The business case for upgrading the copper NBN to fixed line full fibre - FTTP 4th Submission

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The business case for upgrading the copper NBN to fixed line full fibre - FTTP 4th Submission
The business case for upgrading the copper
     NBN to fixed line full fibre – FTTP

                4th Submission

 Inquiry into the business case for the NBN and the
           experiences of small businesses

                       Peter Savio

                   14th September 2020

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The business case for upgrading the copper NBN to fixed line full fibre - FTTP 4th Submission
SUMMARY

The so called “Multi Technology Mix” NBN is a misnomer.

It is not a mix of Technologies.

There is only one dominating “technology” and that is copper wire, the same
“technology” that was once used for Telegrams.

71% of the Copper NBN’s so called “last mile” is fixed line copper.

It is this copper wire that determines the:

-   slow speed,
-   poor performance
-   lower take up rates
-   Inability for true high speed broadband
-   poor reliability
-   lower revenue
-   higher fault rates
-   higher dropouts rates
-   higher outages periods
-   higher wholesale charges
-   higher CVC charges
-   higher operating costs
-   higher training costs
-   higher spare parts costs
-   higher number of people required to support the copper NBN
-   higher complexity
-   higher cost to upgrade
-   lower Australian GDP
-   low World Broadband ranking
-   lower profits for Retail Service Providers
-   lower profits for Australian businesses
-   Competitive disadvantage in relation to our major trading partners

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1991

https://www.crikey.com.au/2016/01/13/who-you-should-blame-for-the-nbn-hint-not-
just-turnbull/

In a cabinet discussion paper prepared by the Department of Transport and
Communications on the delivery of pay TV services in 1991, the department argued
against the very HFC cable NBN is now buying, suggesting fibre-to-the-home (i.e.
Labor’s model of the NBN) would be vastly superior, even in the early 1990s.

“FTTH is the technology for next century. Recent advice from Telecom [the
government-owned company that would eventually become Telstra] is that they do
not expect the economics to be right to commence installation to homes until 1997.

According to the discussion paper, the rollout for “homes in urban areas” would be
$5.3 billion, and could be rolled out to between 3% and 10% of homes every year.
HFC could be rolled out faster, but the paper states that it would “still be expensive
and be made obsolete by FTTH”.

The report was fairly scathing on the HFC networks that Optus and Telstra
eventually would go on to build, and NBN would ultimately buy from them:

“A hybrid network could be started now but it would be obsolete before the end of the
century and could be a one-way system that would not significantly add to the
development of Australia’s telecommunications infrastructure.”

April 2012

https://delimiter.com.au/2012/04/30/fttn-a-huge-mistake-says-ex-bt-cto/

“….former chief technology officer of British telco BT, has publicly stated that fibre to
the node-style broadband is “one of the biggest mistakes humanity has made”,
imposing huge bandwidth and unreliability problems on those who implement it, as
the Coalition may do in Australia.

Shadow Communications Minister Malcolm Turnbull has used BT’s FTTN rollout —
which the telco has said will achieve 80Mbps download speeds and 20Mbps upload
speeds this year — as evidence for his case that the style of deployment will work in
Australia.

However, in testimony to the UK Parliament, Cochrane rubbished claims that FTTN
was an appropriate rollout style for national broadband networks.

“Fibre to the cabinet (node) is one of the biggest mistakes humanity has made,” he
said. “It ties a knot in the cable in terms of bandwidth and imposes huge unreliability
risks”

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7 September, 2013

"We will deliver a new business plan for the NBN so that we can deliver faster
broadband sooner and at less cost. I want our NBN rolled out within three years and
Malcolm Turnbull is the right person to make this happen."

Tony Abbott - A letter to Australians.

https://www.heraldsun.com.au/archive/federal-election/tony-abbott8217s-letter-to-
the-people-of-australia/news-story/bd3056e87ba06dd58120b903f719d258

The copper NBN – “on budget”….multiple times.

$29.5 Billion
$41 Billion
$49 Billion
$51 Billion
$55 Billion

and always “on schedule”…..many times as well.

Sept 2016
End of year 2016
End of FY 2020
End of year 2020?

I've never seen any project that is always “on budget” and “on schedule” with so
many different numbers and timings.

AND then they claimed the FTTP NBN was going to cost

$100 Billion (Turnbull April 2013)
$94 Billion (Turnbull Sept 2013)
$73 Billion (Scenario 1 – Turnbull/JB Rousselot Strategic Review Dec 2013)
$64 Billion (Scenario 2 – Turnbull/JB Rousselot Strategic Review Dec 2013)

and now the latest FTTP NBN “costing”

$500 BILLION – that's half a $Trillion dollars!

https://www.paulfletcher.com.au/print/op-ed-success-of-nbn-is-picking-up-speed

"..to finish the whole project was going to cost over half a trillion dollars!"

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Between Sept 2013 and 30th June 2016, almost 3 years, this Government and
copper NBN Board only activated, on its copper part of its network, 100,000 copper
connections (all FTTN), and spent in that almost 3 years $14 Billion dollars - so at
that point in time, based on those facts, their copper NBN was going to cost $1.7
Trillion dollars and take another 300 years to complete.

The copper NBN - that's worked out well hasn't it:

1. 62nd (July 2020) in the World in broadband speed, we were about 30th back in
   2013.

2. 9 out of 10 of our top 10 trading partners are slaughtering us on broadband
   speed and performance.

3. The vast majority of our top 10 trading partners have either already rolled out full
   fibre FTTP networks or are in the process of doing it or have defined plans.

4. Openreach in the UK (which Turnbull largely based his copper NBN on) is now
   abandoning copper and going full fibre FTTP under the policy settings of
   Conservative Prime Minister Boris Johnson.

5. Australia has the 4th most expensive country in the world for a 100 Mbps
   broadband plan.

6. Australia is the 3rd most expensive country in the world for a 1 Gbps broadband
   plan.

7. Only ~20% of the NBN can achieve true Gigabit speeds - and that's only on the
   FTTP part of copper NBN.

8. The copper NBN will lose up to ~$700 million a year in revenue and cost up to
   ~$1 Billion more a year to operate vs. a full fibre fixed line FTTP NBN.

9. The copper NBN will cost Australia up to $52.5 Billion a year in lost GDP.

10. The copper NBN will cost Australia up to $10.5 Billion a year in lost tax income.

11. The copper NBN is 4 years late and 86% or $25.5 Billion over budget.

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...and what would a full fibre fixed line FTTP NBN have cost?

Based on actual NBN data and evidence to Senate Estimates and Joint Standing
Committees, and separate independent analysis, a full fibre fixed line FTTP NBN,
including Fixed Wireless and Satellite, could have been completed by end of
calendar year 2021 and for $56-58 Billion in peak funding if the FTTP roll out had
continued in Sept 2013.

The Good news…..how do we fix this copper NBN?

