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Western Australian Government

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  • 1. Submission to Australian Communications Authority Review of Australia’s Payphone Policy October 2003
  • 2. Terms of reference In conducting this review, the ACA will examine and make recommendations in relation to: 1) The role of payphones a. The various services provided by payphones, including convenience of telephone access in public places; access to emergency services; and provision of basic telecommunications access to those otherwise lacking it. b. The role of payphones today and in future, including for specific user-groups such as low-income groups, remote Indigenous communities, people with disabilities, users without mobile phones and users in areas without terrestrial mobile phone coverage. 2) The current and likely future structure of the market for services provided by payphones: a. Number of payphones and suppliers in the market. b. Geographical distribution of payphones. c. Revenue and cost structures of payphone provision. d. Functionality of payphones supplied. e. Current and likely future market for substitutes and complements. f. Current state of competition in the payphone market. g. Level and distribution of demand. h. Likely changes in payphone demand over time given greater access to substitutes, changing technologies and new services. 3) The role of the competitive market in payphone provision: a. Impact of regulation on competition, including: i. Effect of price caps on calls from public payphones; ii. Interaction of the Universal Service Obligation (USO) and the competitive market; and iii. Benefits of being the Primary Universal Service Provider (PUSP). b. Performance of the competitive market in addressing community needs, including those of special user groups. c. Commercial viability of payphone provision in the current environment. 4) Developing policies for access to the services provided by payphones and appropriate levels of service: a. Future policy options for access to the services provided by payphones (possibly including the use of technologies and services other than payphones) that is commensurate with community needs while facilitating greater competition and commercial viability. b. Appropriate arrangements for determining the location of payphones; i. Processes for determining optimal numbers and location of payphones; and ii. Criteria including financial arrangements for installation, resiting and removal of payphones. c. Appropriate access and service objectives for future payphone provision given current gaps in accessibility and changing supply and demand, including: i. Functionality of payphones; ii. Levels of accessibility for people with a disability; iii. Levels of accessibility for people in Indigenous communities; iv. Consumer awareness of reasonable access to payphones; and v. Performance and monitoring arrangements. Payphone Submission – WA Government 2
  • 3. d. Whether Telstra’s policies (as universal service provider) remain effective at providing access to payphone services including: i. with regard to the distribution and number of payphones supplied; ii. with regard to provision of payphones for people with disabilities and remote Indigenous communities; and iii. whether the criteria and process for installation, resiting and removal of payphones at a particular site are appropriate and sufficiently objective. e. Performance and monitoring of payphone provision under the USO: i. Role of the ACA in performance monitoring; ii. Level of performance in installation, resiting, removal and repair of payphones; iii. Level of performance achieved in Quality of Service and appropriate functionality terms; iv. Current causes of low performance; and v. Whether existing arrangements adequately address systemic issues. Payphone Submission – WA Government 3
  • 4. Introduction The Western Australian State Government welcomes the opportunity to have input to the Australian Communications Authority (ACA) review of Australia’s payphone policy. The focus of the submission is on the necessity for the ongoing needs of the user to be taken into consideration in the development and implementation of payphone policy. Mobile phones are not a realistic alternative for regional, rural and remote Western Australians; just as they are not for many of the groups reliant on payphones as their primary or supplementary means of electronic communication. Consequently payphones will continue to play an important role in the lives of a small but important proportion of the population. 1) The role of payphones Payphones in Western Australia appear to be used by the following population groups: • Those without a telephone service in their own home, including many of the Indigenous community; • Those whose home telephone service is not working, and who do not have access to a mobile phone; • Youth who wish to make phone calls in greater privacy than their home phone will allow; • The travelling public, whether residential or business, with no access to mobile phone coverage; and • Those in emergency situations. This may or may not be life- threatening. For example, in the case of a vehicle breakdown, a call will not need to be made to a recognised emergency service, but often just to a garage or relative. Toll-free 000 numbers are often not the calls that need to be made in these circumstances. The groups that use the payphone in place of a home phone, and who use it regularly, are likely to take advantage of phone card options. However the people whose home phone is not working and those in emergency situations – and often the travelling public – will be relying on coins to make their calls. This needs to be borne in mind when considering the conversion of payphones to card-only phones. Due to safety concerns with overseas travel, there are increasing numbers of Australians who are now holidaying within Australia. Many – including retirees – take the opportunity to see more of Australia. These people are major users of payphones, especially in areas where there is no mobile phone coverage. For Western Australia, this is over 85% of the State. The poor geographic coverage by terrestrial mobile phones is evident in the maps attached in Appendix 1. Payphone Submission – WA Government 4
