Manager Digital Transition Regulatory Analysis PO Box Q500 Queen Victoria Building NSW 1230

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1 Manager Digital Transition Regulatory Analysis PO Box Q500 Queen Victoria Building NSW 1230 RE: Proposed Guidelines for Digital Television Retransmission Services by Self-Help Providers Dear Manager Please accept this letter as a submission to the review of the proposed guidelines for digital television retransmission services by self-help providers. This submission is made on behalf of Regional Development Australia Wheatbelt Inc. Organizational Profile Regional Development Australia (RDA) is an initiative of the Commonwealth government that aims to enhance the growth and development of regional areas by bringing together the three levels of government to provide a strategic and targeted response to issues in regional areas. There are 55 RDA committees representing regional areas across the country. There are five core functions that underpin the role of the national network of RDA committees: 1) Consultation and engagement with local communities and other stakeholders to identify, prioritise and find solutions to issues impacting on the region 2) Contribute to informed regional planning 3) Contribute to whole of government activities by providing information on regional issues and supporting the implementation of regional programs and initiatives 4) Promote Government programs by creating awareness of services, grants and initiatives for regional development, and supporting stakeholders to gain access to these 5) Support community and economic development through the identification of opportunities to diversify and expand industry and employment opportunities in the region The Wheatbelt Western Australia The Wheatbelt is situated in the south west of Western Australia and covers a vast area extending out to the north, east and south east of the Perth metropolitan area. The population of the Wheatbelt is highly dispersed with approximately 75,000 people living across 43 shires. The highest population density occurs in towns closest to Perth and travelling towards the far north and east of the Wheatbelt, there are further distances between towns and a smaller concentration of people.

2 Retransmission Services In the Wheatbelt region there are over 20 self-help retransmission sites currently in operation. These self-help sites are provided for communities by the Local Government Authorities. Figure 1. Wheatbelt map with indicative locations of existing self-help retransmission sites Considerations Impost on Self-Help Providers Self-help providers in areas where broadcasters will not be providing digital television services are not going to have access to any financial assistance to upgrade retransmission services to digital. In rural and remote areas with existing self-help sites there are essentially two options available; 1) The Local Government (or other provider) self funds the upgrade 2) Residents in the impacted areas access the VAST platform for digital television services

3 Under the proposed guidelines self-help providers who wish to upgrade their retransmission services to digital will be expected to retransmit the full suite of available services, including service information, electronic program guides and closed captioning, all at their own cost. The proposed guidelines also indicate that self-help providers will have to pay for re-stacking of channels as and when required. Again there is no financial assistance for this. The proposed guidelines will make it very difficult for the majority of self-help providers to continue offering the service. The quandary that Local Governments now face is deciding whether or not to continue providing their residents with a retransmission service or to discontinue the service and have their residents move over to the VAST platform. The decision will ultimately be a financial one as the self-help providers not only have the initial outlay but also the ongoing costs of maintaining the service that they have to cover. The ACMA guidelines and the Federal Governments approach to the digital switchover is forcing the hand of self-help providers in favour of VAST. Metro vs. Regional Divide There is a huge divide between what is being provided for metropolitan areas and large regional towns and what is being provided for smaller communities in regional and remote Australia. In areas where broadcasting facilities are being converted to digital (predominately cities and large regional towns) residents only need to purchase a digital capable TV or a set top box. In regional and remote areas that will be serviced by VAST, home owners need to purchase equipment in addition to this if they want to continue enjoying what is now considered a basic service. The Government s Satellite Subsidy Scheme will reduce the cost of purchasing and installing the necessary equipment to enable access to VAST but it does not eliminate it. In addition to the added costs for people in regional/remote areas there are concerns over the many unknowns about the VAST platform. For example; 1) Is VAST as reliable as other transmission services? Specifically, are there interruptions to the service, more so than what you would expect with other means of transmission? 2) What level of maintenance will home owners be faced with if they have a VAST service and will there be any financial assistance to cover ongoing costs? The switch over to Digital TV, is another government initiative that will further the divide between metropolitan and regional Australia. It is already increasingly difficult to attract people to regional areas because of the perception that there is inadequate provision of services and amenities and whilst I do not think television would necessarily be a decisive factor, I do think it is yet another deterrent for people to move to our region. Broadcaster decisions about conversion sites Some of the localities in our region that are not going to be converted to digital would have a good case for why they should be considered. One example is the community of Jurien Bay, which is located on the coastline in the North- West of the Wheatbelt. Jurien Bay has been included as one of nine towns in the State Governments, Regional Centres Development program, announced earlier this year. Under this program the nine identified communities will receive considerable planning and financial assistance to enable them to become large regional centres capable of accommodating the growing population of Western Australia. The resident population of Jurien Bay is, and will continue to grow. Jurien Bay is also a very popular tourist destination, with a high number of people travelling through the area to visit the beautiful coastline and attractions such as the pinnacles. Multi-Dwelling Facilities Another consideration for regional areas, where VAST is the only provision, is the potential impact on multi-dwelling facilities such as hotels, hospitals and lifestyle villages. There are currently no subsidies provided to cover the considerable cost of the connectivity they require to service a large number of televisions. In our region many of

