Submissions


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ACCAN made a submission to the Select Committee Inquiry into Australian Government's Response to the COVID-19 Pandemic. Overall, ACCAN praised the government’s response to the pandemic, NBN Co’s COVID-19 telecommunications assistance packages, and the telecommunications industry providers who quickly developed a range of measures designed to assist recipients to meet their ongoing financial commitments.

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Up until recently, superfast fixed line broadband networks serving residential customers had to operate on a structurally separated basis – which means a strict separation between wholesale and retail arms of the business. Recent amendments to the Telecommunications Act allow networks to functionally separate, which is a less costly way of achieving similar outcomes. The ACCC role is:

  • to develop an optional standard functional separation undertaking for networks, as an alternative to networks developing their own;

  • to make determinations exempting small network operators from separating wholesale and retail parts of their business.

The ACCC’s consultation is about proposed requirements for functional separation, and criteria for granting exemptions.

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The telco regulator, the Australian Communications and Media Authority (ACMA), is updating two parts of the NBN Consumer Experience Rules: the Service Migration Determination, and the Service Continuity Standard. These rules set out how providers should move customers from their old service over to the NBN, including making sure not to turn off the old service before the new one is working, and developing a plan if the new service isn’t working after 20 days. The proposed changes to these rules seek to clarify key terms and obligations.

ACCAN supports most of the proposed changes. However, ACCAN doesn’t support changes about information a provider needs to tell a customer about the cause of and solution for a problem with their new NBN service. ACCAN has previously commented on the NBN Consumer Experience Rules, and you can read more about this here.

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Standards Australia is an independent non-government organisation responsible for the development of Australian Standards. Standards Australia is reviewing its corporate governance and membership system to assess whether it is fit for purpose.

Our submission acknowledges Standards Australia’s existing commitment to consumer representation in standards development. ACCAN encourages Standards Australia to make changes to its corporate governance structure and membership system to expand the role of consumer organisations, and increase their participation in Standards Australia’s governance.

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ACCAN has made two submissions to the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (Disability Royal Commission). In these submissions we highlighted the importance of communications accessibility for consumers with disability.

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ACCAN submitted to the ACCC’s review on Division 12 and Internet Activity Record Keeping Rule where there were several proposals regarding the information the ACCC seeks from service providers.

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The Department of Communications and the Arts has drafted an exemption instrument to the new Statutory Infrastructure Provider (SIP) obligations that started on 1 July 2020. The SIP obligations require NBN and any other carriers providing telecommunications services in existing and new developments to provide high speed internet (broadband) and voice services on request.

ACCAN supports the exemption instrument proposed by the Department for the following reasons:

  • It allows carriers providing voice and mobile services (for example, Telstra fixed voice services; mobile network operators) to continue to do so without being bound by SIP obligations; this ensures that they are not deterred in providing these services.
  • The exemption will support continuity of these important services for consumers and small businesses.
  • ACCAN notes that this does not affect Telstra’s ongoing obligation to provide fixed voice services outside NBN’s fixed line footprint under the Universal Service Obligation, and that NBN will in most cases be obliged by SIP obligations.

 

Download: docxConsultation on Draft Statutory Infrastructure Provider Exemption Instrument Blurb71.77 KB

Download: pdf Consultation on Draft Statutory Infrastructure Provider Exemption Instrument Blurb151.25 KB

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ACCAN made a submission to the Mobile Black Spot Program (MBSP) Round 5A Discussion Paper.

Lack of telecommunications connectivity denies regional, rural and remote communities the socio-economic benefits that people in metropolitan areas take for granted. Yet mobile network providers are now at a point where there is minimal return on investment for them in rural, remote and regional locations and there is little incentive for them to build infrastructure in these areas.

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ACCAN has made a submission to the Department of Infrastructure, Transport, Regional Development and Communications consultation on options to support Australian stories on our screens. Australian content has cultural value for all Australians, including people with disability, and as such everyone should have access to Australian content.

In our submission, ACCAN explained that some accessibility features are readily included on Australian content, whereas others aren’t available (or aren’t consistently available). This is because there are no clear legislative requirements or protections to ensure access to Australian programming across all platforms.

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ACCAN has commented on the proposed update to the Federal Government’s telecommunications in new developments policy.

ACCAN agrees with the policy’s objectives to provide people moving into new developments with ready access to modern telecommunications, both voice and broadband, and to create a competitive market for the provision of such infrastructure. However, ACCAN identified the following areas for improvement in the proposed approach:

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The Department of Infrastructure, Transport, Regional Development and Communications is developing a trial to assess alternative ways of delivering voice (home phone) services in regional, rural and remote (RRR) areas. ACCAN previously commented on how these trials should be designed, run and evaluated. This round of consultation sought comments on the draft Grant Guidelines, Agreement and Application Form.

ACCAN supports the Alternative Voice Services Trials. Our submission makes a number of recommendations to ensure no consumer is worse off by participating in the trials. We also provided feedback on how to make sure the trials are as useful as possible. ACCAN reiterated the need for trialled services to be assessed not just in terms of value for money, but also in terms of quality.

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Some of Telstra’s networks are exempt from Parts 7 and 8 of the Telecommunications Act 1997. You can read more about this here. The Department of Infrastructure, Transport, Regional Development and Communications is seeking comments on Telstra’s request to extend its exemptions for its South Brisbane Velocity and other Velocity phone and internet networks. The current exemptions expire on 30 June 2020, so Telstra has asked the Minister of Communications, Cyber Security and the Arts to extend the exemptions further.

Consumers in the Velocity footprint have a difficult time getting affordable and good quality internet that is suitable to their needs. ACCAN’s submission acknowledged the necessity to grant Telstra’s request this time, otherwise current customers in the Velocity footprints may be left without a service after 30 June 2020. We argued that Telstra’s exemptions should be granted for 2 years at most. We also argued that Telstra should have a plan to sell the networks and should report on this regularly to the ACCC and the Department.