity needs to be limited to the minimum required for viability. Adding additional end-users is likely to degrade the end-user experience such that some basic online activities become unreliable or impossible. The alternative is to upgrade the satellite backhaul capacity, but the cost of this is significant.[67]
  66. Telstra said remote area solutions could include the deployment of co-funded small cell sites, which had been supported in past rounds of the MBSP:

These light, small structures are typically specifically designed to just meet the minimal needs of a single mobile cell. Accommodating multiple small cells for multiple operators (passive sharing) would require the building of a bigger and more costly structure, more akin to what’s required for a macro site. This upgrade cost alone can amount to more cost than if separately sited individual carrier small cells were built to minimal standards.[68]

3.67More remote sites may also be limited in their utility for active sharing:

In our experience, cell radio power is commonly a limiting factor for sites in remote Australia. … Consequently, we typically operate our radios at their maximum power rating to maximise the coverage of a site. In this situation, if additional bandwidth is needed to support additional demand from multiple sharing MNOs (for example, traffic from metro-based customers of a second MNO who are visiting as tourists), the added bandwidth can only be supported if the amount of coverage from the site is reduced. This option may be less beneficial for end-users in the area than the installation of separate additional infrastructure.[69]

3.68Mr Toole outlined the recent work Telstra had undertaken on network sharing has allowed it to determine the options which it considers would ‘deliver the best multi-carrier outcomes from a technical, commercial and customer experience perspective’. He noted that ‘all forms of multicarrier operations have pluses and minuses,’ saying ‘we see it as vitally important to provide flexibility in any future program and avoid any prescribed one-size-fits-all outcome’.[70]

3.69Mrs Tracy Lefroy, Member, National Policy Group, GrainGrowers Ltd believed governments encouraging more multi-carrier mobile infrastructure will potentially make a big difference in regional Australia.[71]

…you certainly have general support for incentivising multi-operator infrastructure and co-location in regional areas…in principle, we love the idea of reducing duplication and increasing coverage and choice for consumers, especially in those hard-to-service areas where…there may only be one customer at the end of that line who is benefiting, but that customer is contributing millions back into our economy.[72]

3.70GrainGrowers also welcomed governments fit-for-purpose funding programs such as the $30 million On Farm Connectivity Program (OFCP) by offsetting some of the cost to extend digital connectivity and enable farmers to take advantage of advanced farming technology and implement digital agribusiness solutions through improved connectivity.[73]

This makes it essential that we continue to tweak this program design to ensure that we push coverage as far as possible. That low-hanging fruit is gone. What is next on the ladder? Changes to each round of the Mobile Black Spot Program is an example of the evolution of these programs, and there is also an ever-increasing need to help producers and regions plan even greater roles…Place-based programs like the RCP (Regional Connectivity Program) have considerable merit. What I love about these is that they are not approaching the issues with broad brush strokes but are looking at tailored, localised solutions.[74]

3.71Indara, which took over Optus towers, submitted the emergence of independent tower companies such as itself may provide the opportunity and incentives to have public funding support all MNOs’ subscribers.[75]

Firstly, the non-MNO aligned independent tower companies respond to incentives to maximise usage and therefore revenues from the tower and so benefit from all potential MNO usage.

Secondly, technology developments in 4G and 5G radio access networking and spectrum sharing now support multiple carriers using the one set of network equipment… This is a significantly improved “value for money” outcome as against the previous policy designs.[76]

3.72Indara outlined that a neutral host/open access funding construct also has the ability to extend the benefits of the public funding beyond just the MNO customers.

3.73Indara said the open access framework that supports the New Zealand Regional Connectivity Group (RCG) (that declared space on publicly funded towers) can be provisioned for MNOs and WISPs, local regional governments and emergency services.

By adopting this approach in the Australian context, capacity on a publicly funded tower could also be reserved for NBN and local fixed wireless service providers. This additional value to the community flowing from co-investing in multi-carrier deployments by independent tower companies is further enhanced by the tower companies’ core business of simplifying and shortening the process of providing third party access to blackspot infrastructure.[77]

Telstra’s views on multi-carrier outcomes

3.74Telstra submitted its belief that the best outcomes for regional communities are achieved by allowing operators commercial freedom to select the most suitable deployment and sharing arrangement case-by-case.[78]

We cannot support programs that mandate roaming. Nor can we support other prescriptive forms of active sharing (such as neutral host requirements) … Overall, we believe that these type of mandated solutions will be detrimental to the objective of improving regional mobile connectivity over the short, medium and long term.[79]

3.75Mr Bill Gallagher, Telstra’s Regulatory Affairs and Legal Services Executive stressed the importance of flexibility in government funding and co-investment programs.

It means to not prescribe outcomes, not prescribe models, not prescribe how bids in these programs should be formed and on what basis they should be put forward but to maintain an ability for the industry to optimise outcomes by choosing different models. In any particular program, in any particular round of funding, you might have multiple models put forward by multiple parties…Different sites or combinations of sites might suit different models.[80]

3.76Telstra conceded it did believe there was ‘scope for a greater degree of commercially agreed infrastructure sharing between operators than there is today’ including on ‘existing and enhanced passive sharing and/or commercially agreed active sharing on future government co-funded sites where costs are shared between participating operators and government’:

Along with continued advances in the technology and standards supporting different forms of active sharing, key factors suggesting there should be a stronger emphasis than historically on multi-carrier outcomes as a viable public interest consideration for government funding of mobile infrastructure in Australia include:

• the increasingly challenging economics of addressing remaining regional coverage gaps; illustrated by Federal Government co-funding in the MBSP increasing from ~29 per cent in Round 1 to ~53 per cent in Round5A;
• the impacts of climate change, which have put a spotlight on the public interest in communities having access to connectivity during natural disasters; [and]
• the recent changes to the structure of the infrastructure businesses of Australia’s three MNOs, creating a competitive landscape in which all tower providers will be keen to maximise the number of access seekers on their infrastructure.[81]
  77. Telstra believed active infrastructure sharing ‘commonly requires the sharing parties to consider and resolve a range of complex operational and commercial matters’.[82]
  78. Mr Gallagher warned if governments were to prescribe a particular model it would ‘exclude other models which might be more suitable’, saying ‘keeping that flexibility for program participants to match models with circumstances’ would allow maximum benefit to be achieved.[83]
  79. Telstra was about ‘maximising bang for buck from these programs’, according to MrGallagher:

If you're too prescriptive about a particular requirement in a program and it excludes alternative approaches, alternative models or alternative technologies…what that does is it essentially minimises the bang for buck that the government, federal or state, will actually achieve … because alternative models might allow the deployment of additional infrastructure using those additional models. Getting greater coverage might be one outcome, or getting less congestion might be another outcome. By maintaining that flexibility and allowing industry to essentially tailor their bids, their proposals in these programs, you will maximise the outcome.[84]

3.80Mr Toole stressed that communities would have individual needs that need to be addressed by programs.

