In addition, it is concerning that the government is directly funding UFB deployment in urban areas but it is not actually putting any funding into rural areas as part of the RBI." It continued to be funded by the industry through the telecommunications development levy.
Ms Gower also claimed that the end-user impact of the proposed utility-style pricing regulation remained unclear.
"Primarily our members want internet and phone prices to remain affordable, while also encouraging wholesale network operators to invest appropriately in improving rural infrastructure," she said.
"We are concerned about how changes to wholesale prices will be treated by retail service providers and reflected in retail prices."
The review also proposed exploring options for promoting competition in the mobile market.
"Mobile coverage is seriously lacking in rural areas, despite the fact that these days it is considered a basic lifeline in emergency situations," she said.
RWNZ's submission encouraged the government to proceed with options that encouraged greater infrastructure sharing and competition between mobile network operators.
It also suggested that additional government stimulus might be needed to fund further investment by mobile network operations in the most uneconomic areas of the network.