Submissions


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In late 2020 the Department of Social Services consulted on the Outcomes Frameworks for the National Disability Strategy (the Strategy) and the National Disability Insurance Scheme (NDIS). The Outcomes Frameworks are intended to track progress over time to consider whether the Strategy and NDIS are improving the lives of people with disability in Australia.

In ACCAN’s submission, we explained that accessible and affordable digital communications technologies are essential to facilitate a more inclusive and accessible society for people with disability in Australia. We argued that outcomes and measures relating to digital communications technologies must therefore be included in the Outcomes Frameworks for both the Strategy and the NDIS.

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The ACMA have proposed new rules to improve telecommunications service standards.

ACCAN supports the draft rules because they ensure telcos pass on to affected customers certain rebates received from wholesalers, such as NBN, when issues of delayed connections and fault repairs, and missed appointments occur. In our submission, we urged that the customer should receive the full amount of rebate, whether that be a direct financial payment or through a measure put in place by their telcos to fix the issue, such as 4G back-up modems.

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ACCAN recently made a submission to the Digital Industry Groups (DIGI) consultation on their voluntary industry Code on disinformation. The Code has been developed in response to ‘Regulating in the Digital Age: Government Response and Implementation Roadmap for the Digital Platforms Inquiry’. The Code outlines what the digital platforms will do to address concerns regarding disinformation and credibility signaling for news content in the Australian context.

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The Federal government Department of Infrastructure, Transport, Regional Development and Communications is consulting on guidelines for funding proposals by the telco industry under Round 5A of the Mobile Black Spot Program (MBSP). Following our submission on the design of Round 5A, ACCAN has provided additional comments on the draft guidelines.

ACCAN supports elements of the Draft Guidelines introduced to target areas prone to natural disasters, promote competition outcomes in previously under-serviced regions and encourage active infrastructure sharing between mobile network operators and infrastructure providers.

ACCAN also advocated in favour of broadening the eligibility for funding to include:

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ACCAN submitted to the review of the ACCC’s Measuring Broadband Australia (MBA) program. Launched in 2017, the MBA measures broadband speeds on NBN Fixed Line broadband services.

ACCAN strongly advocated in favour of retaining the Measuring Broadband Australia scheme because the program has resulted in:

  • A decline in the number of consumer complaints;
  • Improved broadband performance by encouraging competition between telcos selling NBN Fixed Line broadband services;
  • enforcement action against RSPs who have made misleading claims about broadband speeds; and
  • Collection and reporting of data that has influenced policy decisions for the benefit of consumers.

ACCAN also encouraged the ACCC to expand the program to measure the performance of:

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The Department of Infrastructure, Transport, Regional Development and Communications sought comments on proposals to amend part 20A of the Telecommunications Act 1997 to boost pit and pipe provision in new developments.

Currently unincorporated developers are not required to build the necessary pits and pipes to allow network providers to install telecommunications in new buildings. Whilst most developers provide the necessary infrastructure to support telecommunications, there are a small number of premises built, in areas serviced by fixed-line telecommunications networks, without telecommunications pit and pipe, leading to inconvenience and additional costs for occupants of these premises.

This problem affects up to 3,000 premises a year and comes at a cost to new occupants as they will experience a lack of service, delays in service, cost of retrofitting and the cost of interim services.

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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.