An upgrade of the copper NBN to full fibre fixed line FTTP can be achieved before
the end of this decade.

An upgrade of the copper NBN to full fibre FTTP pays for itself in a short time.

…and what is the first step to fix the copper NBN?

The NBN Statement of Expectations (SOE) be revised with the following change;

The NBN develop an approved 10 year costed plan, with the implementation starting
no later than November 2020, to upgrade and overbuild the fixed line copper
components of the Multi Technology Mix NBN with Fibre to the Premise, with a
completion date no later than end of year 2029, with Fibre to the Node, Micro-Node
areas, Fibre to the Curb, Fibre to the Basement, and then HFC being the order of the
upgrades.

This submission was going to be updated for the 2021-2024 NBN Corporate
Plan, but that Plan has not yet been released by the Submission cut off date.

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READING TIME: 50 minutes

My name is Peter Savio. I represent myself in a private capacity.

I refer you to comments made by New Zealand’s Ultrafast Fibre CEO John Hanna;

https://www.ultrafastfibre.co.nz/ultrafast-fibre-ceo-relishes-the-5g-opportunity-as-data-
usage-surges/

“Most nations are saying if we don’t do this we will be left behind. The decisions New
Zealand made in the mid- to late- 2000s, I don’t think we could have envisioned just how
critical those decisions were.”

The pivotal moment was choosing to deliver fibre to the premises rather than fibre to the
node as Australia has done.

“What a disaster,” Hanna said. “They will never recover from that. It will set them back by
decades.”

The copper NBN (so called Multi Technology Mix or MTM) is a technical, financial,
economic and policy failure that isn’t fit for purpose and has set Australian business
competiveness back at least 2 decades unless urgent action is taken now.

On the 9th April 2020:

https://www.itnews.com.au/news/vodafone-chief-flags-co-investment-option-to-upgrade-
nbn-fttn-users-to-full-fibre-546596

“Speaking at the virtual CommsDay Summit……current Vodafone Australia CEO Iñaki
Berroeta said full fibre “is key to Australia’s telecommunications future.

Citing a study commissioned by Vodafone Group’s Berlin-based think tank, Berroeta said
that “increasing the number of fibre connections in a country by one percent per year is
associated with an increase in GDP of between 0.02 percent and 0.04 percent per year.”

“For Australia, this would mean a growth in GDP of $370 million and $740 million per year,”
he said.”

So that's $370 million to $740 million increase in GDP per every 1% increase in full
fibre.

Upgrading the copper NBN to FTTP at a cost of ~$18 Billion @1.5% P.A. = $270 million in
interest costs per year.

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71% of the so called MTM is copper (FTTN, FTTB, Micro-Node, FTTC, HFC) so that's:

71 x $370 million = $26.3 Billion

to

71 x $740 = $52.5 Billion

increase in GDP PER YEAR once the upgrade to a full FTTP NBN is complete and in
smaller increasing incremental amounts doing the upgrade process.

Add in the $1.7 billion extra in revenue and lower OpEx costs PER YEAR of a FTTP NBN
vs copper NBN.

So with a full fixed line FTTP NBN you would be:

$26.3 Billion + $1.7 Billion – $270 million interest on loan = $27.7 Billion

to

$52.5 Billion + $1.7 Billion – $270 million interest on loan = $53.9 Billion

a year better off than with the copper NBN.

Let’s just repeat that:

Based on this Vodafone study Australia’s GDP would increase by $26.3 Billion to
$52.5 Billion a YEAR with a full fixed line FTTP NBN.

The tax to GDP ratio even in bad years is usually at least 20%

https://treasury.gov.au/sites/default/files/2019-03/2-Tax-to-GDP-ratio.pdf

This translates to an increase in tax receipts, with a full fixed line FTTP NBN, of $5.5
to $10.8 Billion a year.

This increase in GDP and the extra tax revenue it generates, higher NBN wholesale
revenues and lower operating costs, of upgrading the copper NBN to full fixed line
FTTP, easily pays for the upgrade and in a very short timeframe.

Ironically the Minister’s “…half a trillion dollars!" figure he quotes on his website could be
the amount of lost GDP to the Country and the Australian tax payers to 2030 if nothing is
done to upgrade the copper NBN to FTTP in that timeframe.

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The CEO of Vodafone Australia is also calling for a full fibre upgrade.

https://www.theaustralian.com.au/business/technology/nbn-needs-fibre-upgrade-vodafone-
boss/news-story/e13934beb78c2771902c73d48db5c3cc

"Vodafone’s chief executive says the NBN needs a rapid upgrade that would bring it much
closer to Labor’s original fibre vision."

The CEO of Telstra is calling for upgrades to the copper NBN and a clear upgrade path
from Government.

https://www.itnews.com.au/news/telstra-ceo-wants-nbn-upgrade-paths-reflected-in-govt-
policy-548506

"Telstra CEO wants NBN upgrade paths reflected in govt policy"

https://www.bit.com.au/news/huawei-australia-suffering-gigabit-gap-despite-spending-51b-
549817

"Huawei Australia has launched its new Gigabit Gap report, made in association with the
Telecommunications Association (TelSoc). It shows that after its "completion" this week, the
$51 billion nbn network - which cost $4,500 for each connectable premises - still leaves
over 70 per cent of Australian homes and businesses unable to access Gigabit speeds. It
also shows that Australia's Gigabit broadband pricing is the third most expensive in the
world"

"Huawei says, "More worryingly, whilst major European markets such as France, Spain and
the UK are all planning to deliver 100% Gigabit capability by 2025, Australia still has no
plan in place to extend Gigabit capability beyond current levels – leaving millions of homes
and businesses stranded on slower speeds with some homes unable to still even reach
25Mbps."

“Stephen Myers, Principal Consultant, OMDIA said, “Unlike many of our trading
partners Australia has not adopted an aspiration to be a Gigabit enabled nation.”

Jeremy Mitchell, Chief Corporate Affairs Officer at Huawei Australia said, “It is simply unfair
– and frankly un-Australian for taxpayer dollars to deliver an outcome where, for example,
Coffs Harbour in NSW gets Gigabit Fibre-to-the-Premises and Bundaberg in QLD gets
speeds forty times slower with 25Mbps on Fibre-to-the-Node – it’s time to put that right.”

The copper NBN has now had to go borrow even more money, another $4.1 Billion, to prop
up its copper network and failing finances.

The copper NBN has now cost up to $55 Billion dollars in peak funding, is 86% over its
original budget of $29.5 Billion dollars and is at least 4 years behind schedule.

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https://www.itnews.com.au/news/nbn-co-sources-61-billion-from-banks-548009

“From the additional $4.1 billion debt facilities, $1.5 billion “will be reserved for working
capital to provide the company with added flexibility and to support NBN Co’s long term
capital management strategy,” the Government said

Some of that money could be used by NBN Co to "pay down" an existing $19.5 billion loan
from the Government "without jeopardising [NBN Co's] performance".

