Submissions


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The Department of Social Services recently released a position paper and sought feedback from the community on the development of a new National Disability Strategy. ACCAN made a submission to this consultation. Our submission was endorsed by 25 organisations and ACCAN members.

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The Western Australian Government recently sought feedback on a blueprint which outlines its vision and approach for making WA a digitally inclusive state.

ACCAN made a submission to this consultation and supported the blueprint’s four priority areas of connectivity, affordability, skills and design. These areas broadly align with ACCAN’s policy priorities and feedback we regularly receive about access to communications products and services. In our submission we provided a brief overview of these priority areas, with a particular focus on affordability and accessibility issues.

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The ACCC has resumed its inquiries into NBN’s access pricing and wholesale service standards. ACCAN has previously responded to these inquiries:

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ACCAN submitted a response to the ACCC’s discussion paper which commenced a public inquiry into whether the following services should continue to be declared:

  • Superfast broadband access service (SBAS)
  • Local bitstream access service (LBAS)


The SBAS and LBAS cover a range of non-NBN superfast fixed broadband networks. ACCAN is supportive of continuing the LBAS and SBAS declarations as superfast broadband networks are enduring bottlenecks. Due to a lack of infrastructure competition, without declaration consumers will be restricted in service provider choice and price.

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ACCAN submitted to the inquiry into the business case for the NBN and the experiences of small businesses.

The Joint Standing Committee sought views on the experiences of NBN consumers throughout COVID-19, network performance and NBN’s response.

ACCAN raised the following points:

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The Federal Government is reviewing consumer safeguards in telecommunications. The third and final part of their review, Part C: Choice and Fairness, looks at consumer protections. Consumer protections rules govern the lifecycle of a customer’s relationship with their telco. The rules outline how a provider must treat their customers, what sort of information it needs to provide, and what it needs to do when things go wrong.

Consumer Safeguards Review Part C examines:

  • The issues that should be covered in consumer protections rules,

  • The way that the rules should be made,

  • The way that the rules should be enforced,

  • What should happen to old rules that have existed for a long time, and

  • What should be done about the affordability of telecommunications services.

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ACCAN made a submission in response to the ACCC’s proposed enhancements to the Broadband Speeds Claims – Industry Guidance. ACCAN submitted that to avoid misleading the consumer telco retailers should:

  • Use the lowest end of any speed ranges provided by a wholesale product in off-peak speed marketing information, and RSPs should inform consumers if the off-peak speed changes;

  • Not advertise ‘burst speeds’ – off peak high speeds that are only occasionally available for short periods – as off-peak speeds;

  • Be transparent about the suitability and quality of their plans and products for online gaming, taking into account periods when the broadband network has high traffic demand;

  • Provide faster connection speeds in plans for online gaming to deliver a good customer experience, particularly in current circumstances where COVID-19 work from home and home schooling restrictions are increasing the strain on the broadband network;

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The Telecommunications Industry Ombudsman (TIO) is the external dispute resolution body for telecommunications consumers and small businesses who are unable to resolve complaints directly with their telco service providers. The TIO has consulted on changes to its Terms of Reference to allow for evolving technologies, changing consumer need and growth of smart devices.

ACCAN’s submission welcomed the proposed changes to the TIO’s remit and Terms of Reference including:

  • an increase in the amount of compensation available to consumers;

  • extending the jurisdiction for complaints and dispute resolution to include smart devices provided by TIO members;

  • allowing more than one service provider to be dealt with in the same complaint to make resolution easier;

  • compensating consumers for non-financial loss; and

  • aligning the TIO’s definition of small business with that in the Australian Consumer Law.

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ACCAN recently made a submission relating to the draft AS/CA S042.1:2020 Requirements for connection to an air interface of a Telecommunications Network— Part 1: General. The aim of this Standard is to provide requirements and test methodology for customer equipment used in connection with a Public Mobile Telecommunications Service (PMTS) or Satellite Service.

In our submission ACCAN argued that there is a need for improved consumer education around making emergency calls from different types of customer equipment.

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ACCAN recently made a submission to Communications Alliance in response to a call for public comments about the Emergency Call Service Requirements Industry Code DR C536 2020 (the Code). The Code places obligations on Carriers, Carriage Service Providers (CSPs) and Emergency Call Persons (ECPs). Carriers, CSPs and ECPs are required to ensure customers have access to the emergency call service, and also have access to information about the emergency call service.

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ACCAN has recently endorsed the Communications Alliance draft DR C564:2020 Mobile Phone Base Station Deployment Industry Code. The draft Code updates the previous version to bring it in line with the ‘temporary facilities’ requirements in the Telecommunications (Low-impact Facilities) Determination 2018.

ACCAN was a participating member of the Communications Alliance working group reviewing this Code.

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The ACCC consulted on the NBN Services in Operation (SIO) Record Keeping Rules (RKR). The rules require NBN to share information on a quarterly basis with the ACCC regarding the number of services in operation, network capacity acquired, technology type and attributes as well as geographical distribution of services. This information is then shared as part of the NBN wholesale market indicators report. The rules are due to expire on 30 September 2020, the ACCC sought consultation on whether they should be extended or amended.

ACCAN supports the ACCC’s preference for extending the rules for another five years and believes that the rules provide a comprehensive view of the NBN wholesale market. We therefore provided no suggestions for revision.