I think, if you start to get too prescriptive in what can be delivered under the program, you can preclude certain solutions. As an example, if you could provide a small cell solution to a roadhouse or a small community that just needs a little bit of a boost to coverage, if there's a very prescriptive technology approach that is put forward that requires a certain multicarrier outcome, that may mean that community can miss out …[85]

Feasibility and cost of regional multi-carrier options

3.81Australia’s largest tower infrastructure company, Amplitel, submitted that co-location through passive mobile infrastructure sharing can offer benefits to mobile network infrastructure providers (MNIPs), mobile carriers, and the public.[86]

3.82Mr Lipton highlighted the considerations Amplitel believes would ‘reduce the disincentives to invest in tower infrastructure’ and lead to better mobile connectivity across Australia:

They include harmonisation of state and territory development and planning processes, planning exemptions extending to non-carriers for towers, and reconsideration of the lot size for towers, and a reduction of government co-user fees when the governments are landlords.[87]

3.83Mr Lipton said to get the best outcome out of co-funding programs and to maximise common interest, Amplitel believed the ‘design of the co-funding programs should include a staged process to allow carriers to express early interest in co-location on sites’, and not be structured in a way that disincentivises co-location on existing infrastructure.[88]

3.84Indara expected the change to build more multi-carrier infrastructure will be driven by the relatively recent shift from the dominance of integrated MNOs as tower owners and operators to the emergence of independent tower companies such as itself.[89]

The underlying driver for this change is the acknowledgement by the integrated MNOs that the investment profiles and operational capabilities of their active network equipment were no longer aligned with the requirements of the (passive) physical tower infrastructure that supported the active equipment.[90]

3.85Mr Jason Horley, Executive Director, Property and Customer Engagement, Indara, supported a multi-carrier mobile infrastructure deployment model in any regional, rural and remote areas where there's ‘market failure’ to attract enough customers to support single carrier infrastructure, such as blackspot areas.[91]

3.86Mr Matt Healy, Principal, Healy Advisory elaborated on behalf of Indara how the motivations were different in the past before the formation of independent tower companies such as Indara and Amplitel when the MNOs owned the mobile towers:

They were owned by the one operator, who had incentives to, essentially, initially serve themselves, because that was why they were doing it. But, as you have the rise of the independent tower company … Their incentive is to get as many signals on that tower as possible—as many operators—because each operator that puts their equipment on that tower is charged a lease fee, and that’s the main source of revenue for the independent tower company.[92]

3.87MNO returns on active equipment required relatively rapid investment horizons, according to Indara, due to the pace of technological change driving demand. It warned the MNOs’ investments for upcoming technology such as next generation 6G services, or additional spectrum to satisfy demand, loom as substantial costs:

The investment profiles for the tower infrastructure, on the other hand, are very different to the capital requirements for spectrum and network technology investment needs. Towers have long period paybacks, often greater than 20 years.

The proliferation of mobile network sites also means there is less competitive advantage to the MNO in having “their” tower, as tower sites are readily available.[93]

3.88Mr Luke Coleman, Head of Government and Corporate Affairs, Vocus Group questioned the effectiveness of the current investment environment which has seen only ‘limited use of multicarrier infrastructure sharing models, even on sites which are largely funded by the public’:

This is primarily due to the coverage dominance of a single carrier [Telstra] which has limited, if any, incentives to share infrastructure with other mobile network operators. In our view, the solution is that government programs should mandate open-access multicarrier solutions to be eligible for public funding. Each subsequent funding round of the Mobile Black Spot Program sees an increased proportion of public funding go towards each site. So we are approaching a point where the government will likely be funding new sites in their entirety, yet the benefits are largely going to a single private company. …

New mobile sites constructed with public funds should include an obligation to provide open-access services at equivalent pricing to other carriers.[94]

3.89Mr McCabe declared the WA Government would closely monitor the progress of the FSG base at Talbot, in the WA wheat belt, co-funded in round 5A of the MBSP, as will the outcome of FSG's neutral host trials in Queensland and New South Wales, when they are completed.[95]

It will be interesting, too, to gauge whether the sale of Telstra, Optus and TPG towers leads to a shift in market dynamics for infrastructure access. The optimal access model at any given site, however, is highly dependent on location-specific factors and it remains to be seen whether these emerging models can both expand coverage and drive competition in areas where no mobile services are at present.[96]

3.90While some local government councils may be reluctant to seek government funding to partner with MNOs on building high tech infrastructure in their region, Ms Jan Ferguson OAM, the Presiding Member of the Outback Communities Authority, which has responsibility for the management and local governance of 63 per cent of South Australia, would welcome working in partnership if it improved coverage.[97]

We're looking at a partnership currently with the Royal Flying Doctor Service to see whether we can partner and pool our investments. We can't do very many things on our own, but we can do things in collaboration and partnership. Like we said, we've got the local knowledge, which in our world of vast areas is really important.[98]

Design of government programs to incentivise multi-carrier solutions

3.91ACCAN outlined that consumers will benefit from greater incentives for incumbent MNOs to further expand infrastructure sharing and there is room for public policies to further drive co-investment.[99]

3.92ACCAN also believed governments should create the right incentives for successful multi-carrier infrastructure through changing the grant funding guidelines for mobile infrastructure grants:

New towers funded through programs such as the Mobile Black Spot Program should prioritise appropriate models based on location specific factors. In addition to grant funding, gifting spectrum to MNOs could be examined to further commercial incentives for co-investment.

Regulatory scrutiny will still be required to ensure that the benefits of shared infrastructure emerge, and that sharing arrangements do not undermine competition and cause consumer harm.[100]

3.93Ms Michelle Lim said Commpete’s members, which include regional providers, MNOs and mobile virtual network operators (MVNOs), all want appropriate pro-competition policy and industry settings, especially in rural and regional areas, in order to be able to compete.[101]

3.94The market share of MVNOs, which are wireless communications services providersthat do not own the wireless network infrastructure or spectrum licences, has failed to grow significantly over the past 25 years and has been declining from approximately 15 per cent to now about nine per cent, according to Commpete:

The MNOs are reluctant wholesalers. … Telstra does not typically support roaming or active sharing to other MNOs, other than in relation to the proposed TPG-Telstra arrangement, which involves other negative impacts on competition.[102]

3.95Mr Lipton from Amplitel called for refinement of government funding programs to ensure efficiencies and improve multitenancy by not disincentivising MNOs to co‑locate on existing mobile infrastructure:

We have seen examples where we've got an adequate tower with sufficient capability to accommodate additional customers, but the structure of the co-funded program provided capital and therefore it effectively encouraged the mobile network operator to build a capital asset as opposed to co-locating on an existing one. …with mobile network operators now divesting their telecommunication towers into new entities, recovery of rental from the mobile network operators is how our business operates. So, if the program is designed to only provide capital, it may inadvertently disincentivise co-location on existing infrastructure and encourage using government capital to overbuild.[103]

3.96Mr Lipton explained the current programs fund capital not an MNOs’ ongoing costs.