So...the Government has allowed the NBN to borrow more money to pay off other NBN
debts, including its Government loan, and for day to day “working capital”.

This is the equivalent of a home owner with a mortgage taking out credit cards to pay the
mortgage.

If the finances, including revenues, operating costs, ongoing capital costs and
projected positive cash flows of the copper NBN were sound, and the decision to
abandon full fibre and go with copper was financially correct, why would the copper
NBN Board need to go borrow another $4.1 Billion dollars?

The copper NBN CEO has confirmed none of that $4.1 Billion extra borrowed is committed
to any upgrades of copper to FTTP which is the only extra borrowing it should be doing.

https://www.smh.com.au/politics/federal/nbn-co-in-no-rush-to-use-extra-funds-on-network-
upgrades-20200514-p54t17.html

The copper NBN is now offering residential Gigabit speed plans on...wait for it....the full
fibre part of the NBN FTTP (how ironic...) and only 7%...yes just 7% of the HFC part of the
network (except its only “up to” 1 Gigabit speed) because the other 93% of HFC isn't up to
scratch and will require substantial hardware and software upgrades at some cost to
become maybe just close to Gigabit capable, and more likely only 250 Mbps.

The copper NBN is a technical, financial and economic basket case.

The Liberal-Nationals NSW Government has now committed to funding regional
upgrades to full fibre FTTP, overbuilding the copper parts of the copper NBN.

https://thenewdaily.com.au/life/tech/2020/05/12/nbn-regional-broadband-tax-gig-state/

“The New South Wales government is planning to roll out its own fibre broadband network
that could undercut the NBN in regional areas, despite the federal government pushing a
new regional broadband tax.

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The…….NBN is approaching its June completion deadline, but the NSW government last
week confirmed it intends to own and operate its own high-speed network in several
regional towns, which would compete directly with the federal government’s mixed-
technology network.

The NSW government’s ‘Gig State’ pilot project, first mooted earlier this year, will see fibre-
to-the-premises and high-speed open access wireless infrastructure rolled out to an
estimated 50,000 homes and businesses in seven towns: Wagga Wagga, Parkes, Dubbo,
Cobar, Nyngan, Narromine and Trangie.”

The Queensland ALP State Government has also recently announced plans to
overbuild parts of the copper NBN.

http://statements.qld.gov.au/Statement/2020/6/26/qcn-fibre-sparks-new-partnerships-to-
end-digital-divide

“Innovation Minister Kate Jones today revealed QCN Fibre had inked an agreement with
Toowoomba’s Pulse Data Centre and Queensland internet service provider Over The Wire
to provide better internet for thousands of businesses in the Darling Downs.

“For years, businesses in Toowoomba and the Darling Downs have been left with a second
rate internet connection. We want to end that,” Ms Jones said.

“It’s no secret that the NBN didn’t deliver everything the Federal Government promised.”

“We’re using thousands of kilometres of state-owned optical fibre to provide a stronger and
more reliable internet connection for locals...”

“Today’s announcement means that these new packages will soon be on the market.”

Ms Jones said a strong and reliable internet connection was crucial for small businesses.

“Now more than ever before, it’s crucial for small businesses in regional Queensland to
have access to a strong, reliable internet connection,” Ms Jones said.”

The announcements by RSPs Telstra and Belong in earlier 2020 to withdraw from the
100 Mega bit per second (Mbps) copper Fibre to the Node, Basement and Curb
market is simply a shocking indictment of the copper based NBN, its technical
limitations and its financial failures, and the root causes, which is the failure of Government
Policy over several decades, including the failure to structurally separate Telstra and the
policy decisions made in late 2013 and 2014 to abandon a full fixed line Fibre to the
Premise NBN.

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RSP TPG has revealed that outages for HFC connections have nearly doubled between
September 2019 and February 2020 from 72,000 to 130,000.

https://www.macrobusiness.com.au/2020/03/vultures-descend-on-nbn/

“HFC remains a large concern,” TPG boss Craig Levy told CommsDay.

The amount of outages going on in the network compared to other access technologies
suggests it’s not up to operational standards.”

The copper parts of the copper NBN, FTTN, FTTB, HFC, micro-nodes and FTTC are
already obsolete and belonged in a Museum a decade ago and now competitors to
the copper NBN are entrenching that.

https://www.itwire.com/telecoms-and-nbn/dgtek-plans-national-fttp-expansion.html

“DGtek operates a fibre to the premises (FTTP) broadband network, filling a gap left by the
Coalition Government's decision to scrap the NBN's mostly-FTTP design for the Multi
Technology Mix which has proved less than satisfactory for at least some customers.

DGtek's network currently covers Melbourne's CBD and some south-eastern suburbs: Port
Melbourne, South Melbourne, St Kilda, Elwood, Bentleigh and Moorabbin.

"With recent investment in our infrastructure we have materially increased our fibre rollout
and network footprint and have the capacity to now extend rapidly throughout large parts of
Melbourne and ultimately throughout Australia," said founder and CEO David Klizhov.

The current NBN network cannot provide the speeds and reliability that Australian
businesses and residents currently need and is already not meeting demand," he added.”

Both the UK and New Zealand, and many other countries, have had the maturity to have
essentially a bipartisan position on the importance of Fibre to the Premise and the
importance to business and their communities as a whole.

The rest of the World is now leaving Australia behind, with many countries including the
majority of our major trading partners rolling out full fibre fixed line networks with Gigabit
capability, which is now the minimum standard, not 25 Mega bits per second (Mbps).

This is clearly also reflected in the Speedtest Global Index where Australia ranks 62nd as of
July 2020 and we are way behind 9 out of 10 of our major trading partners on broadband
performance.

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https://www.speedtest.net/global-index

http://www.worldstopexports.com/australias-top-import-partners/

Table 1: Trading partners and Broadband speed – July 2020

      TRADING PARTNERS          DOWNLOAD           UPLOAD            BROADBAND
                                (Mbps)             (Mbps)            RANKING
1.    China                     137                40                18
2.    Japan                     128                129               20
3.    South Korea               170                165               4
4.    UK                        71                 21                46
5.    USA                       153                57                9
6.    India                     40                 35                75
7.    New Zealand               123                80                22
8.    Taiwan                    122                99                23
9.    Hong Kong                 203                193               2
10.   Singapore                 213                220               1
      AVERAGE                   136                104
      Australia                 53                 22                62

https://www.adlittle.com/sites/default/files/reports/adl_race_to_gigabit_fiber-compresse.pdf

Report dated September 2020

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5 out of 10,

Singapore
South Korea
Hong Kong
Japan
New Zealand

of our top 10 trading partners already have significant FTTP coverage ranging from 95% to
82%.