  • 5. Payphones are particularly important in Indigenous communities, where few residents have a private phone. For many of these users, a card phone is a convenient option, and one that often removes the temptation for others to vandalise the phone and thus make it unusable. 2) The current and likely future structure of the market for services provided by payphones Mobile phone coverage is unlikely to extend significantly further in Western Australia than exists currently, so there will be a continuing need for payphones in rural and remote areas. Satellite phones do not offer a true substitute for terrestrial mobile phones, being far more expensive to purchase (even with a subsidy) and to operate. Internet-based communication, whether by email or by Voice Over IP, is a potential substitute, but is more likely to provide for those in the higher socio- economic groups and in urban centres. In considering future demand patterns, it is important to consider the different needs of the key user groups, and their likely access to substitutes. Despite efforts to introduce more appropriate options for Indigenous communities, it is unlikely that a majority of the Indigenous population will have their own telephones for many years to come. Payphones will remain a prime means of communications for many in these communities. While mobile phone ownership continues to grow among the young, the economically disadvantaged and people in areas without mobile coverage will continue to rely on the payphone for social interaction. Travellers are another group who are likely to continue to rely on payphones when outside mobile coverage areas. 3) The role of the competitive market in payphone provision Many of the payphones in regional Western Australia are likely to be provided only because of Telstra’s Universal Service Obligation (USO). There is not, and there is unlikely to be, any real competition in this market. The Department of Industry and Resources has recently undertaken a comprehensive examination of the communications needs of regional Western Australians. During the last quarter of 2002, public consultations were held in 42 locations throughout the State. Some of the information gleaned in relation to payphones is included in Appendix 2. The extracts clearly indicate the issues being experienced in terms of adequacy of supply, location and repair. Many communities do not feel that Telstra is responsive to their needs. Payphone Submission – WA Government 5
  • 6. 4) Developing policies for access to the services provided by payphones and appropriate levels of service In developing policy options regarding payphones it is vital that the users of the service are consulted both in policy development and in implementation. The user groups identified will have different needs. For example, for people using the phone regularly near their home, a phone-card service is likely to be beneficial as vandalism is less likely to occur. However, it is essential that people have ready access to phone card outlets. Many small Indigenous communities do not have retail outlets, and those that do may not be open when the need to purchase a card occurs, and so a card-operated phone is of more limited value. For those who use payphones less regularly, coin-operated phones will continue to be necessary unless there is a major, and successful, awareness program and 24-hour access to cards. Phone cards should have no expiry date. Siting of the phones is critical to ensure ready access. During our consultations, a lack of responsiveness to requests to move the payphones to cater for changes in the layout and population growth of the community was evident. In Warmun, approximately forty people live on the far side of the creek and are cut off from the rest of the town during the wet season when the creek floods. These people then have no access to telephone services. There must be provision for the twenty-adult minimum to be modified in circumstances like this. Communities must be consulted about the best location for payphones, and how they can be managed to minimise vandalism. In this way the community is more likely to take ownership of, and be satisfied with, the outcome, resulting in optimal outcomes for all parties. Whereas regular users are likely to know where the payphones are located in their vicinity, for many others this is unknown. Despite Telstra’s objections, payphone locations should be printed in telephone directories as well as being available on the internet. Internet-only listings will not benefit the majority of the target groups that use payphones. A significant proportion of payphones are not likely to be moved in a twelve-month period, so a clause indicating the date that the information was valid and a best endeavours statement should be sufficient to cover those instances where the payphone is no longer available at that location. Each payphone should include the addresses of the nearest available alternative payphones, just as is done for many Automatic Teller Machines. The consultation comments in Appendix 2 clearly identify gaps in the current effectiveness of the USO and its implementation. Monitoring does not appear to be sufficient. Payphone Submission – WA Government 6
