::Welcome to August's edition of Communicate
:: New Members
:: ACOMMS: 2008 Winners
:: Sharing Responsibility for Consumer Satisfaction
By Anne Hurley, CEO, Communications Alliance
:: The New Telecommunications Consumer Protection Code
By Margaret Fleming, Program Manager, Communications Alliance
:: Voice Being Accredited as a Standards Developer
By Mike Johns, Project Manager, Communications Alliance
:: Should VoIP Services Offer Preselection?
By James Duck, Project Manager, Communications Alliance
:: VoIP and the Emergency Call Services Debate on a Global Scale
By Buchanan Law
:: About Communications Alliance
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Communications Alliance is pleased to welcome the following new members:
Select Software Pty Ltd
www.telcobilling.com.au
Select Software Solutions is a provider of Billing and CRM solutions for telecommunication businesses in Australia and New Zealand. Select Software was formed in 1994 and is privately owned and operated.
Blue Central (Mobility)
www.bluecentral.com.au
Blue Central (Mobility) provides carrier-grade infrastructure providing the delivery & billing of mobile messages over SMS, MMS & WAP.
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The winners of the prestigious 2008 ACOMM Awards were announced at the Communications Alliance Annual Dinner held in August.
In her opening remarks Communications Alliance CEO, Anne Hurley, commented that the awards reflected the way in which communications products and services had evolved in recent years.
“When you look through the list of finalists for tonight’s awards it’s instructive to note they mostly relate to products and services that reach deep into our daily lives,” Ms Hurley said. “Once our industry awards were about exotic solutions for esoteric problems – hardware, software and services that delighted boffins but lived in the shadows deep within the networks. Now they are about devices and services that are in the hands – and often the ears – of most teenagers in the country.”
Telstra was the winner of the Industry Leadership – Innovation for a Large Company award, with Unwired taking out the Industry Leadership – Innovation SME award. |
There were three ‘Services to the Industry’ winners. Herbert Geer Lawyers secured this year’s prize for Professional Services Excellence, while Alcatel-Lucent took the Partnerships for Growth award. The Commitment to Customer Service for a Large Company award was won by Uecomm with Telarus taking out the Commitment to Customer Service – SME award.
The inaugural Environmental Responsibility award was won by Telstra.
The industry’s top honour for individual achievement, the 2008 Communications Ambassador award, was presented to Simon Hackett, CEO and founder of Internode.
In the form nominating him for the award, he was described as having taken “a leadership role in Australia’s broadband sector since its emergence in 2000-2001. Simon is an activist CEO who is driven to deliver customer value and technical innovation as well as achieve commercial success”.
Commenting on the outcome, Communications Day Publisher, Grahame Lynch said: “The 2008 Awards evidence a new high standard of industry excellence. Tonight’s trophies were presented to the industry’s ‘most deserving’ but the real winners are Australian businesses and consumers who are being increasingly well served by an innovative, competitive and growing communications sector.”
A comprehensive listing of this year’s Award finalists and their accomplishments is available from the www.commsalliance.com.au website.
Industry sponsors for the Communications Alliance Annual Dinner at which the Awards were announced, included Platinum sponsors Pipe Networks and Telstra Wholesale and Gold sponsor KPMG.
2008 ACOMM Award Winners
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Industry Leadership Innovation - Large Company
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Industry Leadership Innovation – SME
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Environmental Responsibility
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Services to Industry – Professional Services
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Partnerships for Growth
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Commitment to Customer Service - Large
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Commitment to Customer Service – SME
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2008 Telecommunications Ambassador
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Simon Hackett |
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Products that were luxuries in one era become necessities in another and they come to be seen as an entitlement. The more “essential” a product or service is perceived, the greater the potential for consumer dissatisfaction.
Therefore, as communications services and products embed themselves more firmly in the everyday lives of Australian consumers, the level of dissatisfaction is inevitably rising.
As the Productivity Commission pointed out in a recent report, communications infrastructure is increasingly considered to be a utility and indeed an essential service. Apart from the rapid uptake of the social networking aspects of communications, there is a greater dependence on interaction with education, health, banking, retail and other services online.
As well as increased dependence, there is a continually rising level of complexity to the product and service offerings. Therefore modern communications offerings demand a much higher level of consumer knowledge and technical understanding than earlier products and services.
For all but the most engaged and technically literate consumers, it is a tremendous challenge to keep up with new features, options, pricing and contract arrangements. In such an environment of confusion, many consumers make purchase decisions based on inadequate understanding and inevitably become dissatisfied.