In the UK BT has announced in May 2020 they will spend $22.8 Billion dollars to upgrade
its copper network to full fibre.

https://www.itnews.com.au/news/bt-unveils-22bn-plan-to-upgrade-copper-network-to-full-
fibre-547900

“BT unveils $22bn plan to upgrade copper network to full fibre”

“Chief Executive Philip Jansen said the coronavirus pandemic, which has seen a surge in
the use of mobile phones and data, had brought BT's national leadership in telecoms into
the sharpest focus in its history, and while upgrading the network had been important
before, it was now "a matter of extreme urgency".

If it’s a matter of “extreme urgency” for the UK to upgrade to full Fibre it should also be a
matter of extreme urgency for Australia to upgrade its copper NBN to full fibre.

The UK is upgrading to FTTP - in the middle of the pandemic!

UK Prime Minister Boris Johnson – 30th June 2020

https://www.spectator.co.uk/article/full-text-boris-unveils-his-new-deal-

“….we will also build faster, and that is why the Chancellor and I have set up Project Speed
to scythe through red tape and get things done and with every home we make, every mile
of full fibre broadband that we lay…we will of course be tackling the next wave of this
crisis by helping to create thousands of high-paid high-skilled jobs.”

https://www.ispreview.co.uk/index.php/2020/07/big-uk-rules-changes-to-boost-gigabit-
broadband-and-5g-rollout.html

“A focus on gigabit-capable networks – A new broad duty for Ofcom to promote
connectivity, access to, and take-up of gigabit-capable networks to help the UK realise its
full digital potential.”

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https://businessnewswales.com/full-fibre-broadband-to-boost-post-covid-economic-
recovery/

“Openreach CEO, Clive Selley, said:

“This year we’ve all seen the importance of having a decent broadband connection and at
Openreach, we’re convinced that Full Fibre technology can underpin the UK’s economic
recovery.

“Right now, we’re building a new, ultra-reliable full-fibre network that will boost productivity,
cut commuting and carbon emissions, and connect our families, public services and
businesses for decades to come.”

“Openreach is leading the charge to help Government achieve its target of making gigabit
capable networks available nationwide by 2025.”

https://www.bmmagazine.co.uk/news/working-from-home-fuels-surge-in-bt-sign-ups-for-
ultra-fast-broadband/

“BT has reported a near-70% surge in customers switching to next-generation full-fibre
broadband as the working-from-home revolution prompts people to upgrade to the fastest
internet connection available.”

“Boris Johnson has pledged to have next-generation broadband made available to every
home by 2025, as the UK plays catchup rolling out the technology compared with most
developed markets around the world. BT is spending £12bn rolling out full-fibre broadband
to 20m homes by the late 2020s”

https://www.telegraph.co.uk/technology/2020/06/07/full-fibre-broadband-could-create-12-
million-jobs/

“Installing full fibre broadband across the UK could create 1.2m skilled jobs by 2025 while
allowing a quarter of workers to be based at home, according to a new report”

Pro rata to the size of the Australian population that would be in the order of an additional
440,000 skilled jobs with a full fibre rollout.

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https://advanced-television.com/2020/06/23/158145/

“The milestone achievement comes as Openreach continues to build the Full Fibre future-
proof broadband network in NI, with an aim of reaching 525,000 premises, which is 60 per
cent, by the end of March 2021. This puts Northern Ireland well ahead of the rest of the UK,
to achieve the Government’s target of 100 per cent access to 1 Gbps speeds by 2025.

Even after the Covid-19 crisis subsides, it is reasonable to expect that infrastructure
demand will continue to increase. As NI moves towards reopening its doors for business,
the roll-out of Full Fibre broadband infrastructure will be a key enabling technology. It will
allow the region to compete with competitor nations, to boost incomes and standards of
living and meet policy objectives of digitisation, improved sustainability and further
embracing globalisation.”

“The Full Fibre build programme is central to NI’s digital future and economic growth and
will provide the region with more reliable, faster and future-proof broadband,” stated
Mairead Meyer, Director of Openreach Northern Ireland.”

In New Zealand (and 10 other Nations) are already offering 10 Gbps symmetrical plans.

https://www.itnews.com.au/news/new-zealand-to-get-10-gbps-fibre-to-premises-in-2020-
534132

Article dated 18th Nov 2019

“Ultrafast Broadband fibre to the premises customers in New Zealand will get the option to
buy symmetric 2 and 4 gigabit per second service next year, with an 8 Gbps option to
follow, as broadband wholesaler Chorus upgrades its network.

Chorus has trialled the XGS-PON, a 10 Gbps passive optical networking standard with a
small set of customers this year, and will offer the product to retail service providers starting
February next year.

The network builder claims this makes NZ one of only 10 countries in the world to offer
XGS-PON service, and the first in the Southern Hemisphere.”

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USA

https://www.majoritywhip.gov/wp-content/uploads/2020/06/Accessible-Affordable-Internet-
for-All-Act-Bill-Text.pdf

https://arstechnica.com/tech-policy/2020/06/100-billion-universal-fiber-plan-proposed-by-
democrats-in-congress/?utm_medium=social&utm_social-
type=owned&utm_brand=ars&utm_source=twitter

“$100 billion “universal fiber” plan proposed by Democrats in Congress”

"America is behind on its transition to a 21st-century, fiber-connected Internet with no plan
for how to fix the problem," Falcon wrote. But Clyburn's bill "would begin a national
transition of everyone's Internet connection into multi-gigabit capable fiber optics”

Falcon argues that a plan like Clyburn's is needed for the US to deploy fiber throughout the
country within a few years instead of decades. "Such an ambitious program would have
the United States match China's efforts to build universal fiber with the US
completing its transition just a few short years after China," Falcon wrote. "Without this
law, the transition would take decades."

https://www.bbcmag.com/tools-and-resources/ftth-top-100/2020

“Fiber-to-the-home (FTTH) deployment in the United States is beginning to outpace legacy
copper broadband, a trend that is impacting service providers and their vendor suppliers.

Fiber continues to be a significant factor in the broadband race.

Market research firm RVA revealed in its 2019-2023 North American Fiber Broadband
Report that broadband providers had passed 49.2 million homes with fiber, up 17 percent in
2019.”

https://www.telecompetitor.com/report-for-an-extra-70-billion-ftth-could-be-available-to-90-
of-u-s-homes-by-2029/

“Building all-fiber networks throughout America is not a pipe dream,” said Lisa R. Youngers,
president and CEO of the Fiber Broadband Association, in a press release about the new
report, titled “All-Fiber Deployment Cost Study 2019.”

She said it is now feasible to make FTTH available to all U.S. homes within the next
decade.

The U.S. is already on a pace to see FTTH available to 50% of homes by 2025, said
Cartesian and the Fiber Broadband Association.”

                                                                                    17 | P a g e
China

https://cnnic.com.cn/IDR/ReportDownloads/202008/P020200827549953874912.pdf

Page 12: “As of December 2019, the number of FTTH/O users had reached 417 million,
accounting for 92.9% of all fixed Internet broadband subscribers..”