  • 7. The knowledge of USO provisions regarding payphones is minimal in the community. There is lack of awareness of entitlements to new payphones, repair times and Telstra’s role in consulting with local communities. The “as far as practicable” needs to be removed form the undertaking to consult. Conclusion In summary, payphones continue to provide an essential communications service to particular segments of the population. Policy solutions must be developed and implemented with particular regard to the disparate needs of these people. There must be improved consultation with local communities over the number, location, resiting and maintenance of payphones, as well as the type. However, the needs of non-regular users of payphones also have to be considered if moves are made towards card-only solutions. More has to be done to increase awareness of payphone universal service obligations and regulated maintenance repair times among consumers. In addition, the location of payphones must be publicly available to meet the needs of the people they are designed to serve. Payphone Submission – WA Government 7
  • 8. CONTACTS Sheryl Siekierka State Development Strategies Phone: (08) 9222 5677 Department of Industry and Resources Fax: (08) 9222 5460 2 Havelock Street Email: sheryl.siekierka@doir.wa.gov.au WEST PERTH WA 6005 Dan Scherr State Development Strategies Phone: (08) 9222 5675 Department of Industry and Resources Fax: (08) 9222 5460 2 Havelock Street E-mail: dan.scherr@doir.wa.gov.au WEST PERTH WA 6005 Payphone Submission – WA Government 8
  • 9. APPENDIX 1: MOBILE PHONE COVERAGE MAPS FOR WESTERN AUSTRALIA Payphone Submission – WA Government 9
  • 10. TELSTRA – CDMA COVERAGE Payphone Submission – WA Government 10
  • 11. TELSTRA – GSM COVERAGE Payphone Submission – WA Government 11
  • 12. VODAFONE – GSM COVERAGE Payphone Submission – WA Government 12
  • 13. OPTUS – GSM COVERAGE Payphone Submission – WA Government 13
  • 14. Payphone Submission – WA Government 14
  • 15. APPENDIX 2: REGIONAL WESTERN AUSTRALIAN INPUT ON PAYPHONES During the last quarter of 2002, a team from the Department of Industry and Resources travelled throughout regional Western Australia consulting with local residents and businesses regarding their telecommunications needs. The final report, Telecommunications Needs Assessment: the communication needs of regional Western Australians, was published in August 2003, and is available at www.doir.wa.gov.au. The following are extracts from the consultation notes taken during this study. Payphone Submission – WA Government 15
  • 16. DAMPIER PENINSULAR Indigenous Communities (north of Broome in the Kimberley) One Arm Point – Needs more public phones. Vandalism is a problem, so often phones don’t work. Beagle Bay – One public phone needs to be relocated to reduce vandalism. Need to have two to three more. Have two payphones for 350 – 400 people. BROOME (Kimberley) At the Hamersley Road phone boxes in Broome, phone users can’t hear for the traffic noise. Vandalism is a problem in communities. Telstra is trying hard to keep up. There needs to be more phones. Jigalong – only one pay phone in whole community. Similar in other communities. (Jigalong is an Aboriginal community with a population of approximately 300.) DERBY (Kimberley) One payphone at Mt Barnett at the store – works sometimes, other times doesn’t. This is not related to vandalism. There is limited capacity to the lines to the communities, so overload occurs. Can’t get through, particularly early in the mornings. Capacity is insufficient – it has been made worse since people have started using the Internet and email. This applies to Gibb River Road communities. At Biridu between Derby and Broome, the cost is $1000 to get a phone. Can’t get a public phone in a community of 15-20 people. Have to go out on road and flag someone down if there is an emergency. There are no emergency phones for long distances along the road – big stretches in the Kimberley and Pilbara. There are only two roadhouses in a 600 km stretch. There is a danger of hitting cows – have to wait for the next car for help. In the wet season this can be a long wait. Remote communities need a better coin management system. Payphones are often full and do not operate. This is a regular problem along Gibb River Road. Also at the Burrabi community and on Drysdale Station. Apart from Drysdale, you can’t buy phone cards in the communities. This is an issue for replacement of coin phones by card phones. Payphone Submission – WA Government 16
  • 17. FITZROY CROSSING (Kimberley) There is a move away from payphones in communities. Putting normal phones in homes. The community pays the bills but this limits vandalism. One house has a phone installed that is a community phone. Paid for by all of the community. Works well. Less vandalism but disrupts life of householder. With payphones someone has to be responsible for telephone box – cleaning, emptying money etc. Still problems with vandalism in some larger communities. It takes a long time to get serviced. Had to get two payphones moved last year as the layout of the community had changed – it took a year to get done. HALLS CREEK (Kimberley) Safety issues: The payphones are only located in the old areas of town, not the new. The majority of local residents do not have a phone. There are two payphones in the main street, and two at the shire offices. There are none in the “Garden Area”. The person with a phone in this street keeps on getting people knocking on the door to use their phone. They have been waiting two years for the additional payphones. This (the “Garden Area”) is a long road servicing fifty odd houses. It is a volatile area. The phones are likely to be vandalised but still there is a definite need. Telstra has been out on a number of occasions to assess the location. Need to consider design of public phones. Should be card system, not coins, and should be built simply. Current concept is wrong – they are attractive to children. Kids get the phones to jam. WARMUN (Kimberley) Aboriginal settlement at Turkey Creek. 450 residents rising to 600 during the wet season. There are two payphones in community – one by shop, and one down the end. The other side of Turkey Creek needs a service (40 people) – they get cut off when the creek floods. They have applied for 2 more phones – Telstra is reluctant as high maintenance. Council has a plan – looking at the possibility of getting Gold Phones or Blue Phones. There are five family groups in the community – if each family group could be given access to one by it being placed in the house of a leader, it may solve many of the problems. Worth a go. Payphone Submission – WA Government 17
