Letter from the Australian Communications Authority to a member of APUMP.

Dear Sirs

CDMA COVERAGE AND PREVIOUS ANALOGUE CLOSURE

I refer to your letter of 29 December 1999 regarding the closure of the analogue
mobile phone network and the lack of current coverage of CDMA in the Western
District of Victoria.

The decision to close the analogue mobile network was made in 1991 and is one of
the outcomes of the deregulation of the telecommunications industry. By closing the
analogue network, radio spectrum, has been made available allowing more mobile phone operators to offer competing services.

In 1998, in response to concerns from consumers regarding the scheduled closure of
the analogue mobile phone network on 31 December 199, the Government asked the 
ACA to conduct an urgent review of analogue coverage in regional areas. The ACA
reported to the Government on 30 June 1998.

Based on this review, the Government asked Telstra, Optus and Vodafone to advise
how they would meet the requirement that all areas of regional Australia which
currently receive mobile phone coverage would continue to enjoy reasonable
equivalent coverage after the close of the analogue network on 31 December 1999.

On 31 November 1998, the Government announced that it had reached agreement
with the three mobile carriers regarding the closure of the analogue mobile phone
network in regional Australia. Of the 400 base stations used by the analogue network
in regional Australia, 130 of these would close on 31 December 1999, at least 135
would close on 20 June 2000 and the remainder would close by 31 December 2000.

The Government has also imposed Licence Conditions on Telstra requiring it to
operate a digital mobile network(s) which provide reasonably equivalent coverage to
the analogue network in non-metropolitan areas.

Telstra has announced that it will use a technology known as CDMA  (Code Division Multiple Access) to construct a new network to satisfy the Licence Conditions.
Telstra is progressively rolling out CDMA to replace the analogue network as it
closes down. Stage One of closure occurred on 31 December 1999. The enclosed
map shows the areas which have now closed. The remaining network (including that
around Portland) will close sometime during this year at dates to be announced. You
may, however, find Telstra's rollout schedule (enclosed) of interest as Portland is
sceduled to be covered by CDMA by July 2000.

The ACA is responsible for administering the Licence Conditions. It is important to 
note that under the Licence Conditions, the coverage provided by CDMA is not
required to exactly replicate previous analogue coverage, but instead to provide
coverage that is "reasonable equivalent".

What constitutes "reasonable equivalent coverage" is not defined in the Licence
Conditions. However, if the ACA was required to consider whether Telstra had met
its Licence Conditions, it may take the following into account:

• The natural irregularity of coverage of communications provided by radio waves;
• The fact that such communications may be affected by topography, weather
  conditions and the power of individual transmitters or the sensitivity of individual
  receivers;
• The provision of a "reasonably equivalent network" considered as a whole (that is,
  nationally rather than in particular geographic locations);
• The reasonableness of imposing additional costs on the carrier;
• The extent to which claimed detriment in one particular geographic area has been
  offset by additional coverage in other areas; and
• Other factors it may deem to be relevant.

Digital mobile phones, (such as CDMA) are an advanced technology which will allow
fir additional features such as privacy and security for voice communication and
longer talk and stand-by time. Other data services can also be delivered by digital 
technology.

The alternatives to the analogue phone network are GSM digital, CDMA
digital and satellite mobiles (which operate through radio signals sent to and from
communications satellites orbiting that ear, and are ideal for covering vast distances
and mountainous terrain). You may wish to discuss with your service provider the
relative merits and suitability of each type in order to choose which technology best 
meets your needs.

In the meantime, if you have any other queries in relation to the closure of the
analogue mobile phone network, please contact the toll free Analogue Closure Hotline
on 1800 351 135.

I hope this information is of assistance.

Yours sincerely,

Neill Whitehead

Acting Executive Manger
Consumer Affairs Group

14 January 2000

This is a precise word-for-word reproduction of the ACA's letter.

(Enclosed document)

Telstra MobileNet CDMA Rollout -Victoria

Coverage at launch:
Melbourne greater metropolitan and surrounding areas including Geelong and the Mornington 
Peninsula.
For further details refer to the CDMA coverage maps.

Coverage by October:
Central Victoria and the Eastern Mallee area bounded by the Great Dividing Range and the 
Melba, Midlands, Goulbourn Valley and Murray Valley Highways to Swan Hill and the Calder 
Highway to Bendigo, Woodend and Macedon.
Includes Mansfield, Yea, Benalla Euroa, Seymour, Broadford, Shepparton, Kyabram, Echuca, 
Nagambie, Elmore, Cohuna, Kerang, Swan Hill, Bendigo, Heathcote and Inglewood.

Coverage by Jan 2000:
The areas currently with Analogue and Digital (GSM) in Eastern Victoria, north of the Great 
Diving Range to Central Victoria and the eastern edge of the Mallee from Swan Hill down to 
Bendigo. Major towns to be covered by CDMA in this area include Mt. Buller, Mt. Hotham, 
Falls Creek, Corryong, Wodonga, Wangaratta, Yarrawonga, Cobram, Myrtleford, Bright, 
Rutherglen, Beechworth and Yackandandah. Major highways include Gt. Alpine Rd, Hume 
Highway, Murray Valley Highway, Midland Highway, Kiewa Valley Highway.

Coverage by April 2000:
Existing Analogue and Digital (GSM) areas in the South Gippsland region. Major towns 
include Wonthaggi, Inverloch, Leongatha, Korumburra, Warragul, Moe, Morwell, Traralgon, 
Sale, Bairnsdale, and Orbost. Major highways are, Princes Highway, South Gippsland 
Highway, Bass Highway.
Existing Analogue areas in Western Victoria. Major towns included are Ballarat, 
Warrnambool, Colac, Portland, Hamilton, Horsham, Ararat, Nhill, Maryborough, St. Arnaud, 
and Stawell. Includes areas along the following major highways: the Western Highway, 
Wimmera Highway, Prices Highway, Sunraysia Highway, Henty Highway, and Calder 
Highways.
Areas to the north will include Mildura along with parts of the Calder and Sturt Highways.

Coverage by July 2000:
The existing Digital (GSM) areas in Western Victoria from Geelong to Portland, Ballarat to 
SA border, from Bendigo to St. Arnaud. Major Towns/areas include Casterton, 
Peterborough, Port Campbell, Apollo Bay, and Nelson. Along with sections of the Great 
Ocean Road from Apollo Bay to Lorne and from Warrnambool to Port Campbell, along with 
parts of the Hamilton Highway.

Areas in east Gippsland to be covered will include the towns of Cann River, Genoa and 
Mallacoota and parts of the Princes Highway in these areas.

Coverage by October 2000:
The Mallee area including, Warracknabeal, Ouyen, Hopetoun, Sea Lake, Birchip, Culgoa, 
Speed, Manangatang.