Submissions


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The Australian Communications and Media Authority (ACMA) conducted a consultation regarding proposed amendments to the Telecommunications (Emergency Call Service) Determination 2019. This Determination imposes requirements on carriers, carriage service providers and emergency call persons (Telstra and the National Relay Service provider) regarding access to the emergency call service (000, 112, 106). This consultation was in response to issues raised by the Senate Standing Committee for the Scrutiny of Delegated Legislation.

ACCAN recently submitted to the ACMA’s review of the NBN consumer experience rules.

The rules focus on improving the way the telco industry handles consumer complaints about the NBN, provides information about the NBN to consumers, and ensures consumers have access to a working service. The consumer experience rules also provide for the regulation of the migration of services from the legacy network onto the NBN.

ACCAN has provided a brief submission to the Communications Alliance review of Guideline G660:2018, Assisting Customers Experiencing Domestic and Family Violence. This Guideline offers education to telco providers about the impacts of domestic and family violence and how they can help customers who are experiencing domestic or family violence.

In our response, ACCAN outlined that more information is needed about whether the Guideline is currently being used by telcos. Once more is known about the use of the Guideline, ACCAN believes that the intended audience of certain parts of the Guideline could be reviewed to make it more user friendly for telco staff. We also suggested that the length of the Guideline could be reviewed given the length of other industry guidance notes regarding domestic and family violence.

ACCAN recently submitted to ACMA’s Draft Telecommunications (Mobile Number Pre-Porting Additional Identity Verification) Industry Standard 2020. ACMA drafted the Standard to help prevent the unauthorised porting of mobile service numbers and reduce the damage done to consumers from this activity.

Mobile number fraud is a gateway to identity and financial theft. ACCAN is aware of numerous reports by victims of fraudulent number porting which reinforce the need for stronger protections.

ACCAN recently submitted to the Department of Communications and the Arts review of the 2015 Telecommunications in New Developments (TIND) Policy. The policy governs the development of telecommunications infrastructure in new greenfields sites and competition between private sector infrastructure providers and NBN Co.

ACCAN is regularly contacted by consumers residing in non-NBN networked new areas that are experiencing poor service outcomes through slow or intermittent services, while facing higher than competitive retail prices for services that are often lower value than their NBN alternative. However, systematic evidence of poor outcomes is limited due to the opacity of current reporting arrangements.

ACCAN recently submitted to the Joint Parliamentary Committee on the NBN inquiry into the business case for the NBN and experience of small businesses.

The Committee is inquiring into the rollout of the NBN and the performance of NBN Co. in relation to its key financial and economic forecasts, coverage, the delivery of services to small and medium businesses, as well as pricing and in particular the effect of pricing on low-income and rural and regional consumers.

In December 2019, ACCAN submitted to the Senate Environment and Communications Legislation Committee consultation on the telecommunications legislative reform package. The consultation focused on two Bills under consideration by the Federal Parliament – the Telecommunications Legislation Amendment (Competition and Consumer) Bill and the Telecommunications (Regional Broadband Scheme) Charge Bill.

ACCAN recently submitted to the ACCC’s inquiry into NBN Access Pricing. The inquiry examined the possibility of ACCC regulating the price of entry level NBN services, in order to facilitate consistent pricing for services that are equivalent to legacy ADSL internet services.

ACCAN is supportive of measures being taken to allow for consumers to smoothly transition to NBN services without facing material increases in the price of their existing service.

Although broadly supportive of the ACCC’s inquiry, ACCAN argued that:

  • The best approach to providing pricing relief is through the introduction of a funded concessional broadband service for low income households;
  • If pricing regulation of the NBN is implemented, it should be applied to the 25/5Mbps speed tier rather than the 12/1Mbps speed tier;
  • The proposed retail price point of $60 for (a 12/1Mbps service) was well in excess of what many consumers can afford to pay.

The telco industry peak body, Communications Alliance, is reviewing the Integrated Public Number Database (IPND) Code. The IPND is a secure database that stores all listed and unlisted public numbers assigned to communications services. These include numbers assigned to a telephone, fax machine, or connected device like a tablet or car that can make and receive calls via Bluetooth. The IPND includes information about the service, including the name of the customer, the telco that provides the number, and the where the ‘service address’ is (that is, the street address where the customer lives or where telephone service is located).

The IPND Code sets out rules for telcos that supply information to the IPND, and for anyone that uses information from the IPND. In a 2018 review of the IPND, the ACMA found that a large portion of information was inaccurate. The IPND Code is being updated to make sure that telcos frequently compare their customer information with information in the IPND, and correct any discrepancies that are discovered.

The ACMA is reviewing rules about international mobile roaming (IMR) for Australian telcos. They have proposed that International Mobile Roaming rules should be applied via a service provider determination, rather than an industry standard. This makes the rules administratively simpler to change and increases the maximum penalty for non-compliance. The ACMA has proposed a few other updates to mobile roaming regulation with the intention of making the rules more flexible for customers and telcos.

ACCAN supports of some, but not all, of the proposed changes. We agree with the tightening of existing International Mobile Roaming rules. However, we are concerned that some flexibility measures are too discretionary, and fail to provide appropriate consumer protections.

ACCAN made a submission to the House of Representatives inquiry into 5G in Australia. ACCAN highlighted the need for whole of community engagement in the roll-out of 5G across Australia, emphasising the role that the telecommunications industry and government agencies need to undertake to ensure that consumer information is easily accessible, reliable and evidence based.

ACCAN participated on the review of the industry code, C625 Information on Accessible Features for Telephone Equipment Code. The Code requires handset manufacturers to provide information about the accessibility features on their handsets to telcos. It also requires that handset manufacturers make this same information freely available to consumers. The updated Code also includes ACCAN’s Accessible Telecoms service as an alternative way for consumers to get information about accessibility features for handsets.