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The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability recently sought submissions to its Promoting Inclusion issues paper. The aim of the issues paper was to gather information about what makes an inclusive society and what steps can be taken to promote a more inclusive society.

In ACCAN’s submission to this issues paper we explained that available, affordable and accessible digital communications technologies can facilitate a more inclusive and accessible society. We outlined the work we have undertaken in relation to the Ideal Accessible Communications Roadmap, and identified communications-related actions that could contribute to a more inclusive society.

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ACCAN made a submission in response to the ACCC’s proposed enhancements to the Broadband Speeds Claims – Industry Guidance. ACCAN submitted that to avoid misleading the consumer telco retailers should:

  • Use the lowest end of any speed ranges provided by a wholesale product in off-peak speed marketing information, and RSPs should inform consumers if the off-peak speed changes;

  • Not advertise ‘burst speeds’ – off peak high speeds that are only occasionally available for short periods – as off-peak speeds;

  • Be transparent about the suitability and quality of their plans and products for online gaming, taking into account periods when the broadband network has high traffic demand;

  • Provide faster connection speeds in plans for online gaming to deliver a good customer experience, particularly in current circumstances where COVID-19 work from home and home schooling restrictions are increasing the strain on the broadband network;

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In late 2020 the Department of Social Services consulted on the Outcomes Frameworks for the National Disability Strategy (the Strategy) and the National Disability Insurance Scheme (NDIS). The Outcomes Frameworks are intended to track progress over time to consider whether the Strategy and NDIS are improving the lives of people with disability in Australia.

In ACCAN’s submission, we explained that accessible and affordable digital communications technologies are essential to facilitate a more inclusive and accessible society for people with disability in Australia. We argued that outcomes and measures relating to digital communications technologies must therefore be included in the Outcomes Frameworks for both the Strategy and the NDIS.

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The ACMA have proposed new rules to improve telecommunications service standards.

ACCAN supports the draft rules because they ensure telcos pass on to affected customers certain rebates received from wholesalers, such as NBN, when issues of delayed connections and fault repairs, and missed appointments occur. In our submission, we urged that the customer should receive the full amount of rebate, whether that be a direct financial payment or through a measure put in place by their telcos to fix the issue, such as 4G back-up modems.

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ACCAN recently made a submission to the Digital Industry Groups (DIGI) consultation on their voluntary industry Code on disinformation. The Code has been developed in response to ‘Regulating in the Digital Age: Government Response and Implementation Roadmap for the Digital Platforms Inquiry’. The Code outlines what the digital platforms will do to address concerns regarding disinformation and credibility signaling for news content in the Australian context.

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The Federal government Department of Infrastructure, Transport, Regional Development and Communications is consulting on guidelines for funding proposals by the telco industry under Round 5A of the Mobile Black Spot Program (MBSP). Following our submission on the design of Round 5A, ACCAN has provided additional comments on the draft guidelines.

ACCAN supports elements of the Draft Guidelines introduced to target areas prone to natural disasters, promote competition outcomes in previously under-serviced regions and encourage active infrastructure sharing between mobile network operators and infrastructure providers.

ACCAN also advocated in favour of broadening the eligibility for funding to include:

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ACCAN submitted to the review of the ACCC’s Measuring Broadband Australia (MBA) program. Launched in 2017, the MBA measures broadband speeds on NBN Fixed Line broadband services.

ACCAN strongly advocated in favour of retaining the Measuring Broadband Australia scheme because the program has resulted in:

  • A decline in the number of consumer complaints;
  • Improved broadband performance by encouraging competition between telcos selling NBN Fixed Line broadband services;
  • enforcement action against RSPs who have made misleading claims about broadband speeds; and
  • Collection and reporting of data that has influenced policy decisions for the benefit of consumers.

ACCAN also encouraged the ACCC to expand the program to measure the performance of:

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The Department of Social Services recently released a position paper and sought feedback from the community on the development of a new National Disability Strategy. ACCAN made a submission to this consultation. Our submission was endorsed by 25 organisations and ACCAN members.

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NBN Co sought feedback on its wholesale pricing for selected services. The paper was split into two parts:

  • Part A focused on the short term (24 month) residential services discount bundles as well as the cost for connectivity virtual circuit (CVC). CVC is the network capacity purchased by retail service providers (RSPs).
  • Part B looks at the longer-term pricing construct of wholesale services, changes to voice only and business grade services as well as an offering to support low-income households.

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ACCAN recently responded to the Senate Standing Committees on Environment and Communications inquiry into the Broadcasting Legislation Amendment (2021 Measures No.1) Bill 2021. This Bill proposes amendments to the Broadcasting Services Act 1992, including in relation to subscription television captioning rules.

In our submission ACCAN stated that the Broadcasting Services Act 1992 remains the most appropriate place for captioning requirements to be set out. We recommended broader amendments to the Broadcasting Services Act 1992 to embed the same levels of access features (including captioning, audio description and Auslan interpreting) across all subscription, video on demand, commercial free-to-air and national broadcasters. We made a similar recommendation in response to the Media Reform Green Paper.

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The Department of Infrastructure, Transport, Regional Development and Communications sought comments on proposals to amend part 20A of the Telecommunications Act 1997 to boost pit and pipe provision in new developments.

Currently unincorporated developers are not required to build the necessary pits and pipes to allow network providers to install telecommunications in new buildings. Whilst most developers provide the necessary infrastructure to support telecommunications, there are a small number of premises built, in areas serviced by fixed-line telecommunications networks, without telecommunications pit and pipe, leading to inconvenience and additional costs for occupants of these premises.

This problem affects up to 3,000 premises a year and comes at a cost to new occupants as they will experience a lack of service, delays in service, cost of retrofitting and the cost of interim services.

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Communications Alliance, the peak body for the telco industry, is undertaking a routine review of C515:2015, the industry Code on Pre-Selection.

Pre-selection allows consumers with landline phone services on the copper network to use one telco for certain types of calls, but another for different types of calls, such as calls to mobile or international numbers. The Pre-Selection Code sets out technical processes for the industry to follow when establishing and delivering pre-selectable services.

In our submission, ACCAN said that while consumer demand for pre-selection has dropped substantially, the Pre-Selection Code should remain in place until the telco regulator, the ACMA, revokes or changes the Pre-Selection Determination.

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