Page 11: “As of December 2019, the number of subscribers of fixed Internet broadband at
the speed of 100 Mbps or above had accounted for 85.4% of all fixed Internet broadband
subscribers”

India - there are calls for a “massive fibre roll out”.

https://telecomtalk.info/broadband-india-implement-pending-ndcp/269377/

and the Indian Prime Minister has recently announced:

https://swarajyamag.com/insta/boost-to-digital-india-optical-fibre-connectivity-to-each-
village-in-country-in-three-years-assures-pm-modi

“Giving a new fillip to the Digital India vision, Prime Minister Narendra Modi on Saturday (15
August) announced that every village in the country will be connected by the optical fibre
cable (OFC) in the next 1,000 days, nearly 3 years.”

“Prime Minister’s renewed emphasis and target would, however, give a major push to the
project of making rural India truly digital.”

In Australia today, in 2020, we have a “Fibre Gap” with our major trading partners.

Spain and Italy

https://www.telecomtv.com/content/access-evolution/after-a-slow-start-fibre-is-now-
galloping-towards-the-home-39628/

“Fibre is now being dug in at full gallop as network builders continue to invest (only slightly
held back by the pandemic…..) while service providers wheel and deal to arrange access.

We’ve seen a real uptick in fibre focus over the past year or so. Some of the latest moves
include fibre progress in Italy with TIM laying the groundwork for a single national fixed fibre
access network; before that, BT took the time to quash rumours that it was considering
selling a stake in OpenReach to fund its fibre effort. In July Telefónica unveiled its Digital
Deal, a pledge to achieve 100% fibre coverage in Spain by 2025”.

                                                                                      18 | P a g e
The report by the FTTH Council Europe in September 2019 Fibre to the Home states:

https://www.ftthcouncil.eu/documents/FTTH%20Council%20Europe%20-
%20Panorama%20at%20September%202019%20-%20Webinar%20Version4.pdf

   -   Data and bandwidth continues to grow, more operators and governments are
       working towards future proofed FTTH deployments

   -   During 2019, more governments launch subsidy programmes to reach new FTTH
       areas, including rural regions

   -   More operators migrate towards FTTH, they are focusing on copper switch-off and
       cable migration towards full-fibre.

https://www.adlittle.com/RaceToGigabitFiber

“We are pleased to report that fiber rollout continues to pick up pace in almost all markets
across the world, as was also the key message in the previous edition of our study “The
race to gigabit fiber” in 2018. As of 2019/2020, there are more than 10 markets where fiber
coverage has reached at least 95 percent of homes.”

“An increasing number of incumbents acknowledge the inevitability of switching off and
dismantling their legacy copper networks as fiber coverage becomes ubiquitous, while the
cost economics of maintaining a fiber network are far superior to maintaining a legacy fixed
network.”

Back in Australia

https://sydney.org.au/wp-content/uploads/2020/07/Committee_Unleashing-
Innovation_7_web.pdf

“While Australia’s political leaders may be unwilling to countenance further investment to
advance our digital infrastructure in the wake of an expensive and arguably underwhelming
NBN program, it also remains true that Australia will be able to enable a world-leading
innovation economy to emerge while the country still has world-following internet. It is also
true that Australia cannot afford to shun this discussion until such time as the current NBN
roll-out is complete. Other countries are doubling down on their internet investments, and
Australia will be left behind if it does not follow suit.

We believe that an appropriate target for the Australian Government should be to, at an
absolute minimum, be in the top 50% of OECD countries for broadband speed by 2030 and
in the top 25% by 2035. This will likely require substantial investment, but the cost of
inaction is likely to outweigh the benefits.”

                                                                                   19 | P a g e
https://www.zdnet.com/article/customers-up-thanks-to-belong-in-rare-increase-for-telstra-in-
fy2020/

Andy Penn – Telstra CEO

"Without some sort of long-term change leading to improvement in RSP economics, the risk
of retail price increases, reduced customer experience or customers moving onto other
networks such as 5G will increase. In Telstra's case, the profitability of reselling the NBN is
negligible at best — that is not sustainable."

So this Government and copper NBN Board have also delivered a copper based wholesale
broadband network that is "not sustainable" for some RSP's, is under direct threat from 5G,
and already costs the consumer more.

Sooner – FAILED

Cheaper – FAILED

more affordable – FAILED

....and that's what happens when you build a copper based broadband network that has
lower revenues, higher operating costs and higher ongoing capital costs than a FTTP
broadband network, and politics gets in the way of rational technical, financial and
economic management.

The current Australian Government still claims 25 Mbps, or is it 15 Mbps as claimed in the
Copper NBN’s so called Cost Benefit Analysis (Vertigan-Ergas Report), is more than
enough and their rhetoric is that Broadband is predominately a Video Entertainment
System, and its copper NBN is “Fit for purpose” and to date has no vision or actual defined
plan to upgrade it to full fibre fixed line FTTP.

https://www.researchandmarkets.com/reports/5141630/australia-telecoms-industry-report-
2020-
2025?utm_source=GNOM&utm_medium=PressRelease&utm_code=2zcrcl&utm_campaign
=1434994+-+Australia+Telecoms+Industry+2020-
2025%3a+Revenue+and+Market+Forecasts&utm_exec=joca220prd

“Australia Telecoms Industry Report - 2020-2025”

“Capex Investments”

                                                                                    20 | P a g e
“The capital expenditure (Capex) from telecommunications operators is coming off from an
all-time peak between 2017 to 2018 due to the NBN investments in upgrading Australia’s
fixed broadband infrastructure. The publisher expects Capex investments to remain
sustained to accommodate for data usage growth, mobile coverage expansion and capacity
improvements. NBN expects a steady Capex spend from 2021 which excludes any further
gigabit speeds network upgrade to full-fibre still pending for nearly 70% of premises.
Instead, NBN will be required to continually invest in HFC and fixed wireless to increase
capacity and accommodate more customers and higher data usage.”

“Australia is now in the unfortunate position of being the only country in the
developed world with a higher average mobile speed compared to fixed broadband
as per Ookla speed tests.”

“The NBN project remains a politically contentious issue for the country. The NBN has
failed to address a flawed pricing structure, including a contentious usage charge, resulting
in high pricing and is a wholesale failure to deliver affordable gigabit speed in comparison to
countries such as New Zealand or Singapore who launched national broadband plans at a
similar time. For the third year in a row, NBN also shifted its forecasted positive cash
flow position to 2023 after increasing its forecast Capex spend.”

COVID-19: Some claim the copper NBN has held up well during the CIVID-19 pandemic
and with people working from home.

The truth is COVID-19 has shown the shortfalls of the copper NBN.

   1. Users on the Whirlpool forums have reported upload speeds on the HFC network
      being badly affected by HFC specific congestion while people are working from
      home.

       https://forums.whirlpool.net.au/thread/3xk7p1q9

       https://forums.whirlpool.net.au/thread/94825my9?p=25

   2. Consumers working from home and schooling children at home using online classes
      have struggled using a speed limited 25 Mbps service on long line copper FTTN
      links.

