Submissions


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NBN Co’s Special Access Undertaking (SAU) is a key part of the nbn’s regulatory framework. The SAU determines how much nbn can charge for wholesale phone and internet services and provides the framework for non-price issues to help ensure the nbn works in a way that protects the long-term interest of consumers.

On the 18th June ACCAN attended an industry roundtable hosted by the ACCC. The purpose of this roundtable was to discuss the regulatory arrangements for the nbn that could be established under the revised SAU – Special Access Undertaking. The ACCC prepared a framing paper prior to the roundtable. In response to the framing paper, ACCAN:

ACCAN recently submitted to the ACCC regarding an authorisation application for members of the Telco Together Foundation (TTF) to work collaboratively to reduce modern slavery.

The authorisation would allow TTF members to engage in conduct that would normally be viewed as anticompetitive and illegal. Under the authorisation, collaborative conduct would be allowed in relation to specific activities necessary to identify and address modern slavery within telecommunications industry supply chains.

Nbn Co sought feedback on the second consultation paper of its wholesale pricing review. Earlier in 2021, ACCAN provided feedback to its first consultation paper.

In our response to nbn Co’s second consultation paper ACCAN explained that we would not like to see wholesale costs for residential customers increase, due to the flow on impact that wholesale price increases can have on consumers. As such, in our response ACCAN supported:

ACCAN recently responded to the Senate Standing Committees on Environment and Communications inquiry into the Broadcasting Legislation Amendment (2021 Measures No.1) Bill 2021. This Bill proposes amendments to the Broadcasting Services Act 1992, including in relation to subscription television captioning rules.

In our submission ACCAN stated that the Broadcasting Services Act 1992 remains the most appropriate place for captioning requirements to be set out. We recommended broader amendments to the Broadcasting Services Act 1992 to embed the same levels of access features (including captioning, audio description and Auslan interpreting) across all subscription, video on demand, commercial free-to-air and national broadcasters. We made a similar recommendation in response to the Media Reform Green Paper.

The Department of Infrastructure, Transport, Regional Development and Communications released the Media Reform Green Paper: Modernising television regulation in Australia in December 2020 for consultation.

The Green Paper proposed that:

  • Australian broadcasters and free-to-air television networks may be able to make a ‘one-time transition' to a new broadcaster's licence with reduced tax and content quotas on multichannels.

  • In exchange, those who take up the ‘new licence' must agree to transmit content on reduced radiofrequency spectrum, with surplus spectrum to be auctioned off to the telecommunications industry and proceeds used to funds to finance Australian screen content production and local news.

  • Large Subscription Video-on-Demand (SVOD) services and Advertising Video-on-Demand (AVOD) providers may be forced to invest into Australia's screen industry.

The Department of Social Services recently sought input to the National Disability Employment Strategy. This Strategy will have close ties to the forthcoming National Disability Strategy.

ACCAN made a submission to this consultation to outline the role of communications technologies in supporting greater inclusion and participation of people with disability in the workforce.

Communications Alliance, the peak body for the telco industry, is undertaking a routine review of C566:2005, the Industry Code on the Rights of Use of Numbers.

The Rights of Use of Numbers Code sets out rules and guidance for telcos when issuing, reserving, ‘quarantining’ and re-allocating telecommunications numbers to customers. A number goes into ‘quarantine’ – that is, it can’t be given to anyone else – for a period of usually 6-12 months once a service linked to that number is disconnected.

ACCAN’s submission outlines some of the issues customers have with numbers during the quarantine period, and how the Code could be improved to address these issues.

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.

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.

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.

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.