How consumers are migrated from Telstra to NBN Co is set out in procedures in a Migration Plan. These were initially put in place in 2011 when the Government's NBN plan was to rollout fibre to the premises (FTTP). Since then the National Broadband Network (NBN) model has changed to be delivered using a Multi Technology Mix (MTM), using technologies such as fibre to the node (FTTN), fibre to the basement (FTTB) and HFC. The new range of technologies requires a revised Migration Plan. The Department of Communications ran a consultation over the Christmas/New Year period on principles to be used in the new Migration Plan, and ACCAN has submitted identifying some consumer issues to be taken into account.

ACCAN believes that the proposed revisions to the Migration Plan principles address some of the issues that end users have experienced during migration to date and will hopefully improve the migration experience. The revised plan provides further clarity on a number of areas including; areas of responsibility, procedures in instances of disconnection, procedures around HFC services, information security and the Migration Assurance Policy to protect customers and support service continuity.

However, we are concerned that some areas have not been fully addressed and end users will continue to experience issues. Firstly, there is no clear procedure for areas which are not Telstra's responsibility, or which are dependent NBN Co. ACCAN feels that this will result in frustration for consumers who are passed between the numerous bodies involved. Secondly, responsibility for a chain of communications to consumers is not established. This is likely to result in Telstra, and other organisations, not engaging with consumers on issues which do not directly fall within their designated responsibility areas. Thirdly, ACCAN is concerned that end users will continue to experience breaks in their services. Finally, ACCAN is concerned that the instruments do not go far enough to ensure that there is a level playing field between the competitors and will limit consumer choice.

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