We recover our tower costs over quite a long period from our customers. That's an operational expense or a rental expense for them. The way the current program is designed it may be more efficient for them to overbuild an existing tower, because they've got access to capital rather than an ongoing [cost].[104]

3.97Optus submitted there were two steps for effective Australian Government programs to better promote regional sharing:

1. Address the competitive impact of differing network coverage footprints through programs designed at promoting competitive coverage. The aim of this is to reduce the coverage differential.[105]
2. Focus on areas of common coverage interest, or where MNOs have equivalent existing coverage. Areas of common coverage interests increase as the coverage differential is reduced. Without broad equivalent coverage, areas of common interest are most likely to be specialist land types such as rail and road corridors.[106]
   98. Optus stated its preference that Government funding programs replace the primacy of achieving ‘new’ coverage with the delivery of ‘improved’ services, which may include a combination of new coverage, upgraded technologies, resiliency measures and competitive services.[107]
   99. DITRDCA noted that under the MBSP, ‘grantees are required to offer co-location on funded infrastructure to other carriers where technically feasible’ and required to ‘provide backhaul to a co-locating carrier’ at ‘more favourable prices than those regulated by the ACCC’.[108]
   100. DITRDCA said under Round 5A of the MBSP, MNIP and operator FSG was awarded funding to undertake two trials of new mobile deployment models in partnership with Optus:

The first trial involves the use of an Active Neutral Host RAN to deliver coverage from FSG’s Regional Australia Network and the Optus mobile network on seven new mobile towers … The neutral host model will use a single set of electronics and radio equipment on each tower to deliver coverage from both providers, with the potential to accommodate additional carriers. …

The trial aims to demonstrate the technical feasibility of the neutral host model, as well as its benefits in reducing costs for mobile network operators and driving competitive coverage outcomes in less economically viable areas of rural Australia.[109]

3.101The second trial, according to DITRDCA, will utilise a domestic roaming arrangement to allow other carriers’ customers to ‘roam’ onto FSG’s Regional Australia Network in regional, rural and remote areas. Under this arrangement, other carriers’ subscribers will be able to continue to use Optus voice and data services on their mobile device when visiting an area with coverage on the FSG Regional Australia Network.[110]

3.102Mr Andrew Sheridan, Vice-President, Regulatory and Public Affairs, Optus outlined how an MNO and infrastructure provider may jointly bid for a regional site and how this impacts upon co-location with another MNO:

So, importantly, there's an opportunity to redesign incentives around how funding is provided to ensure that, if there's taxpayer funding of any particular infrastructure, it should flow through to the customers of all providers who want to use that infrastructure. And that isn't really the case today in many of these schemes.[111]

3.103Mr Preuss of Optus agreed there was room for ‘improvement in some of the designs around these programs and an upfront matching of where all carriers want to invest would potentially improve some of these outcomes so that—to Andrew's point—the taxpayer funding does flow to all carriers and their customers’.[112]

3.104Vocus submitted that the extreme power imbalance in the mobile market has stymied the development of multi-carrier regional mobile infrastructure such as neutral-host networks, and that Government programs should mandate open-access solutions to be eligible for public funding.[113]

3.105Vocus commented how the Government had opened applications for the latest funding round of the MBSP, however Vocus believed the program guidelines were unlikely to sufficiently incentivise multi-carrier infrastructure sharing due to the market power issue as:

…it does not take into account the market power dynamics of the mobile industry which has resulted in no successful multi-carrier, neutral-host, or active sharing models being deployed in the Australian market to date. The success of neutral-host infrastructure sharing trials has been hampered by one or more MNOs refusing to participate.[114]

3.106Pivotel argued that regulated access to Telstra’s network was ‘the only path forward’ to encouraging new and existing operators to provide new coverage:

Such access will foster innovation and newcompetition in the provision of mobile services… it is incumbent on future government programs to provide active sharing on all new coverage, funded wholly or in part through government co-contributions at regulated rates.[115]

3.107According to Indara, new open access deployment models require a new funding construct where public funding covers build, activation, and operational costs for an initial period of service, noting that all MNOs have the opportunity to benefit from thetower’s operation:

Importantly, the cost to the Federal Government of the program is expected to be comparable with past models on account of the “shared” nature of many of the capital and operational costs.[116]

3.108In a supplementary submission, Indara Digital Infrastructure recommended the government reserve a ‘modest portion’ of its Round Three RCP and MBSP for allocation to ‘fast track the trialling of a new shared deployment model’:

Unlocking the full benefits that flow directly to the community from the public funding of mobile connectivity in regional and remote areas is significantly enhanced if all three MNOs are able to provide services via co-funded multi-carrier tower(s). This is especially the case in connectivity gaps along major regional roadways that are subject to persistent market failure in attracting private investment. …

In the upcoming Round 3 funding, $10M should be set aside for co-investment toward 6–8 sites to prove out the technical and commercial model for multi-carrier sharing.[117]

3.109The Round Three draft guidelines foreshadow the preference for multi-carrier MNO solutions, according to Indara, including solutions that use active sharing technologies and/or mobile roaming.[118]

3.110The solution Indara proposed was designed to efficiently enable all MNOs to use the funded sites through a single deployment model which ‘incorporates shared shelters, power systems and backhaul which reduces deployment time and cost’:

However, to accommodate MNOs preferences for greater network control this model dedicates each MNO their own antennas and allow MNO choice of equipment vendor. This approach will reduce MNO integration costs. Indara believes this model will be more acceptable to MNOs and will deliver improved price to performance outcomes.[119]

3.111Indara submitted that locations along major highways that ‘lack contiguous coverage’ should be priority locations for a trial, which could help to address connectivity gaps, expand competition, and lower costs for MNOs.[120]

3.112One Wifi outlined three key reasons for government co-investment in active neutral hosting, so as ‘not to replicate errors of the past’—optimisation of costs, more consumer choice and price competition, and avoiding inefficiencies due to misalignedincentives.[121]

Mandating co-location in return for public funding

3.113Dr Peter Adams, Director, Regional Digital Connectivity Program, Department of Regional NSW claimed from his extensive experience in NSW that mandating conditions on infrastructure co-investment was the only way to ensure multiple carriers share the tower.

