Submissions


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ACCAN recently submitted to a consultation on the NBN Special Access Undertaking Variation: Response to ACCC Draft Decision – Modified Pricing Options.

In our submission ACCAN expressed our qualified support for the proposed pricing framework. We noted that:

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ACCAN recently responded to the Australian Competition and Consumer Commission’s (ACCC) public inquiry into the declaration of the domestic transmission capacity service, fixed line services and domestic mobile terminating access service discussion paper (the discussion paper).

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ACCAN recently made a submission to the Department of Infrastructure, Transport, Regional Development, Communications and the Arts’ 2022 Review of the Disability Standards for Accessible Public Transport 2002 (the Transport Standards). This submission was developed in consultation with our members, including Deafness Forum of Australia and Blind Citizens Australia (BCA).

Additionally, ACCAN supported the recommendations made in BCA’s submission to the review of the Transport Standards. 

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ACCAN recently submitted to Communications Alliance’s scheduled review on C564:2020 Mobile Phone Base Station Deployment Industry Code.

ACCAN endorses the Code as drafted and supports reconfirming the Code, which sets out the technical procedures for involving communities in the planning, installing, and operation of mobile phone base stations.

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ACCAN recently submitted to the Australian Communications and Media Authority’s (ACMA) consultation on the sunsetting of the Broadcasting Services (Television Captioning) Standard 2013.  This submission was developed in consultation with our members, including Deafness Forum of Australia, Deaf Australia and the Centre for Inclusive Design (CfID). ACCAN’s submission recommended:

  • That the Standard is redrafted with minor amendments to require broadcasters to address issues of latency and synchronicity in the captions used on their television programs.
  • That the redrafted Standard is implemented by the ACMA with stronger compliance and enforcement measures.
  • That the ACMA further investigates and provides information on the implementation of a metric model such as the Number, Edition error, Recognition error (NER) model.

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ACCAN recently provided comment on further pricing documents regarding the Variation to the NBN Co Special Access Undertaking Draft Decision consultation to the Australian Competition and Consumer Commission (ACCC).

ACCAN’s submission details our first assessment of the further documentation provided by NBN Co. In our view the additional material does not adequately address the concerns raised by ACCAN in our previous submissions. With respect to the further documentation provided by NBN Co. We consider that:

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ACCAN recently submitted to the Senate Environment and Communications Reference Committee’s Inquiry into greenwashing. Greenwashing is where a business or organisation misleads consumers about their products or services as being in some way environmentally friendly.

ACCAN supports RSPs establishing practices to decrease their environmental impact and sharing those practices with consumers. However, consumers should have confidence that the RSPs they choose for their sustainability claims are substantiating those claims. In response to greenwashing in the telecommunications market ACCAN recommends:

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ACCAN recently submitted to Communications Alliance’s consultation on the Telecommunications Consumer Protections (TCP) Code Review 2024. ACCAN’s engagement with consumers, consumer representatives, peak bodies, and consumer groups has elicited a common view that the TCP Code provides inadequate consumer protections and is not underpinned by effective compliance, enforcement, and penalty arrangements.

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ACCAN has recently submitted to the Australian Communications and Media Authority’s call for comments on their draft caption target reduction orders.

ACCAN has recommended that the ACMA do not grant the exemptions for the two channels arguing that they undermine the obligation for subscription broadcasters to provide year-on-year increased quotas for captions.

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ACCAN recently submitted our comments on the draft grant opportunity guidelines for Rounds 1 and 2 of the Telecommunications Disaster Resilience Innovation program.

ACCAN supports programs that mitigate the impact of natural disasters by strengthening the resilience of telecommunications facilities throughout Australia. In ACCAN’s view, the guidelines provide sound guidance to facilitate grant opportunities that improve the preparedness of Australia’s telecommunications networks against rising climate risks.

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ACCAN supported the ACMA proposal to remake the Radio Communication Labelling Determination (2013) in a recent submission. The labelling of high-power radiocommunications transmitters operating under transmitter licenses at communal sites enables  both industry and the ACMA with the necessary information to ensure that these transmitters continue to operate as intended. 

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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.