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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.

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.

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.

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.

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.

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.

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.

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.

ACCAN has responded to the draft report published by the ACCC on the public inquiry on the access determination for the domestic mobile terminating access service (MTAS). The purpose of the inquiry was to set an appropriate price that mobile network operators can charge for calls terminating on their mobile networks.

The ACCC carried out a benchmarking exercise which sought to estimate the current cost of providing MTAS in Australia by comparing the cost of providing the service in various countries and applying it to an Australian context. ACCAN supports the methodology used in the benchmarking exercise which produced a range for the estimated cost of supplying MTAS in Australia, but questions aspects of the approach taken by the ACCC.

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.

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

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.