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Advocacy on Telco Act Ramped Up

Advocacy on Telco Act Ramped Up

Advocacy on Telco Act Ramped Up
Date: 28-Nov-2023

Over a number of years the water industry has had challenges with the way telecommunication providers are “piggy backing” their infrastructure on critical water assets.  Telco infrastructure have created drinking water risk for our communities and worker safety risk for staff in the industry.

Following the issue being raised by water service providers and a number of QWRAP Regions, over the past three months, qldwater CEO Georgina Davis has been actively working on this matter with State and Federal regulators.

Last week, we had a very productive meeting with the Department of Infrastructure who are eager to work with the industry to examine the issues and challenges that water service providers are experiencing.

As part of building a body of evidence, to support the changes that our industry is recommending, it is very important that our industry register any issues and complaints formally with the telco regulator.

As such, we are looking to hear from any water service providers that are experiencing difficulties in this area, and wanting to help them to lodge the issues with ACMA. (The ACMA Mobile Phone Base Station Deployment Complaint Form can be downloaded here).

Any water service providers with concerns in this area are encouraged to reach out to Georgina directly.

Summary of work to date

Key risks and problems for the water industry include:

  • Damage to assets from telecommunications infrastructure construction on or adjacent to water industry assets.
  • Workplace health and safety risks to water industry staff from EME exposure, dangerous site conditions and damaged water infrastructure.
  • Costly damage to our infrastructure and the fact that our customers and communities are having to pay for this work.
  • Drinking water quality risks for our communities from damaged infrastructure and an inability of water service providers to undertake appropriate cleaning, monitoring and maintenance activities on the water infrastructure.

Key issues of concern raised by members have included;

  • Clear contradictions between legal obligations on the urban water sector under the Security of Critical Infrastructure Act and the Telco Act.
  • The designation of critical water infrastructure as a low impact site under the Telco Act (based on visual amenity values).
  • The in-effective nature of the Telco Act to control safety risk and drinking water risk. (we are aiming to have the Act amended to give a “right of refusal” to water service providers for accepting telco infrastructure).
  • The Seqwater Case and the issues that it raises for the telco act.
  • The shutdown of the 3G network. qldwater is advocating to Government they need to have a system to enforce the safe removal of legacy assets from our members infrastructure and aim to minimise costs and risks for the Queensland Water Sector
  • The ineffective nature of the telco industry regulator ACMA and the controls that are available under the current act and a series of strengthening recommendations for that instrument.
  • Template Agreement – many QWRAP regions have indicated a desire for template of an agreement that they can present to telcos. qldwater are seeking financial support for this work from the Government and have engaged a legal expert to draft this material (ex Seqwater lead for these matters)
  • The fact that a Parliamentary committee reviewed this issue and supported many of the issues our industry is raising and that there has been limited response to these matters by the Government. ParlInfo - Standing Committee on Communications and the Arts : 19/11/2019 : Deployment, adoption and application of 5G in Australia (aph.gov.au)]

qldwater will continue to work with members to formally lodge issues with the telco regulator ACMA. Recent discussions with Minister Rowlands office indicate that they will monitor responses and this will help to build the case for regulatory reform.

Other relevant information relating to Telcos

Letter to Communications Minister Regarding Telecommunications Act Deficiencies - Release Date 28-Jul-2023: - Letter to The Hon Michelle Rowland, Minister for Communications, Department of Infrastructure, Transport, Regional Development, Communications and the Arts, drawing urgent attention to several outstanding issues arising from deficiencies in the regulatory framework surrounding telecommunications deployment by telecommunication carriers under the Telecommunications Act 1997 impacting upon the water sector.

The Fundamentals of Telco on Towers Webinar delivered by Murray Thompson, July 2021

WIOA WaterWorks Special Feature on Telcos - Release Date 13-Dec-2019: - An extract from WIOA Waterworks special feature on telcos and water assets. It provides a great summary of the regulatory environment, risks every service provider which hosts telecommunications equipment on its infrastructure need to consider, and the process for Low Impact Facilities including how to object.

2019 Biloela Conference QLDWater Telcos on Reservoir Presentation - Release Date 05-Apr-2019: - Biloela training day - safely accessing reservoirs

SEQ Telco Conditions of Approval - Release Date 12-Apr-2018: - Sample Document: Conditions of Approval

SEQ Telco Email Response Objection to Land Entry Activity - Release Date 12-Apr-2018: - Sample document: Email response objection to land entry activity.

SEQ Telco Email Response Reasons to Sustain Rent Prices - Release Date 06-Apr-2018: - Sample document: Email indicating reasons to sustain rent prices.

SEQ Telco Seqwater Telemetry Access Permit - Release Date 06-Apr-2018: - Seqwater sample document: Telemetry Access Permit for use on reserve land. The example is for a 3 year term (with option) and includes recommendations from the water directorate guidelines.

SEQ Telco Summary Report March 2018 - Release Date 06-Apr-2018: - Summary Report: Opportunities for South East Queensland Water Service Providers to promote stronger commercial relationships and better manage risks with telecommunications providers through lease arrangements and internal procedures March 2018.

SEQ Telco Summary Report March 2018 - Release Date 06-Apr-2018: - Summary Report: Opportunities for South East Queensland Water Service Providers to promote stronger commercial relationships and better manage risks with telecommunications providers through lease arrangements and internal procedures March 2018.

SEQ Telco Telecommunications Installation Checklist for Designers - Release Date 06-Apr-2018: - Sample document: Telecommunication Facility Installation at Water Utility Sites - Checklist for Designers

3rd Party Infrastructure on Water Supply Reservoir Guidelines Volume 1 - Release Date 15-Jun-2017: - The Third Party Infrastructure on Water Supply Reservoirs Guidelines is a joint publication between qldwater and NSW Water Directorate. This document has been divided into two (2) volumes. Volume 2 (below) contains Appendices A to E which are also available separately under the "Other Resources" tab.

3rd Party Infrastructure on Water Supply Reservoirs Guidelines Volume 2 - Release Date 15-Jun-2017: - The Third Party Infrastructure on Water Supply Reservoirs Guidelines is a joint publication between qldwater and NSW Water Directorate. This document has been divided into two (2) volumes. This Volume contains Appendices A to E which are also available separately under the "Other Resources" tab.

3rd Party Telcos - AMTA RF Safety Compliance Fact Sheet - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Exclusion Zones Factsheet - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Fact Sheet about the MCF - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Fact Sheet Working Safely at Sites - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Industry Code Fact Sheet - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Mobile Base Stations and Health Fact Sheet - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Reading the Australian Radiation Protection and Nuclear Safety Agency EME Report - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

3rd Party Telcos - Regulatory Requirements for Mobile Base Stations - Release Date 07-Jun-2017: - Sample document forming part of Volume 2 of the qldwater / NSW Water Directorate "3rd Party Infrastructure on Water Supply Reservoir Guidelines".

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