   3. The copper NBN was forced to increase CVC capacity by 40% at considerable cost.
      The higher revenues and lower operating costs of a full fibre fixed line FTTP NBN
      would have easily covered this additional financial burden on the NBN AND
      wholesale and CVC charges would be much lower, or CVC ultimately eliminated,
      under a FTTP NBN to start with due to higher revenues and lower operating costs
      allowing reductions in wholesale and CVC changes in the first place.

                                                                                    21 | P a g e
https://www.crn.com.au/news/nbn-co-extends-extra-bandwidth-for-two-more-months-
   547550

4. The Government and copper NBN had to beg the streaming services to cut their
   streaming rates.

   https://www.theguardian.com/media/2020/mar/20/australian-government-asks-
   netflix-and-stan-to-reduce-data-to-avoid-broadband-overload

5. https://www.news-medical.net/news/20200828/COVID-19-crisis-highlights-
   shortcomings-in-Australias-National-Broadband-Network.aspx

   “The COVID-19 crisis has increasingly highlighted shortcomings in Australia's
   National Broadband Network, Flinders University experts say.

   With access to high-speed broadband (HSB) and the internet via the NBN now
   central to people's livelihoods, education, healthcare delivery and even social
   connections, the Flinders University researchers say the "short-term politics of the
   2013 federal election" led to decisions which caused an expensive rollout and
   current problems with the network.”

                                                                               22 | P a g e
In particular I want to address the following:

a. The economics of the NBN, including key operational and financial performance
forecasts in the Corporate Plan.

b. current pricing structures, including wholesale pricing, affordability and take-up

and

f. Compliance with the NBN Statement of Expectations and adequacy of that Statement.

I have used the NBN 2020 to 2023 Corporate Plan in part, along with other NBN data that is
publicly available, including all past NBN Corporate Plans and Annual reports.

After many hours of research, calculations, modelling and analysis I have come up with
some interesting findings and conclusions which I believe the data and evidence supports.

In summary:

1. A full fixed line Fibre to the Premise NBN to 91.5% of homes and businesses, and I
   emphasis the business part of that, plus the fixed wireless and satellite component,
   could have been completed for a peak funding cost in the range of $56 to $58 Billion
   dollars and by the end of calendar year 2021 including all complex installations, with the
   volume rollout completed by end of financial year 2021. The peak funding cost would
   have been at most $3 Billion more than the now $55 Billion cost of the copper NBN.

2. The claims by this Government and its various Ministers over the years that a fixed line
   Fibre to the Premise NBN would cost $30 Billion more and taken another 4, or 6, or 8
   years are absurd and not supported by their own data or claims made by the NBN.

   Not even their own IT Strategic Review from late 2013 supports their claims (Scenario 2
   - $64 Billion end of CY 2023, full FTTP fixed line NBN), nor does my independent
   analysis using mostly NBN data, nor does statements by the previous NBN CEO Bill
   Morrow, who stated in a Joint Standing Committee in August 2017, that a 30,000 per
   week Fibre to the Premise rollout connection rate was possible, and in Senate
   Estimates in November 2017 and May 2018 a Fibre to the Premise CapEx of $3,900 per
   connection was possible.

   I refer you to Hansard:

   NATIONAL BROADBAND NETWORK - SENATE ESTIMATES Page 53 Thursday, 23
   November 2017:

   Senator REYNOLDS: Between the FTTP and FTTC, which you were just talking about,
   does the FTTC deliver similar speeds to the FTTP, and is it cheaper?

                                                                                        23 | P a g e
Mr Morrow: It is definitely cheaper to build FTTC historically, and I'll explain that,
because I don't want to misrepresent this. Historically, our cost for fibre to the premises
was $4,400. That would be cheaper today—Senator O'Neill, I want you to know that.
Senator O'NEILL: How much cheaper, Mr Morrow?

Mr Morrow: Probably in the neighbourhood of $500 cheaper, so think of $3,900. If we
applied the same tactics that Mr Ryan has applied to bringing fibre out to that
neighbourhood entry point, we'd probably be looking somewhere around that $3,900.

NATIONAL BROADBAND NETWORK - JOINT STANDING - Senate Tuesday, 1
August 2017 Page 66:

Mr Morrow: Because fibre-to-the premises brownfields is largely complete, we are not
doing a whole lot of it. I see a lot of questions like, 'Does NBN think this price can come
down?' Yes, sure, a little bit, but we are not building anymore. It was $4,400 for the last
few that we did—that's the historical cost, and we are leaving it there.

Could we be rolling out at 30,000 FTTP per week? I would hope that we have the
capability to do that. It is a process-improvement machine, and we are already seeing
improvements with FTTC to be able to reduce that build time and speed up the volume
that can run through that. So I would say, yes, we would've been a lot better.

Page 68:

Senator URQUHART: Mr Morrow, can I just clarify: did you say that you could hit
30,000 per week with FTTP?

Mr Morrow: It's not beyond unthinkable. We didn't analyse it. We stopped building
FTTP, so we don't know. If somebody said that's a challenge they'd throw down in front
of me, I'd take that challenge.

NATIONAL BROADBAND NETWORK - SENATE ESTIMATES Page 118 Thursday,
24 May 2018

Senator O'NEILL: Mr Morrow, you said on 27 November that NBN could deploy fibre to
the premises for $3,900 per premises. That was your evidence. Is that correct?

Mr Morrow: That would be if you took a lot of averages, so I'm being careful with that
number. It's kind of the high-level analysis like what I did for the minister before. Yes,
that would be roughly it.

Mr Rue: It's an approximation, I suggest.

                                                                                  24 | P a g e
Senator O'NEILL: That means the underlying construction cost of fibre to the premises
   would be $3,200. Is that correct?

   Mr Rue: If you take out the Telstra lease and you assume that $3,900 is correct, that
   would be correct.

   30,000 Fibre to the Premise connections a week in the last 4 years of a rollout, Financial
   Years 2018 to 2021, easily allows a 2021 end of calendar year completion date, that is
   half way through Financial year 2022, even with a slow ramp up in the early years
   between 2014 and 2017, had the Fibre to the Premise rollout continued from September
   2013, along with an average CapEx of $3,900 gives a sub $60 Billion peak funding cost
   using the actual and forecast NBN Fibre to the Premise take up rates (ie Activations)
   and ARPU in their Corporate Plans.

