RURAL and regional Victoria have been short-changed by the $36 billion National Broadband Network roll-out.

That's according to a new report which found the project would do little to fix crucial mobile and broadband black spots.

In a strongly worded submission to the Regional Telecommunications Review, the Victorian Government argues the NBN roll-out project does not focus enough on fixing poor telecommunications in rural and regional areas.

"Disparities between regional and metropolitan Victoria may persist during this next phase of broadband development, and could potentially magnify the disadvantages of regional communities as their metropolitan counterparts enjoy accelerated benefits of broadband as the NBN is rolled out," the submission warned.

Late last year, the Federal Government announced a 12-month construction list of NBN sites nation-wide.

Melbourne City and inner-city Brunswick were among the seven areas nominated in Victoria, alongside Ballarat, Bacchus Marsh, Melton, South Morang and Tullamarine.

Victorian Minister for Technology Gordon Rich-Phillips questioned why rural and regional areas had not been prioritised in the 12-month roll-out.

"Obviously a lot of existing broadband gaps are in rural and regional Victoria and they are the areas that should have been prioritised," he said.

The Government's submission pointed out that nearly a third of Victoria's unmet demand for broadband was in regional areas.

Mr Rich-Phillips also said there was a risk the NBN could be seen as a "panacea" for all communications problems faced by rural residents and that the Federal Government needed to focus equally on mobile coverage. "The NBN does nothing to fix mobile black spots, which is a huge issue for a lot of Victorian residents," he said.

An NBN Co spokeswoman said the first-release sites were chosen to reflect a cross-section of areas, and she pointed to the inclusion of Ballarat as evidence that Victorian rural and regional areas were not being ignored.

Independent MP Rob Oakeshott, whose support for the minority Gillard Government partly hung on the roll-out of the NBN to regional areas, said it was up to the Victorian Government "to provide more details as to why this policy is somehow inequitable in their eyes".

Broadband, Communications and Digital Economy Minister Stephen Conroy did not return calls.