…as states and territories we have one lever, which is money, and the Commonwealth has the regulatory levers. So, to answer your question about how we get outcomes as the Commonwealth, and between ACMA, the ACCC and your department there are regulatory levers. … With 36 per cent of New South Wales with absolutely zero coverage and having national spectrum licences that cover that area, if a fourth party wants to come in and use what spectrum is not owned by it, it is difficult for them to get access to that spectrum, even though there is no-one else there.[122]

3.114Ms Rebecca Fox, Secretary, Department of Regional NSW agreed the first key issue for the Australian Government to undertake is the mandate issue:

If it's government funded and we're using taxpayer money at a high level, without getting into any of the technical arrangements, every taxpayer should be allowed to use it and be enabled to use it. We never build a bridge and say, “Only this group of people can go across it.” It doesn't make any sense to me.[123]

3.115Mr Luke Coleman, Head of Government and Corporate Affairs, Vocus Group conceded ‘mandating co-location was difficult because you are effectively forcing another operator to invest in equipment that is installed on a tower’:

There are going to be legitimate reasons why an operator might not want to invest in equipment on a tower; it could be a long way from their existing network and they don't want to build an island of coverage. … That is not something we are proposing here.[124]

3.116However, Mr Coleman proposed that compelling carriers to offer services from publicly funded open-access infrastructure should be considered, noting that the ‘market power issue’ means the economics of building a multi-carrier solution are changed by the refusal of ‘any one carrier’ to be a part of it.[125]

3.117Mr Coleman recalled that in previous funding rounds of the MBSP there had been trials of multi-carrier sites and some were won by Field Solutions Group (FSG):

…so far they have only got one carrier to sign up. So the open-access infrastructure is there—it has been funded by the public and is available to be used—and yet Telstra and TPG refuse to use it. They have raised a number of legitimate reasons why they might not want to be part of it. But this is why we have proposed this concept of requiring mobile carriers to use publicly funded infrastructure. …

The key issue we are trying to break the back of here is carriers with too much market power refusing to be a part of a multicarrier solution. … if a new tower has been built on public funds that is open to be used on an equivalent basis by all carriers, why shouldn't a carrier make that coverage available? We need to find innovative ways to get around this issue of carriers refusing to use this infrastructure when it is made available.[126]

3.118Ms Lim of Commpete Inc recommended the Australian Government ensure ‘competition is always kept as a priority in any design or decision that is made moving forward in relation to the deployment of mobile services as well as the national mobile network as it stands today’:

That is through encouraging regulated access and wholesale, as well as ensuring that there are mandates to ensure open access for any government-funded initiatives, which encourages a diversity of smaller and larger providers and allows new entrants to participate in telecommunications in Australia in the future.[127]

3.119Ms Lim also called on the Government to consider mandating that any co-funded infrastructure must provide active network sharing on an open access basis at prescribed rates to both MNOs and MVNOs,[128] saying that ‘Commpete considers it to be completely unacceptable’ that Australian consumers are denied the benefits of competition ‘as a result of historic ownership of infrastructure by one market participant’.[129]

3.120Mr Brendan Coady, Partner, Maddocks Lawyers; and External Counsel, representing Commpete claimed the ACCC has the power under part XIC of the Competition and Consumer Act (Cth)[130], which deals with the regulation of the telecommunications industry, to ‘conduct an inquiry and declare a service, such as a service that provides open wholesale access to the Telstra network in regional areas’:

That power has been routinely used in relation to regulating the fixed telecommunications network. That sort of regulation is generally required to have competition in the industry.[131]

3.121Mr Coady added the commission might ‘need some direction from government to exercise those powers’.[132]

3.122Ms Penny Griffin, Acting Director, Regional Digital Solutions, WA Department of Primary Industries and Regional Development (DPIRD WA) outlined from Western Australia’s very first mobile infrastructure project back in 2012, mandating for emergency service operators (ESOs) and multiple mobile carriers was a requirement of the state funding:

It is not just co-locating; we have a six-metre capacity reservation on every tower of a usable height. That has been funded under both the Black Spot Program and our first Regional Mobile Communications Project program; that is 400-odd, and it applies to all carriers delivering macro cells.[133]

3.123Ms Griffin insisted the WA mandate worked ‘absolutely’ in regards to interested emergency services organisations using the infrastructure.[134]

The towers are constructed, necessarily, to suit the networks of ESOs [emergency services organisations]. There is an existing radio network; often they are adding on. WA Police, for example, was provided with funding a couple of years ago to expand its radio network into the Kimberley where it had not been before. They made good use of the towers that had been provided under these programs. It is around 65. The towers have to be built for the equipment they want to deploy. … they have to provision the compound to allow space for this—whether or not the emergency services organisations take up this colocation, their right of use. Then it is free rent for up to 15 years. They do not charge an annual leasing fee, either.[135]

3.124Ms Griffin believed the ESO co-location mandate was accepted generally, as part of the social licence to operate, or a community contribution.[136]

Unfortunately, under the Regional Connectivity Program which coincided with the sale or divestment of tower assets, that deal is no longer in place. The ESO co-location rights have not been offered under the Regional Connectivity Program by any carrier, partly because the divestiture was in process. It wasn't clear what could be committed in the long-term because there is a 15-year tail of these rights.[137]

3.125Mr Jayatilleke of One Wifi & Infrastructure, an MNIP, would be recommending the Australian Government consider mandating.

We would, because we are not disadvantaging any single operator, nor advantaging any single operator. We are levelling the playing field. But if not—and there are always exceptions—we are suggesting that any funds released to a single MNO or an MNIP bid should require them to make available access to that site on a benchmarked basis.[138]

3.126Mr Jayatilleke was aware of plenty of organisations that can do the benchmarking.

At the end of the day, our view is it's the public's money or the government's money and, therefore, commercial returns need to be in line with what is reasonable.[139]

…I believe that, if you are trying to address the problem of coverage, competition and choice, I think mandating MNIP-led will absolutely achieve those objectives. … what we're saying is that it should not be handed over to any single carrier.[140]

3.127In a supplementary submission Telstra doubted claims made at public hearings that there would not be ‘any downside to imposing requirements for future co-funded sites to support multiple carriers’:

We don’t believe this would be a “costless” policy direction to take. That is why we continue to advocate for a flexible, multi-faceted approach, which will allow as many potential participants as possible in future programs by matching deployment models to their individual circumstances (and the needs of the relevant regional community), while still seeking to incentivise multi-carrier outcomes where possible.[141]

3.128Telstra reiterated in its supplementary submission some of the most important ‘trade-offs for taxpayers and for regional communities which may be associated with mandating particular multi-carrier requirements’:

The first consideration is the potential impact on MNO incentives to invest in regional mobile infrastructure. Approaches such as mandated domestic roaming … would not deliver more coverage or more competition and would be very harmful to MNO investment incentives.[142]

3.129Telstra raised as a second consideration the ‘impact of these requirements on the cost of the infrastructure’:

This is vital, because if potential bidders cannot make the costs of deployment stack up, they will have no incentive to participate in future programs:

• larger, stronger towers and sites designed to support the equipment of multiple MNOs and to house multiple equipment huts typically cost more; …
• potentially, some of these costs may be avoided where the MNOs are able to share the same active equipment. However, active sharing arrangements involve their own additional costs associated with the need to establish new commercial, technical and operational arrangements between the sharing parties, and to integrate their networks. MNIPs or Neutral Hosts may also lack access to the deployment expertise, economies of scale, established workforces and commercial relationships of MNOs, also potentially adding to their cost of deployment.[143]
  130. Telstra highlighted site deployment costs can ‘vary significantly from site to site, Federal Government funding under the Mobile Blackspot Program has historically been capped at $500,000 per site’:

By contrast, a recent example from NSW saw two ‘neutral host’ towers delivered in an area already covered by Telstra’s mobile network for a cost to government of $5.5 million.[144]

Successful multi-carrier models—local and abroad

3.131As discussed below, two international examples of multi-carrier mobile telecommunications infrastructure models were studied in evidence — in NewZealand (NZ) and in the United Kingdom.