   Table 2: Predicted Fibre to the Premise rollout rate based largely on NBN Claims

             FTTP (B & G)   FTTP (B &G)    FTTP (B &G)
                   Yearly   Connections    Connections
  Fin Year   Connections     Per Week      Cumulative     Basis of rollout rate
2009-2014         492,000              -        492,000   Actual
      2015        730,000         14,038      1,222,000   Morrow and Chairman claim 2,000 per day(1)
      2016        950,000         18,269      2,172,000   Estimate
      2017      1,500,000         28,846      3,672,000   Estimate
      2018      1,560,000         30,000      5,232,000   Morrow claim 1 Aug 2017 - Joint standing(2)
      2019      1,560,000         30,000      6,792,000   Morrow claim 1 Aug 2017 - Joint standing(2)
      2020      1,560,000         30,000      8,352,000   Morrow claim 1 Aug 2017 - Joint standing(2)
      2021      1,560,000         30,000      9,912,000   Morrow claim 1 Aug 2017 - Joint standing(2)
      2022        738,000         26,462     10,650,000   Morrow claim 1 Aug 2017 - Joint standing(2)

   Notes (1): 2016 NBN Corporate Plan – page 23 Chairman and CEO’s message: “the
   FTTP rollout has scaled to ~1,500-2,000 premises RFS per day” – 2,000 premises per
   day equates to 730,000 connections (RFS) per year for FY 2015.

   (2): Bill Morrow former NBN CEO 1 August 2017 “Could we be rolling out at 30,000
   FTTP per week?.....So I would say, yes, we would've been a lot better…..It's not beyond
   unthinkable”

   The other evidence to support a 30,000 a week FTTP rollout rate is the fact that in June
   2015 the NBN was for a few weeks already hitting up to 24,000 per week FTTP
   connections (12 week rolling average of around 13,000), and that's when the NBN had
   half the number of contractors and staff, and were focused on FTTN trials and the
   beginnings of the HFC rollout and were actually winding down FTTP rollouts as per the
   FTTP rollout rate discussion in Senate Estimates 14th Sept 2015.

                                                                                      25 | P a g e
https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22committ
ees%2Fcommsen%2F5da16dd3-ceb5-45be-994e-c57ab82d8e67%2F0000%22

Senator CONROY: To confirm where we are up to, your fibre rollout rate to July is
about 13,000 premises a week—like 12,200 and something, which you have frequently
exceeded; you have got past 20,000 and up to 24,000 a week. That has all happened
while you had about 4,500 workers on the ground. You and your delivery partners were
also using resources to get the FTTN, FTTB and HFC rollouts off the ground, and the
FTTP rollout has been scaled back to make way for HFC and FTTN.

Mr Adcock: The FTTP rollout will naturally taper off, yes.

Senator CONROY: You have done all of that?

Mr Adcock: Yes.

If the Government and copper NBN Board had focused just on FTTP from Sept
2013 onwards the NBN evidence and NBN data suggests they would have done
30,000 FTTP a week easy from Financial Year 2018 onwards and finished 10.65
million fixed line FTTP premises by end of Calendar Year 2021.

My independent analysis, see Table 3 below, calculated remarkably very similar figures
for a peak weekly rollout rate for financial Years 2018 to 2022 for Fibre to the Premise,
had that rollout continued from September 2013, and as a consequence, a rollout
completion date also by the end of calendar year 2021.

I also add I wasn’t aware of Mr Morrow’s and Mr Rue’s statements at Senate and Joint
Standing Committee meetings until after I had completed my analysis when I started
going through Hansard transcripts and videos.

Table 3 – Independent FTTP rollout rate modelling – continuation of a FTTP
rollout from September 2013.

                 FTTP (B & G)   FTTP (B & G)   FTTP (B & G)
                       Yearly   Connections    Connection
  Fin Year       Connections    Per Week       Cumulative       Basis of rollout rate
2009-2014             492,000             -          492,000    Actual
      2015            700,000        13,462        1,192,000    My modelling and estimate
      2016          1,000,000        19,231        2,192,000    My modelling and estimate
      2017          1,500,000        28,846        3,692,000    My modelling and estimate
      2018          1,550,000        29,808        5,242,000    My modelling and estimate
      2019          1,657,300        31,871        6,899,300    My modelling and estimate
      2020          1,657,300        31,871        8,556,600    My modelling and estimate
      2021          1,657,300        31,871       10,213,900    My modelling and estimate
      2022            436,100        14,850       10,650,000    My modelling and estimate

                                                                                26 | P a g e
I also modelled and calculated a very similar FTTP cost per premise of $3,872.

The claim that a fixed line FTTP rollout to 91.5% of premises would have taken
another 4 to 8 years and would cost another $30 Billion, is not supported based
on the copper NBN’s own data and evidence to Senate Estimates and data in its
Corporate Plans.

So it’s most likely, almost certain, based mostly on NBN data and evidence, a full fixed
line Fibre to the Premise rollout to 10.65 million premises, plus the Satellite and Fixed
Wireless components, was achievable by end of calendar year 2021 had that Fibre to
the Premise rollout continued from September 2013, and had the Government and NBN
focused on a FTTP rollout instead of wasting years, and wasting tens of Billions of
dollars of tax payers money on its copper NBN.

The data and evidence indicates the peak funding cost of a FTTP NBN would have
been, at worst, in the range of $56 to $58 Billion dollars, so only $1 Billion to $3 Billion
more than the copper NBN, and as little as $6 billion more than the original 2013 FTTP
peak funding cost of $50 Billion with the 10% contingency on Capital FTTP costs.

In the 2016 NBN Corporate Plan it costed a restart from 2015 of a full fixed line FTTP
NBN - “Management estimates that an all-FTTP fixed line rollout could be completed by
2026 but possibly as late as 2028”.

It should be noted that this NBN costing was, in effect, the costing of a restart of a FTTP
rollout after this Government and copper NBN had wasted 2 years doing not much more
than so called Strategic Reviews, so called Cost Benefit Analysis, a few FTTN trials,
realising the Optus HFC cable network wasn’t usable, and the Telstra HFC network
would require major upgrading at considerable cost and time, and had already wasted
and committed (to June 2016) $14 Billion on its copper NBN.

Independent analysis indicates (Table 4) had a restart in July 2015 occurred of a full
fixed line FTTP rollout to 91.5% of premises it could have been completed around the
end of calendar year 2023. This is based on using mostly NBN data or NBN claims on a
FTTP weekly rollout rate, and with a very slow ramp up over 4 years.

The claim by this Government on its 2015 modelling and costing that a restart of a
full fibre FTTP NBN would have taken another 6 to 8 years is not supported based
on the copper NBN’s own data and evidence to Senate Estimates and data in its
Corporate Plans.

