The Australian Communications and Media Authority (ACMA) conducted a consultation regarding proposed amendments to the Telecommunications (Emergency Call Service) Determination 2019. This Determination imposes requirements on carriers, carriage service providers and emergency call persons (Telstra and the National Relay Service provider) regarding access to the emergency call service (000, 112, 106). This consultation was in response to issues raised by the Senate Standing Committee for the Scrutiny of Delegated Legislation.

ACCAN made a brief submission to this consultation. We were supportive of the amendments which addressed the use of ‘no-invalidity’ clauses and references in the Determination to documents that were not publicly available. We suggested a few additional changes to improve the transparency and comprehensibility of the Determination. For example, we recommended that the Determination be updated to remove references to unclear actions and timeframes, such as the phrase ‘as soon as practicable.’ It is ACCAN’s position that strict timeframes must be clearly outlined to protect and support consumers making emergency calls.

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