3.132An alternative multi-carrier model commended in evidence is the New South Wales(NSW) Government’s Active Sharing Grants Program, which provides for the construction and operation of active sharing mobile solutions between MNOs, with trial sites in Brewarrina and Wilcannia in regional NSW.

International examples

New Zealand’s Regional Connectivity Group

3.133The Regional Connectivity Group (RCG) is an independent entity established in 2017by the New Zealand Government to build infrastructure for the country’s three mobile operators—Vodafone, Spark and 2degrees—as part of New Zealand’s Rural Broadband Initiative 2 and Mobile Black Spots Fund.[145] DITRDCA explained the RCGis funded by a levy and contributions from the three operators to a total of NZ$225 million to establish 600 cell sites by December 2023:

By April 2022, the RCG had completed more than 325 sites. This has brought connectivity to over 27,650 households and businesses across New Zealand, 68 tourist spots and 742 km of highways.[146]

3.134The RCG uses MOCN (Multi-operator core network) sharing, whereall three operators share spectrum, base station equipment, transmission and passive infrastructure (sites, equipment shelters, towers and mains power) to provide 4Gwireless broadband and mobile services. Operators pay a monthly fee to RCG on a wholesale basis based on the amount of capacity theyneedat each site.[147]

3.135DITRDCA noted RCG manages and monitors capacity, common radio parameter settings and manages common radio backhaul for 4G solutions.[148]

3.136Mr Vin Mullins of Field Solutions Group (FSG) said New Zealand’s RCG was proving more successful at improving regional mobile coverage than Australia, where coverage in dominated by one MNO:

One [reason] is that Kiwis get on a hell of a lot better than Australians do, so those three carriers could sit down and work well together. Also, their networks were pretty much of the same symmetry, of a very similar level, so it's easier to get everyone to play together nicely when there's quite a large mutual benefit across the three organisations.[149]

3.137Mr Jason Horley of Indara said NZ’s RCG was probably the best model for Australia could learn from:

… all three mobile network operators use all of those 400 sites. I think that's a good proof point that the model works and is working successfully…

Locally here, I think one of the key points to consider is that it's such a big difference in the market share in rural and regional areas, particularly remote areas, between Telstra, Optus and TPG. I can see a model like this having very strong appeal to TPG and to Optus…[150]

3.138Mr Trent Czinner, Group Executive, Legal and External Affairs, TPG Telecom said NZ was allocating spectrum for less cost to operators than in Australia, and that revenue was used to support the rollout of infrastructure where it is not commerciallyviable:

The New Zealand approach is progressive and innovative, and we would support the Australian government considering similar ideas for regional and remote areas.[151]

3.139On the other hand, Telstra said the Australian Government’s MBSP had delivered coverage to three times as many sites as NZ’s RCG program over an equivalent period:

Despite commencing in 2017, initial progress by the RCG was slow at least partlyas a result of requiring multi-carrier agreement on sites and priorities. By February 2021, RCG reached 200 sites over more than three years of actual build time. Over the same time period, MNO-led deployment supporting predominantly single carrier coverage under Australia’s MBSP had delivered conservatively three times as many MBSP sites.[152]

3.140Mr Coleman of Vocus Group said co-designing multi-carrier solutions was key to thesuccess of the NZ model, emphasising the need for ‘a degree of buy-in’ from MNOs.[153]

United Kingdom Shared Rural Network

3.141The United Kingdom’s Shared Rural Network (SRN) was established in 2019 by the UK Government, in conjunction with mobile operators Three UK, Vodafone, O2 and EE, to extend 4G mobile coverage to 95 per cent of the UK by 2025.[154]

3.142In March 2020, the UK Government and four MNOs signed the formal agreement setting out how the program would be governed:

The agreement requires each operator to reach 90 per cent geographic coverage by 2025, with mobile coverage obligations on spectrum licensing coming into effect in 2026.[155]

3.143DITRDCA noted the SRN would be funded jointly by the MNOs and the Government:

Collectively, the MNOs will contribute £532 million to the SRN, in order to address partial not-spots, a geographic area with 4G coverage from least one, but not all four mobile network operators. The Government will invest an additional £500 million to provide new mobile masts in areas with no 4G coverage.[156]

The SRN aims to provide coverage to 280,000 premises and 16,000 km of roads, with the biggest improvements expected in Scotland and Wales.[157]

Applicability of New Zealand and UK experience to Australia

3.144DITRDCA noted differences between the Australian, New Zealand and UK mobile markets:

Primarily, the smaller landmass and higher population density in the UK and New Zealand mean on a cost-revenue basis any of the individual MNOs could increase its own mobile coverage, even in non-commercial areas where such investments may require subsidies to proceed. Programs like the New Zealand initiative can deliver substantial coverage improvements for relatively modest funding amounts.[158]

3.145The Department said both the UK and New Zealand have MNOs with comparable market share and coverage with competition occurring through differentiation in features and services, leading to a stronger incentive for MNOs to cooperate to reduce costs to increase coverage.[159]

3.146Mr O'Leary of the Australian Competition and Consumer Commission (ACCC) said NZ’s RCG Program enjoyed buy-in from operators and was built around mobile broadband and wireless coverage.[160]

3.147Dr Joyce said Nokia’s shared technology used in the RCG could be just as effective in Australia:

The technology is no different, whether it's in New Zealand or Australia.

