ACCAN recently submitted our comments on the Variation to the NBN Co Special Access Undertaking (SAU) Draft Decision consultation.
The SAU sets out the regulatory framework for determining NBN Co’s service offerings, revenue, expenditures and service standards. The variation sets out a framework for extensive engagement with Consumer Advocacy Groups, such as ACCAN to inform the prioritisation of expenditure to align with consumer expectations. While the proposed variation to the SAU represents a material step forward, there is no provision to resource the extensive engagement NBN Co is proposing to undertake, accordingly we consider further refinements are needed.
ACCAN’s submission argued that NBN Co’s proposed variation to the SAU should be revised to:
- embed genuine consumer engagement on proposed expenditures, revenue, service standards and affordability by fully resourcing consumer engagement.
- remove deemed endorsement where Consumer Advocacy Groups are not able to participate in product development and network change consultations.
- remove or revise the credit rating objective.
- strengthen service quality provisions for the first regulatory cycle, noting existing standards are likely to be obsolete shortly after the acceptance of a revised SAU.
- remove restrictions on the ACCC’s power to issue a replacement module determination within the initial regulatory period.
Download: ACCC NBN SAU November 2022 Draft Decision FINAL3.47 MB
Download: ACCC NBN SAU November 2022 Draft Decision FINAL219.94 KB