  • 18. There is a constant stream of people walking to phones at local service station. There are no street lights – this is very dangerous with traffic on the road at night. This is a safety issue. There needs to be more payphones so people can call the health clinic. WYNDHAM (Kimberley) The payphones are broken all the time. There are two at the Post Office, and one at the caravan park. There was one at the port but this got torn out and thrown in the water, and hasn’t been replaced. There is a Gold Phone at the Community Club. There is often a 2-3 day wait for repairs to the payphone at the Community Club. This is a real issue for calling taxis etc. The Club is located five miles from town. They only seem to fix it when they are here (not a special trip). There is a problem here with specialisation as well – the crew has come over and looked at it in response to a fault report, only to say they weren’t trained to fix a gold phone and someone else needed to come out. This took another 3 days – Friday to Monday. This is the busiest time of the week for the Country (Community) Club. YANDAYARRA (Aboriginal community in the Pilbara) The coin-operated payphones get broken into, but there is no problem with the card-operated ones. Can take from 3-4 days to several weeks to repair. The community suggests all card phone boxes would be appropriate for them. NULLAGINE (Pilbara) Tourists use two pay phones (coin/card), which are vandalised. Payphones in the Aboriginal village are not vandalised. It takes approximately 3-4 days to get repairs. There was an experiment with a solar-powered Dorophone payphone that was installed at the caravan park. This was unsuccessful. The caravan park has approximately 100 visitors on a winter weekend; there are four times as many people in town in June as at Xmas. This transient demand needs to be considered in payphone decisions. CARNARVON (Gascoyne) There are two public phones in Carnarvon: why are they side-by-side? There are more on the way, including TTY. Payphone Submission – WA Government 18
  • 19. WILUNA (Gascoyne) The payphones are in disrepair. A nun tried to reach a colleague and the line cut off after making a connection. The colleague thought there was an emergency and desperately tried to reach her. NORSEMAN (DUNDAS SHIRE) (Goldfields-Esperance region) Payphones are used widely in Eucla because of the lack of mobile coverage on both sides of the border. MENZIES (Goldfields-Esperance region) Menzies is very small and on its own would be very difficult to justify services, but there is considerable passing traffic. There are 120 – 130 in the town, 70 – 80% are Aboriginal. Menzies has one payphone. There are some problems with vandalism but they have no complaints. The Hotel licensee looks after the payphone. LAVERTON (Goldfields-Esperance region) There appears to be sufficient payphones in the shire. There are four in town opposite the police station, and each Aboriginal community has a payphone. There is some vandalism, but generally this is not a problem and the phones are well used. KALGOORLIE (Goldfields-Esperance region) Vandalism of payphones is a problem in town. The Ambulance Service has been concerned that there is no payphone for a dry indigenous community outside the town. Apparently there is a considerable distance to walk before you can use a phone. LEONORA (Goldfields-Esperance region) Leonora has caged payphones in the main street – these phones are in working order. Recently a payphone was removed from Gwalia following vandalism. Telstra also removed the concrete slab. This is/was the only payphone in the area. This is a problem as they are trying to promote the area as a tourist precinct. Payphone Submission – WA Government 19
  • 20. WIDGIEMOOLTHA (Goldfields-Esperance region) The lone public phone located at the Widgiemooltha Road House is reliant on generator power for its operation. The generator is switched off at night, so the payphone is unavailable between 11.30 pm and 7.00 am. Given the limited mobile phone service coverage between Norseman and Coolgardie, this adds to the risk in emergency situations. MERREDIN (Wheatbelt) There is a high usage of payphones in the area, although it was noted no one in the community takes on the responsibility of looking after it. It used to be the post office that was paid by Telstra but not any more. Maintenance standards have slipped. KATANNING (Great Southern) Telstra has removed a lot of payphones but the coverage is still okay. There is a big damage bill. The ones in the main street of Katanning are always being replaced. People smash the glass. The need for public phones is being replaced in this area by people having mobile phones. BODDINGTON (Peel) There are two payphones out in front of the Shire offices, one at the caravan park, one at Crossman, two at Halfway House and one at another roadhouse. Unsure of the number in Quindanning. There is good coverage by payphones in this area. NORTHCLIFFE (South West) There are two public phones in Northcliffe; one that operates with a card. There is also one at Mill Town. Vandalism is a problem. Payphone Submission – WA Government 20