As an operator in the past, the sharing deals that I've been across didn't fall through because of technology; they fell through because people couldn't agree on who should pay what. That's the challenge.[161]

NSW Government’s Active Sharing Grants Program

3.148The NSW Government announced in 2022 it would work with Optus, Telstra, TPG Telecom, BAI Communications, FSG, Infrastructure Logic, NEC and Pivotel Mobile to overcome what then Deputy Premier Paul Toole called a ‘patchwork’ of coverage created by the ‘one tower, one carrier model’.[162]

3.149The NSW Government submitted that its NSW Connectivity Strategy’s priorities include improving regional coverage and performance to metropolitan equivalent levels regardless of carrier, and that innovative operating models are required to meet community needs and the high cost of operating network infrastructure in regional and remote areas.[163]

3.150The NSW Government submitted that it would proactively seek co-investments andpartnerships with the Australian Government, ‘telecommunications carriers, infrastructure investors, and research organisations to deliver innovative, shared infrastructure solutions including active sharing, neutral host models, and emerging connectivity technologies’:

There is a range of alternative future incentives where the States and Territories could partner with the Commonwealth to encourage neutral hosting and active site-sharing that are not in the form of grant investment, such as access to additional under-utilised low band spectrum or waiving spectrum fees.[164]

3.151Ms Rebecca Fox, Secretary, Department of Regional NSW said the NSWprogram had a strong focus on ‘reducing the digital divide by increasing both coverage and competition to ensure that consumers have better coverage and more choice of mobile network providers’.[165]

3.152Ms Fox said more than 36 per cent of NSW has no mobile coverage, and around 26per cent has one mobile provider.[166]

3.153Mr Jayatilleke of One Wifi & Infrastructure said his company had developed a commercially feasible multi-carrier neutral host solution under the NSW Active Sharing Program:

We are now the first operator under the … program to implement a carrier neutralmulticarrier solution that preserves mobile operators' autonomy and product differentiation. Site deployment works have already commenced, and we estimate the first mobile active neutral host site will be ready for service next month, only three months after officially being engaged by the department.[167]

3.154Mr Jayatilleke said neutral host active sharing provided a commercially viable solution for coverage in thin markets:

The benefits of active neutral host are manyfold but at the core it is cost optimisation; the ability to do more with the same pool of funds through sharing both passive and active infrastructure. The sharing of power and backhaul removes unnecessary duplication and reduces costs by 50 per cent, while also reducing carbon footprint. It also reduces active radio equipment, which saves another 25 per cent. This improves the business case to facilitate multiple operators playing in these markets.[168]

3.155Mr Jayatilleke said MNOs’ retained their autonomy under neutral host active sharing:

In terms of the technical architecture, we are not asking the carriers to pool their spectrum. We are not asking them to have the same service delivered. They can differentiate their service through their different ratio of backhaul transmission and different frequency bands that they want to transmit. … We are not trying toprescribe to them how they should run the service.[169]

3.156Mr Jayatilleke said One Wifi’s neutral host model in regional NSW (being rolled out initially in Brewarrina and Wilcannia) will be suitable for provision of mobile coverage in other sparsely populated areas.[170]

3.157Mr Coleman of Vocus Group urged the Australian Government to follow the NSW Government’s example:

Their efforts to create a multicarrier coverage program are something that I think the Commonwealth should take as an example, to have a multicarrier designed program.[171]

3.158Dr Peter Adams, Director, Regional Digital Connectivity Program, Department of Regional NSW said governments should take a firmer approach with mobile providers regarding the outcomes they expect:

If the government is paying 100 percent-plus of the costs, it is well within ourremit of, and of value to the taxpayers, to say, 'This is the outcome that government wants, and if you don't want to play ball we will open the market up to people who do'.[172]

3.159Ms Fox said she could use her phone across the world seamlessly ‘yet domestically there are a string of reasons why coverage can't be shared in areas acknowledged as uneconomic, except if government funds a single operator’. She said achieving better outcomes for regional citizens was a ‘commercial challenge, not a technical one’:

Technical barriers are often presented to dismiss sharing options but, really, the commercial dynamics drive decision-making. A second learning is that the market finds it difficult to self-organise around solving this issue. The current market structure does not encourage new entrants or innovative solutions, and those commercial dynamics again play a role.[173]

3.160Dr Adams proposed a joint federal and state government funded trial of neutral host and active sharing arrangements along a proposed tourism route to the west of Newell Highway:

That is the perfect place for us to work collaboratively together, put our money in, and essentially enforce this standard of neutral host and active sharing. We'll use it essentially as a large-scale trial to get the outcomes that we're looking for…[174]

Committee comment

3.161The Committee heard compelling evidence from a broad range of witnesses with ideas to encourage competition, based on a range of models for multi-carrier mobile infrastructure. The Committee was also interested to hear about practical examples ofmulti-carrier models and co-investment in New South Wales, New Zealand and theUnitedKingdom.

3.162It is clear to the Committee that commercial imperatives, where carriers seek to maximise profit to shareholders, are the key impediment to achieving multi-carrier objectives in regional and remote Australia. Even when shared infrastructure is provided, carriers will make commercial assessments as to the desirability of providing services to markets they consider thin in terms of return-on-investment, and this still leads to carriers deciding not to proceed. Other matters – technical and operational considerations, policy and regulatory settings, jurisdictional issues and other factors also serve to inhibit the deployment of multi-carrier solutions, but the big one is there just isn’t enough money to be made from servicing the bush.

3.163The Committee believes the Government has an essential leadership and coordination role to play, to bring together infrastructure providers, mobile carriers, regulators, and other interested parties to manage future funding and co-investment programs, as well as examine potential policy and regulatory changes related to multi-carrier infrastructure. Where there is market failure, Government must step in to ensure Australians living and working in regional and remote communities are connected.

3.164The Committee notes evidence from witnesses that technology is changing fast and previous infrastructure funding models have been overly prescriptive, limiting the scope for innovative, agile and bespoke solutions.

3.165The Committee recommends the Australian Government establish a working group involving mobile network operators, infrastructure providers, regulatory bodies, and relevant government agencies to address technical, regulatory, and policy barriers to the adoption and deployment of multi-carrier mobile network infrastructure across regional and remote Australia, and to provide input on future funding and co-investment programs that allow for innovation and focus on outcomes.

3.166The Committee considers there is a role for Government to support trial programs to identify promising technologies and funding models. Consultation on the parameters of any trial programs could take place through the working group recommended above.

3.167The Committee sees merit in the Government leveraging co-funding of new mobile infrastructure by trialling mandates to ensure active network sharing on an open access basis for a diversity of providers and carriers. It is hoped these trials can encourage new entrants to participate in Australia’s regional telecommunications.

3.168The Committee recommends the Australian Government establish a trialprogram to fund mobile carrier infrastructure in specific regional and remote geographical areas with a mandate for open access through active or passive sharing to any funded infrastructure.

3.169The Committee considers the Australian Government could benefit from participating in future trials under the New South Wales Government’s Active Sharing program, leveraging the good work done to date. Outcomes could help inform the optimal way forward for federal telecommunications infrastructure investment.

3.170The Committee recommends the Australian Government work with the New South Wales Government to develop more extensive trials of active infrastructure sharing solutions in regional New South Wales, including along road corridors and in remote Indigenous communities.

3.171The Committee also supports the proposition that funding from future rounds of theMBSP and the RCP be allocated to expedite trials of new active-sharing technologies or network roaming to address connectivity and coverage gaps in regional and remote locations.

3.172The Committee recommends the Australian Government consider allocating dedicated funding through programs such as the Mobile Black Spot Program and the Regional Connectivity Program for co-investment in trial sites to demonstrate the feasibility of technical and commercial models for multi-carrier mobile network sharing.

3.173Lastly, the Committee supports trialling new multi-carrier mobile network sharing models in the context of addressing connectivity gaps along major roads in regional and remote areas, and in adjacent communities.

