Submissions


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Infrastructure Australia recently undertook an industry consultation for its Regional Strengths and Gaps project. ACCAN provided a response to this consultation.

In our response ACCAN highlighted the Wamboin Communications Action Group as a strength in terms of their success in improving connectivity in their area. This group is now providing guidance to other communities across Australia with similar aspirations. Similarly, ACCAN’s Community Consultation Guide provides information to communities to put together a business case for investment via the Mobile Blackspot Program.

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The Digital Technology Taskforce was established by Prime Minister Scott Morrison in November 2019 with the purpose of ensuring Australia is a leading digital economy by 2030. The Digital Technology Taskforce is looking to develop a Digital Australia Strategy to this end.

The Digital Technology Taskforce has set out the following themes to inform the Digital Australia Strategy:

  • Moving more businesses to the digital frontier

  • A digitally capable and inclusive Australia

  • Building digital trust

  • Digital-first Government

  • Lifting sectors through digital technology

ACCAN strongly supports the development of a Digital Australia Strategy. Our submission highlights the need for this Strategy to address telecommunications affordability, reliability and accessibility – as well as the many barriers to access – for communications consumers.

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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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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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The Department of Infrastructure, Transport, Regional Development and Communications have proposed standards, rules and benchmarks for Statutory Infrastructure Providers (SIPs). SIPs are telecommunications carriers that provide wholesale broadband services, such as NBN Co. The rules proposed are in relation to timeframes for connections, repairs and appointment keeping, rebates, speeds, remediation and record keeping.

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The ACMA is inviting feedback to inform the development of its 2021-22 Compliance Priorities. These are the areas that will guide the ACMA’s activities when enforcing and improving rules and regulations about communications services.

ACCAN’s submission outlines key areas where the ACMA should direct its compliance and enforcement efforts, based on:

• the impact of these issues on consumers of phone and internet services,

• the severity of the risk of consumer harm stemming from non-compliance in relation to these issues, and

• member feedback and evidence received by ACCAN.

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The Australian Broadband Advisory Council (ABAC) was established by Communications, Urban Infrastructure, Cities and the Arts Minister Paul Fletcher in July 2020. ABAC is working to explore and promote ways that broadband connectivity can boost Australia’s economic output and improve Australians’ wellbeing.

In December 2020, ABAC released its first paper titled Riding the Digital Wave: Report on COVID-19 Trends and Forward Work Program. The report explores the impacts, challenges and opportunities of COVID-19 relating to broadband connectivity.

ACCAN strongly supports the work of the ABAC and has provided feedback on the Riding the Digital Wave report, identifying a range of issues that should be represented in ABAC’s future work plan.

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The Department of Infrastructure, Transport, Regional Development and Communications sought feedback on whether it should allow the Australian Competition and Consumer Commission the power to permit certain fixed line networks to sell both wholesale and retail services.

Currently networks serving up to 2,000 residential premises can operate as both a wholesaler and retailer. The Department consulted on whether this limit should be extended to networks serving up to 12,000 customers in order to encourage investment and create more infrastructure competition. ACCAN considered that this should not happen until the following safeguards have been established:

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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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The Department of Infrastructure, Transport, Regional Development and Communications released an exposure draft of the Online Safety Bill in late December 2021 for consultation.

ACCAN provided a submission in response, welcoming the Bill’s move to improve Australia's online safety regulatory regime and shift the onus of responsibility for protection from online harm away from consumers back onto online platforms and services.

ACCAN agreed that some form of pre-emptive and preventative action is needed to protect all consumers from online harms, including those who are most vulnerable (e.g. children and seniors).

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ACCAN has made a submission to the Australian Competition and Consumer Commission (ACCC) consultation on consumer choice screens in search services and web browsers. The ACCC is interested in understanding the consumer impact of default web browsers and search engines.

ACCAN reiterated our support for the ACCC’s recommendation to facilitate consumer choice through the changes to default search engine and internet browser arrangements, as outlined in our 2019 submission to the Treasury inquiry into the implementation of the ACCC’s Inquiry into Digital Platforms.

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Communications are an essential service. ACCAN’s Pre-Budget Submission 2020-21 outlines policies, programs and areas of need for communications consumers that should be addressed in the Australian Government’s upcoming 2020-21 Budget. Affordability, accessibility, regional access and infrastructure, and empowered consumer decision-making are areas where continued government investment is vital to ensure all Australians benefit from connectivity.