Submissions


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ACCAN made a submission to the Mobile Black Spot Program (MBSP) Round 5A Discussion Paper.

Lack of telecommunications connectivity denies regional, rural and remote communities the socio-economic benefits that people in metropolitan areas take for granted. Yet mobile network providers are now at a point where there is minimal return on investment for them in rural, remote and regional locations and there is little incentive for them to build infrastructure in these areas.

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ACCAN has made a submission to the Department of Infrastructure, Transport, Regional Development and Communications consultation on options to support Australian stories on our screens. Australian content has cultural value for all Australians, including people with disability, and as such everyone should have access to Australian content.

In our submission, ACCAN explained that some accessibility features are readily included on Australian content, whereas others aren’t available (or aren’t consistently available). This is because there are no clear legislative requirements or protections to ensure access to Australian programming across all platforms.

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ACCAN has commented on the proposed update to the Federal Government’s telecommunications in new developments policy.

ACCAN agrees with the policy’s objectives to provide people moving into new developments with ready access to modern telecommunications, both voice and broadband, and to create a competitive market for the provision of such infrastructure. However, ACCAN identified the following areas for improvement in the proposed approach:

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The Department of Infrastructure, Transport, Regional Development and Communications is developing a trial to assess alternative ways of delivering voice (home phone) services in regional, rural and remote (RRR) areas. ACCAN previously commented on how these trials should be designed, run and evaluated. This round of consultation sought comments on the draft Grant Guidelines, Agreement and Application Form.

ACCAN supports the Alternative Voice Services Trials. Our submission makes a number of recommendations to ensure no consumer is worse off by participating in the trials. We also provided feedback on how to make sure the trials are as useful as possible. ACCAN reiterated the need for trialled services to be assessed not just in terms of value for money, but also in terms of quality.

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Some of Telstra’s networks are exempt from Parts 7 and 8 of the Telecommunications Act 1997. You can read more about this here. The Department of Infrastructure, Transport, Regional Development and Communications is seeking comments on Telstra’s request to extend its exemptions for its South Brisbane Velocity and other Velocity phone and internet networks. The current exemptions expire on 30 June 2020, so Telstra has asked the Minister of Communications, Cyber Security and the Arts to extend the exemptions further.

Consumers in the Velocity footprint have a difficult time getting affordable and good quality internet that is suitable to their needs. ACCAN’s submission acknowledged the necessity to grant Telstra’s request this time, otherwise current customers in the Velocity footprints may be left without a service after 30 June 2020. We argued that Telstra’s exemptions should be granted for 2 years at most. We also argued that Telstra should have a plan to sell the networks and should report on this regularly to the ACCC and the Department.

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ACCAN submitted to the ACCC’S draft determination of NBN’s Long-Term Revenue Constraint Methodology (LTRCM) 2018-19. The LTRCM determines NBN’s allowed annual regulated revenue by examining various components such as operating expenditure, depreciation and return on capital.

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ACCAN, the Consumers Federation of Australia and the Consumer Action Law Centre jointly submitted to the ACCC’s consultation on authorisation for NBN Co and telecommunications companies who are members of a Special Working Group. The ACCC granted an interim authorisation and is considering issuing a final determination in September.

The authorisation allows members of the group to engage in conduct which would normally be viewed as anticompetitive and illegal. The purpose of the authorisation is so that members of the group can work together to support best performance of the network and hardship measures during the COVID-19 pandemic.

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ACCAN wrote a submission in response to the draft Reducing Scam Calls Industry Code, released for comment by the Communications Alliance. ACCAN welcomed the draft Code as an acknowledgement of the important role the telecommunications industry can play in the control of scam calls which pose a risk to consumers.

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ACCAN has made a submission in response to the Australian Human Rights Commission’s Human Rights and Technology Discussion Paper. This follows our 2018 submission in response to the Human Rights and Technology Issues Paper.

The Discussion Paper considers possible responses to the human rights challenges and opportunities brought about by new and emerging technologies. It consolidates the responses to previous rounds of consultation, and outlines the Australian Human Rights Commission’s thinking on a range of issues. In the Discussion Paper, the Australian Human Rights Commission offers a range of proposals designed to address the impact that new and emerging technologies have on human rights. This includes discussion of the impact of Artificial Intelligence (AI) and AI-informed decision making, and of accessible technologies.

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ACCAN has made submissions to various state-based inquiries regarding the 2019-20 bushfire season, including the NSW Independent Bushfire Inquiry, the SA Fire and Emergency Service Commission's independent review into South Australia's 2019-20 bushfire season, and the Inspector-General for Emergency Management's inquiry into the 2019-20 Victorian fire season. We have also submitted to the Royal Commission into National Natural Disaster Arrangements and the Senate Finance and Public Administration References Committee. ACCAN’s submissions focused on the impact of bushfires on communications infrastructure and reliability, and how this affected communications consumers.

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The ACMA is reviewing the Telecommunications (Provision of Pre-Selection) Determination 2015 to assess whether it remains fit-for-purpose. The Determination outlines the requirement for telco service providers to allow consumers to use ‘pre-selectable services’. Pre-selection allows consumers with landline phones on the copper network to use one telco service provider for local calls to other landline phones, but another provider for other types of calling, to mobile or international numbers for example.

ACCAN has no objection to the ACMA taking steps to withdraw the Determination, so long as the ACMA is certain there will be minimal impact on residential and small businesses consumers. Should the Determination be withdrawn, any consumers with pre-selectable services activated on their account need to be provided with adequate information and support while transitioned away from these services.

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ACCAN has written a submission in response to the draft Regional Connectivity Program Grant Opportunity Guidelines.

ACCAN was pleased to see the Grant Opportunity Guidelines prioritised the place-based needs of local communities and directed applicants to draw on advice from local industry, business, and community groups, not-for-profits and First Nations community-controlled organisations. The inclusion of three funding streams, including a low-budget option for smaller projects, will also mean more regional, rural and remote communities will be in a position to apply for funding.