3.174The Committee recommends the Australian Government establish a trialprogram to fund infrastructure to support multi-carrier mobile network sharing models at locations on major roads in regional and remote areas with limited or no contiguous network coverage.

Footnotes

[1]Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), Submission23, p. 9.

[2]Nokia, Submission 12, p. 4. (Higher frequency bands which 5G technology utilises, have shorter transmission reach and thus require more infrastructure points.)

[3]Nokia, Submission 12, pp. 4–5.

[4]DITRDCA, Submission23, p. 10.

[5]DITRDCA, Submission23, p. 11.

[6]DITRDCA, Submission23, p. 11.

[7]Mr Jason Horley, Indara Digital Infrastructure (Indara), Committee Hansard, 23 November 2022, p. 2.

[8]Nokia, Submission 12, p. 5.

[9]DITRDCA, Submission 23, p. 10.

[10]DITRDCA, Submission23, p. 10.

[11]Mr Greg Preuss, Optus, Committee Hansard, 14 April 2023, pp. 2–3.

[12]Mr Jon Lipton, Amplitel, Committee Hansard, 8 March 2023, p. 2.

[13]Ms Michelle Lim, Chair, Commpete Inc. (Commpete), Committee Hansard, 26 May 2023, p. 15.

[14]Mr Grahame O’Leary, Australian Competition and Consumer Commission (ACCC), Committee Hansard, 26May 2023, pp. 45–46.

[15]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 34.

[16]Nokia, Submission 12, pp. 5–6.

[17]Mr Jason Horley, Indara, Committee Hansard, 23 November 2022, p. 2.

[18]Mr Peter Bolger, Pivotel, Committee Hansard, 26 May 2023, p. 22.

[19]Mr Gary Bhomer, Pivotel, Committee Hansard, 26 May 2023, p. 22.

[20]Mr Gary Bhomer, Pivotel, Committee Hansard, 26 May 2023, p. 22.

[21]DITRDCA, Submission23, p. 11.

[22]Dr Robert Joyce, Nokia, Committee Hansard, 26 May 2023, p. 48.

[23]Mr Ian Miller, Australian Radio Communications Industry Association (ARCIA), Committee Hansard, 7June2023, p.8.

[24]Nokia, Submission 12, p. 6.

[25]Nokia, Submission 12, p. 6.

[26]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 32.

[27]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 32.

[28]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 33.

[29]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 33.

[30]One Wifi & Infrastructure, Submission26, p. 1.

[31]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 35.

[32]Commpete, Submission7, p. 6.

[33]Commpete, Submission 7, p. 6.

[34]Field Solutions Group, Submission 32, p. [4].

[35]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, p. 1.

[36]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, p. 3.

[37]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, p. 4.

[38]FSG, Submission 32, p. 4

[39]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, p. 1.

[40]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, p. 5.

[41]Ms Elyssa Rollinson, BAI Communications, Committee Hansard, 26 May 2023, p. 15.

[42]Ms Elyssa Rollinson, BAI Communications, Committee Hansard, 26 May 2023, p. 23.

[43]Mr Trent Czinner, TPG Telecom (TPG), Committee Hansard, 26 May 2023, p. 25.

[44]Mr Trent Czinner, TPG Telecom, Committee Hansard, 26 May 2023, p. 27.

[45]Mr Trent Czinner, TPG Telecom, Committee Hansard, 26 May 2023, p. 28.

[46]Mr Grahame O’Leary, ACCC, Committee Hansard, 26 May 2023, p. 40.

[47]Ms Tara Morice, ACCC, Committee Hansard, 26 May 2023, p. 42.

[48]Mr Grahame O’Leary, ACCC, Committee Hansard, 26 May 2023, p. 38.

[49]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 2.

[50]Nokia, Submission 12, p. 6.

[51]Nokia, Submission 12, p. 6.

[52]ACCAN, Submission 4, p. 4.

[53]DITRDCA, Submission23, p. 10.

[54]Mr Trent Czinner, TPG Telecom, Committee Hansard, 26 May 2023, p. 25.

[55]Mr Andrew Roberts, FSG, Committee Hansard, 14 June 2023, pp. 1–2.

[56]Mr Andrew Sheridan, Optus, Committee Hansard, 14 April 2023, p. 4.

[57]Mr Andrew Sheridan, Optus, Committee Hansard, 14 April 2023, p. 4.

[58]Mr Andrew Sheridan, Optus, Committee Hansard, 14 April 2023, p. 4.

[59]Mr Andrew Sheridan, Optus, Committee Hansard, 14 April 2023, p. 4.

[60]Ms Jan Ferguson, Outback Communities Authority, Committee Hansard, 15 May 2023, p. 27. See also: MrStephen McCarthy, District Council of Mount Remarkable, Committee Hansard, 15 May 2023, p. 16.

[61]Mr Andrew Briggs, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, p. 2.

[62]Telstra, Submission 14.1, p. 2.

[63]Telstra, Submission 14.1, p. 2.

[64]Telstra, Submission 14.1, p. 2.

[65]Telstra, Submission 14.1, p. 2.

[66]Telstra, Submission 14.1, p. 2.

[67]Telstra, Submission 14.1, pp. 2–3.

[68]Telstra, Submission 14.1, p. 3.

[69]Telstra, Submission 14.1, p. 3.

[70]Mr James Toole, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, p. 1.

[71]Mrs Tracy Lefroy, GrainGrowers Ltd, Committee Hansard, 17 May 2023, p. 13.

[72]Mrs Tracy Lefroy, GrainGrowers Ltd, Committee Hansard, 17 May 2023, p. 13.

[73]DITRDCA <www.infrastructure.gov.au/media-communications-arts/better-connectivity-plan-regional-and-rural-australia/farm-connectivity-program#:~:text=The%20Australian%20Government%27s%20On%20Farm,connected%20machinery%20and%20sensor%20technology> viewed 28 July 2023.

[74]Mrs Tracy Lefroy, GrainGrowers Ltd, Committee Hansard, 17 May 2023, p. 13.

[75]Indara Digital Infrastructure, Submission 24, p. 7.

[76]Indara Digital Infrastructure, Submission 24, p. 7.

[77]Indara Digital Infrastructure, Submission 24, p. 7.

[78]Telstra, Submission 14, p. 10.

[79]Telstra, Submission 14, p. 10.

[80]Mr Bill Gallagher, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, p. 2.

[81]Telstra, Submission 14, p. 10.

[82]Telstra, Submission 14, p. 10.

[83]Mr Bill Gallagher, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, p. 2.

[84]Mr Bill Gallagher, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, pp. 2–3.

[85]Mr James Toole, Telstra Corporation Ltd, Committee Hansard, 22 March 2023, p. 3.

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

[87]Mr Jon Lipton, Amplitel, Committee Hansard, 8 March 2023, p. 1.

[88]Mr Jon Lipton, Amplitel, Committee Hansard, 8 March 2023, p. 2.