4 these facilities are quite small and have minimal profit margins, which will make the costs associated with providing the service prohibitive. Recommendations 1) If the Government will not consider a subsidy or financial assistance for self-help retransmission services then the providers should be given the option to pool the individual householder subsidies available for the installation of VAST equipment to cover the costs of the upgrade 2) If VAST is the only option for a locality then a subsidy for multi-dwelling facilities should be considered to assist with the huge cost of purchasing and installing the necessary equipment 3) The Government should consider providing additional assistance in the form of a regional task force or similar, who can undertake a brokerage role between the self-help providers and commercial broadcasters to negotiate the upgrade of facilities in high growth towns 4) The Digital Switchover Task Force should liaise with regional development organizations such as the network of RDA s (and Development Commissions in Western Australia) to streamline the roll-out of the digital switchover in regional areas as we are best positioned to disseminate information and help our regions plan and prepare RDA Wheatbelt is concerned about the potential impact the Digital Switchover will have on our region, particularly given the large number of self-help retransmission sites that operate in the area. Our organization is actively engaging with other stakeholders such as the Wheatbelt Development Commission, Local Governments and the Department of Commerce, WA to identify solutions to the barriers our region will face and to advocate for better outcomes for the Wheatbelt and other regional/remote areas of the country. I have included as an appendix to this document some additional comments provided by two Wheatbelt Local Governments who have shared their views on the digital switchover. Should you have any questions or require further information please do not hesitate to contact me. Sincerely Rebekah Burges Executive Officer P: (08) M: rebekah.burges@rdawheatbelt.com.au

5 Appendix - Feedback from Wheatbelt Local Governments Shire of Lake Grace The main issues arising from the changeover from analogue to digital TV signal are: Costings vary greatly depending on the source of the information. This makes it very difficult for Shires to make the best decision for their communities. The cost of subsidies for satellite options are also varied, again impacting decision making. Information from the digital ready website indicates that a final decision on subsidy amounts will not be made until closer to changeover time, but that applications for the upgrade of transmission towers need to be made at least 9 months before the planned upgrade. Community information the Digital Ready website appears to be pre-empting any decision made by the Shire of Lake Grace. The website shows that no towns in the Shire will have the existing transmission towers upgraded and that households will need to access VAST once the analog signal is turned off but the Shire is yet to have these discussions with the community. Shire of Koorda proposal to Great Eastern Country Zone At the end of 2013, all analogue television broadcasting transmissions will cease in favour of digital rebroadcasting services. As part of the switchover to digital services, the Federal Government has come up with several funding programs to assist people with the switchover from analogue to digital television transmissions. For the area of in Great Eastern Country Zone, the option that will be available for digital television services will be the Viewer Access Satellite Television (VAST) or an upgrading of the current rebroadcasting services to a digital signal. Officer Comment: There is a lot of confusion at the moment with regards to the set up for the changeover to digital television. Initial information provided to Local Governments and members of the public can be misleading, with some believing that they only have one choice. For television services to GECZ, areas where central wheatbelt transmissions do not reach, there are currently 2 choices. Both of which have positives and negatives. VAST System The VAST system is what is being promoted by the Federal Government for most regional areas of Australia. The VAST System is an installation of a satellite dish and decoder in every household in areas where digital television rebroadcasting will not be available. The estimated cost of an installation is approximately $200 after the government subsidy, which will allow for a single point access for television and a satellite decoder or set top box. Current installations are showing that the cost of this installation is more likely to be about $350 after the subsidy. Additional access points are likely to cost a further $350 (cheapest available receiver) per access for which there is no funding. A family home with 3 access point will be looking at costs of $900 to maintain 3 different access points ($200 + $350 + $350 = $900). Hi-definition receivers are approximately $600 each.

6 For businesses in the accommodation industry, the cost can run into thousands of dollars for a specialized distribution system. This is pending on the number of rooms. Tourists coming through the area will be able to get a satellite service and roaming access to the satellite feed if they have the required equipment. Tourists without the required equipment will not be able to receive television broadcasts. The VAST access is available through all areas of Australia and will give access to all 17 channels with some channels being specific to the area. Self Help Rebroadcasting The Shire has the possibility of updating its current rebroadcasting service to allow for digital rebroadcasting within the town site area. This has several advantages over the VAST access option which are: Providing the TV antennae is able to receive digital signal, access to digital TV can be gained at all current points with a simple set top box if the television is not digital ready or just with the TV unit. A simple set top box can be purchased for $ Accommodation businesses will not need to install expensive systems to provide television access for each room. Tourists can access digital television with a simple set top box or digital TV. The cost of the upgrading of the service is the biggest inhibitor. We have received quotes from two suppliers ranging from approximately $88,000 to $120,000 pending on what items can be reused from our current systems to a complete new system. No federal funding is available to assist local government with upgrading of the rebroadcasting services and any requests have been flatly refused with the idea that the VAST system is for the regional areas. As digital television will be available through some areas due to retransmission sites, tourists may not go to the expense of having a VAST system in their caravans and may opt to stay in areas where reception is available. This will restrict tourist movement through much of the wheatbelt area. The upgrading of the retransmission sites will also not have the problems with asbestos in homes which created problems with installations in Queensland. Funding In Koorda there are approximately 250 houses. Given that each house will have access to the Satellite Subsidy Scheme (SSS) to have a VAST system installed, the Federal Government will be looking at spending $100,000 in subsidies. Many towns in the wheatbelt area would be similar or larger. Previous advice received has indicated that no funding will be available for Local Governments to upgrade their current services to digital standard. All requests are being refused. Part of the concern with this is the continued cost of maintaining the system is not viable for smaller towns. Some local authorities already have funds available to assist with the changeover to digital which can be used to upgrade the self help sites but may not have funding to cover the full cost. Therefore, the option of a self help retransmission site is not available. If local governments had the option available to use the funding that would have been allocated to households for the VAST installations, more shires are willing to upgrade digital retransmission sites and deliver the same service. It may also be a cheaper service to the ratepayers as multiple satellite receivers will not be required.

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