ACCAN and Internet Australia have jointly submitted to industry peak body Communications Alliance’s consultation on the deregistration and repeal of the End to End Network Performance for the Standard Telephone Service (STS) Code.

The Code sets out technical rules for the performance of standard voice services. These rules mean that voice services operate within acceptable standardised levels of echo, delay and loudness, supporting positive consumer experience. Our submission argues that consumers both need and deserve the high quality of voice telephony supported by the Code.

Communications Alliance considers that C519 no longer holds currency and practical value due to frequently evolving telecommunications technology and the declining use of the STS, and the current scope of the Code.

While acknowledging that the scope of the Code has changed with new network technology, ACCAN and Internet Australia believe that its aims and principles are as applicable now as when it was developed. Deregistration of the Code would mean there is no enforceable requirement to support high performing voice service quality, and could result in a poorer experience for consumers using voice telephony. We submit that the Code can be readily updated by amending the definitions of the technology outlined in the Code along with the measures of quality so that they are applicable to voice services over IP-based networks.

Such amendments should be technology-neutral where possible to future-proof the Code against further technological changes and ensure that all voice services used by consumers are protected regardless of the technology that they use. This is particularly necessary as Australians make the switch to the NBN, a process that has raised widespread issues about the quality of services.

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