[89]Indara Digital Infrastructure, Submission 24, p. 5.

[90]Indara Digital Infrastructure, Submission 24, p. 5.

[91]Mr Jason Horley, Indara, Committee Hansard, 23 November 2022, p. 2.

[92]Mr Matt Healy, Healy Advisory, Committee Hansard, 23 November 2022, p. 2.

[93]Indara Digital Infrastructure, Submission 24, p. 5.

[94]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 1.

[95]Mr Eamonn McCabe, Department of Primary Industries and Regional Development, WA Government (DPIRD WA), Committee Hansard, 17 May 2023, p. 2.

[96]Mr Eamonn McCabe, DPIRD WA, Committee Hansard, 17 May 2023, p. 2.

[97]Ms Jan Ferguson, Outback Communities Authority,Committee Hansard, 15 May 2023, p. 23.

[98]Ms Jan Ferguson, Outback Communities Authority, Committee Hansard, 15 May 2023, p. 23.

[99]ACCAN, Submission 4, p. 4.

[100]ACCAN, Submission 4, p. 5.

[101]Ms Michelle Lim, Commpete Inc., Committee Hansard, 26 May 2023, p. 14.

[102]Ms Michelle Lim, Commpete Inc., Committee Hansard, 26 May 2023, p. 15.

[103]Mr Jon Lipton, Amplitel, Committee Hansard, 8 March 2023, p. 2.

[104]Mr Jon Lipton, Amplitel, Committee Hansard, 8 March 2023, p. 4.

[105]Optus, Submission 35, p. 5.

[106]Optus, Submission 35, p. 5.

[107]Optus, Submission 35, p. 5.

[108]DITRDCA, Submission23, p. 11.

[109]DITRDCA, Submission23, p. 11.

[110]DITRDCA, Submission23, p. 11.

[111]Mr Andrew Sheridan, Optus, Committee Hansard, 14 April 2023, p. 3.

[112]Mr Greg Preuss, Optus, Committee Hansard, 14 April 2023, p. 3.

[113]Vocus, Submission37, p. 1.

[114]Vocus, Submission37, p. 2.

[115]Mr Peter Bolger, Pivotel, Committee Hansard, 26 May 2023, p. 16.

[116]Indara Digital Infrastructure, Submission 24, p. 8.

[117]Indara Digital Infrastructure, Submission 24.1, p. 1.

[118]Indara Digital Infrastructure, Submission 24.1, p. 2.

[119]Indara Digital Infrastructure, Submission 24.1, p. 2.

[120]Indara Digital Infrastructure, Submission 24.1, pp. 1–2.

[121]OneWifi & Infrastructure, Submission 26, p. 1.

[122]Dr Peter Adams, Department of Regional NSW, Committee Hansard, 26 May 2023, p. 57.

[123]Ms Rebecca Fox, Department of Regional NSW, Committee Hansard, 26 May 2023, p. 57.

[124]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 3.

[125]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 3.

[126]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 3.

[127]Ms Michelle Lim, Commpete Inc., Committee Hansard, 26 May 2023, p. 23.

[128]Ms Michelle Lim, Commpete Inc., Committee Hansard, 26 May 2023, p. 23.

[129]Ms Michelle Lim, Commpete Inc., Committee Hansard, 26 May 2023, p. 15.

[130]Competition and Consumer Act 2010 (Cth), Part XIC.

[131]Mr Brendan Coady, Maddocks Lawyers; representing Commpete, Committee Hansard, 26 May 2023, p. 23.

[132]Mr Brendan Coady, Maddocks Lawyers; representing Commpete, Committee Hansard, 26 May 2023, p. 23.

[133]Ms Penny Griffin, DPIRD WA, Committee Hansard, 17 May 2023, p. 5. See also: Mr Eamonn McCabe, DPIRD WA, Committee Hansard, 17 May 2023, p. 2.

[134]Ms Penny Griffin, DPIRD WA, Committee Hansard, 17 May 2023, p. 6.

[135]Ms Penny Griffin, DPIRD WA, Committee Hansard, 17 May 2023, p. 6.

[136]Ms Penny Griffin, DPIRD WA, WA Government, Committee Hansard, 17 May 2023, p. 6.

[137]Ms Penny Griffin, DPIRD WA, Committee Hansard, 17 May 2023, p. 6.

[138]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 37.

[139]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 37.

[140]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 37.

[141]Telstra, Submission 14.1, p. 4.

[142]Telstra, Submission 14.1, p. 4.

[143]Telstra, Submission 14.1, p. 4.

[144]Telstra, Submission 14.1, p. 4.

[145]Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), Submission23, p. 12.

[146]Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), Submission23, p. 12.

[147]DITRDCA, Submission23, p. 12. See also: Dr Robert Joyce, Nokia, Committee Hansard, 26 May 2023, p.52.

[148]DITRDCA, Submission23, p. 12.

[149]Mr Vin Mullins, Field Solutions Group (FSG), Committee Hansard, 14 June 2023, p. 6.

[150]Mr Jason Horley, Indara, Committee Hansard, 23 November 2022, p. 3.

[151]Mr Trent Czinner, TPG Telecom, Committee Hansard, 26 May 2023, p. 25.

[152]Telstra, Submission 14, p. 7.

[153]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 6.

[154]DITRDCA, Submission23, p. 12.

[155]DITRDCA, Submission23, p. 12.

[156]DITRDCA, Submission23, p. 12.

[157]DITRDCA, Submission23, p. 13.

[158]DITRDCA, Submission23, p. 13.

[159]DITRDCA, Submission23, p. 13.

[160]Mr Grahame O’Leary, ACCC, Committee Hansard, 26 May 2023, p. 42.

[161]Dr Robert Joyce, Nokia, Committee Hansard, 26 May 2023, p. 52.

[162]DITRDCA, Submission23, p. 14.

[163]New South Wales Government, Submission 25, p. 1.

[164]New South Wales Government, Submission 25, p. 2.

[165]Ms Rebecca Fox,Department of Regional NSW, Committee Hansard, 26 May 2023, p. 54.

[166]Ms Rebecca Fox,Department of Regional NSW, Committee Hansard, 26 May 2023, p. 54.

[167]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 32.

[168]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 32.

[169]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 33.

[170]Mr Mevan Jayatilleke, One Wifi & Infrastructure, Committee Hansard, 26 May 2023, p. 34.

[171]Mr Luke Coleman, Vocus Group, Committee Hansard, 26 May 2023, p. 6. See also: Mr Gary Bhomer, Pivotel, Committee Hansard, 26 May 2023, p. 19.

[172]Dr Peter Adams, Department of Regional NSW, Committee Hansard, 26 May 2023, p. 56.

[173]Ms Rebecca Fox,Department of Regional NSW, Committee Hansard, 26 May 2023, p. 55.

[174]Dr Peter Adams, Department of Regional NSW, Committee Hansard, 26 May 2023, p. 59.