                                                                                   27 | P a g e
Table 4 – Independent predicted FTTP rollout rate modelling had a restart
   occurred in 2015

              FTTP (B & G)   FTTP (B & G)   FTTP (B & G)
                    Yearly    Connection    Connections
  Fin Year    Connections       Per Week     Cumulative     Basis of rollout rate
2009-2014          492,000              -        492,000    Actual
       2015        405,000          7,788        897,000    Actual
       2016         70,000          1,346        967,000    Estimated Ramp up
       2017        500,000          9,615      1,467,000    Estimated Ramp Up
       2018      1,000,000         19,231      2,467,000    Estimated Ramp Up
       2019      1,300,000         25,000      3,767,000    Estimated Ramp Up
       2020      1,560,000         30,000      5,327,000    Morrow claim 1 Aug 2017 - Joint standing
       2021      1,560,000         30,000      6,887,000    Morrow claim 1 Aug 2017 - Joint standing
       2022      1,560,000         30,000      8,447,000    Morrow claim 1 Aug 2017 - Joint standing
       2023      1,560,000         30,000     10,007,000    Morrow claim 1 Aug 2017 - Joint standing
       2024        793,000         15,250     10,800,000    Morrow claim 1 Aug 2017 - Joint standing

3. Analysis indicates $1.7 Billion dollars a year (possibly as much as $1.9 Billion) in
   revenue lost, extra operating expenditure, and extra ongoing capital expenditure on the
   copper NBN, starting in Year 2022, in comparison to a full fixed line Fibre to the Premise
   NBN had that rollout continued in 2013, based on, in large part, data in the 2020 NBN
   Corporate Plan and the leaked Optus HFC NBN overbuild report.

4. A full fixed line Fibre to the Premise NBN, had that rollout continued in 2013, would have
   easily paid for the modest additional peak funding debt costs through higher revenues,
   lower operating and lower ongoing capital costs.

5. The NBN’s predicted take up rates of services by consumers is:

   -    on the copper Fibre to the Node areas a low 70% in 2022 and 2023,

   -    HFC 76% in 2022 and 80% in 2023, and

   -    Fibre to the Curb 79% in 2022 and 2023,

   -    Fibre to the Premises areas of 80% to 82% in 2022 and 82% in 2023,

   as calculated using data in the 2020-23 NBN Corporate Plan – that is Activations
   divided by Ready to Connect (RTC) by technology type on Page 49.

   Analysis shows that the copper NBN, based on its own forecasts for 2023, will have
   636,000 less users than it would have had with a full fixed line Fibre to the Premise NBN
   network.

                                                                                     28 | P a g e
Table 5: Lost revenue due to lower predicted take up rates on copper
   technologies vs Fibre to the Premise as per the 2020 NBN Corporate Plan.

                                                                                            Lost Revenue per Year
         2023     Takeup Rate    ARPU                                        % Difference   just on take up rates on
   Technology       Fixed line     per                                        FTTP(B) to
         Type            2023    month   Months   Activations        RTC             MTM        MTM Technologies

FTTP Brownfield          82%       $51       12      900,000     1,100,000            0%                         $0
FTTP Greenfield          82%       $51       12      900,000     1,100,000            0%                         $0
       FTTN/B            70%       $51       12    3,300,000     4,700,000           12%              $333,818,182
         FTTC            79%       $51       12    1,100,000     1,400,000            3%                $27,818,182
          HFC            80%       $51       12    2,000,000     2,500,000            2%                $27,818,182
                                                                10,800,000     Year 2023              $389,454,545

                                                                                            Lost Revenue per Year
         2022     Takeup Rate    ARPU                                        % Difference   just on take up rates on
   Technology       Fixed line     per                                        FTTP(B) to
         Type            2022    month   Months   Activations        RTC             MTM        MTM Technologies
FTTP Brownfield          82%       $49       12      900,000     1,100,000            0%                         $0
FTTP Greenfield          80%       $49       12      800,000     1,000,000            2%                         $0
       FTTN/B            70%       $49       12    3,300,000     4,700,000           12%              $320,727,273
         FTTC            79%       $49       12    1,100,000     1,400,000            3%                $26,727,273
          HFC            76%       $49       12    1,900,000     2,500,000            6%                $85,527,273
                                                                10,700,000     Year 2022              $432,981,818

   Notes: The revenue for 2022 FTTP Greenfield has been excluded.

   These predicted lower copper technology take up rates and the consequences for
   revenue by themselves proves the failure of this Governments copper so called Multi
   Technology Mix policy decisions in 2013 and 2014 and since.

6. There is a reduction of 200,000 predicted Activations for Year 2022 on the Fibre to the
   Node and basement part of the copper NBN network between the 2019 and 2020 NBN
   Corporate Plans yet RTC stays the same in both Corporate Plans.

7. The predicted difference in take up rates, from 2022, between Fibre to Node and the
   Fibre to the Premise part of the copper Multi Technology Mix NBN is 12%.

8. Clearly it seems, the NBN is predicting a massive threat from the rise of 5G broadband
   on its already outdated and slow copper NBN technologies, in particular Fibre to the
   Node.

   The financial consequences for the copper NBN and the tax payers will be catastrophic.

                                                                                                 29 | P a g e
9. Analysis of the copper NBN take up rate forecasts indicates up to $433 Million dollars in
   2022 and $389 million dollars in 2023, in revenue lost due to lower take up rates on
   Fibre to the Node in particular, but also HFC and Fibre to the Curb lower take up rates
   than Fibre to the Premise, and reductions in forecast Fibre to the Node Activations,
   amounting to a 11% to 10% hit on its total forecast revenue for 2022 and 2023.

10. The lost revenue per year on the speed limited FTTN, FTTB, FTTC and large parts of
    the HFC copper NBN Network now that the NBN has introduced 250 Mega bit per
    second (Mbps) and 1 Giga bit per second (Gbps) speed plans, is likely be in the order of
    at least $280 million dollars per year based on, in part, overseas trends and data, and
    the 1 Gbps FTTP take up rate with Aussie Broadband.

   In New Zealand – Feb 2020

   https://www.zdnet.com/article/chorus-concerned-users-switching-away-to-wireless-due-
   to-fake-copper-shutdown/

   “The company (Chorus) said it now has 68% of its UFB connections on fibre, with
   1Gbps plans now accounting for 13% of its fibre plan uptake”

11. A line item analysis indicates a specific to the copper NBN an extra operational
    expenditure cost of at least $726 million dollars in year 2022, and likely increasing every
    year, that would not be incurred on a full fixed line Fibre to the Premise NBN.

12. The leaked NBN report in relation to the Optus HFC overbuild published by Fairfax and
    mentioned in the Conservation website states:

   https://www.smh.com.au/politics/federal/leaked-nbn-budget-blowout-documents-
   threaten-to-embarrass-malcolm-turnbull-20151125-gl7fso.html

   https://www.scribd.com/doc/291057120/Leaked-NBN-document

   http://theconversation.com/what-will-the-nbn-really-cost-51562

   “In fact, the leaked nbn co document mentioned earlier shows that the operational costs
   of FTTN network are 67% more than for FTTP, and the operational costs of HFC are
   25% more”.

   Applying this to the operating expenditure data in the NBN 2020 Corporate plan
   calculates out to an additional at least $760 Million dollars a year, in Year 2022, in extra
   operational expenditure, specific to the copper NBN, that would not be incurred on a full
   fixed line Fibre to the Premise NBN. This tends to verify the line item analysis.

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