A specific cause of confusion – and hence dissatisfaction – is the complex nature of many new bundled offerings that are built on inter-dependencies between multiple suppliers. Many consumers are unclear about the appropriate pathway for an information query or fault report, whereas customer service is also more complex from a provider perspective.
Because dissatisfaction can be defined as the gap between expectation and delivery, we can’t simply address failures in service provision. We must address perceptions of failure.
Consumers’ expectations of innovative products and services can only be based on what they already know and understand. So we must empower consumers by helping them to navigate the increasingly complex communications landscape.
Service providers and consumers should begin to view each other as collaborators rather than antagonists in solving the problems we share.
For instance, we should consider how best to help consumers make informed decisions, not only with regard to the products and services they buy but also how to use those products and services in ways that suit their requirements.
Whether they want to make an informed choice between competing offerings, to upgrade or vary an existing service, to understand a billing issue, or to trouble-shoot a technical problem, information needs to be structured in ways that make it accessible to consumers of varying degrees of knowledge.
A greater sharing of responsibility for consumer satisfaction requires a broad-based approach. Consequently, strengthened cooperation is needed between industry, consumer representative bodies, government and regulatory agencies. Promoting dialogue and joint initiatives is important, but ensuring follow-through and implementation is essential.
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Hamish Fraser and Michael Stojanovic of Truman Hoyle Lawyers have written an article that discusses a few of the more significant rules in the Telecommunications Consumer Protection Code (‘TCPC’). The TCPC, developed under the auspices of Communications Alliance, was registered by the Australian Communications and Media Authority (ACMA) on 18 May 2008.
Entitled ‘Getting the act together: the new Telecommunications Consumer Protection Code’, the article is available at http://www.trumanhoyle.com.au/TrumanHoyle042/downloads/CAMLA_article-TCPC.pdf
The authors observe that whilst many of the rules in the TCPC already existed in one form or another under the 6 industry codes replaced by the TCPC, it is opportune for suppliers to review the new code to ensure that their processes and procedures are compliant with it. Although the intent was to retain the same rules as in the superseded industry codes, the practical outcome has been that some of the rules are framed differently or written in a different way in order to provide consistency. For example, the authors note that whereas the previous codes each used different definitions of a ‘customer’ and/or a ‘consumer’ the TCPC has adopted clear definitions of ‘consumer’ and ‘customer’.
The conclusion of the authors is that the TCPC ‘…consolidates the consumer protection landscape for the telecommunications industry, and should ensure that the development of future regulation can occur in a more consistent and simple way.’
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Communications Alliance has been developing Standards for the telecommunications industry for over ten years. These Standards are referenced under telecommunications legislation, providing suppliers of telephony products the requirements that their products need to meet to get the ACMA A-tick label ‘seal of approval’. This label demonstrates that the product has met the appropriate Standards.
To ensure that Communications Alliance maintains a rigorous, transparent and internationally aligned development process we became, as the former ACIF, the first accredited development organisation outside of Standards Australia who could develop and publish Australian Standards. This accreditation demonstrates that Communications Alliance has the standing, resources, processes, neutrality and independence that one would come to expect from a developer of national Standards. Communications Alliance has just undergone an audit by the Accreditation Board for Standards Development Organisations (ABSDO) to continue our accreditation for another three years.
It is a critical time for our industry in its evolution in a converged, digital and global communications environment. Communications Alliance is well positioned to seize the opportunities and assist the industry with this migration. One component of this is ensuring that we have the necessary Standards available and in place to assist equipment suppliers and service providers in the delivery of their products and services. Equally important is the ongoing review and future planning to ensue that we have the optimal arrangements in place for assisting in areas such as emerging services and the implementation of national broadband networks.
Communications Alliance regularly consults with industry members, the regulator and the Department of Broadband, Communications and the Digital Economy on a variety of issues. One example of this is the forthcoming Standards Roundtable, providing the opportunity for stakeholders to reflect upon, among other things, how we go about developing Standards for the Australian communications industry in an increasingly global market. As an accredited developer of Standards, Communications Alliance continues to play a pivotal role in the area of standardisation for the communications sector.
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Communications Alliance is reviewing* the Preselection Code as part of its regular review of each existing publication after a defined number of years.
One of the challenges for the industry working group performing the Code review is how to handle the issues arising from the potential combination of preselection and VoIP services. That is, questions arise around whether or not to require preselection in a VoIP environment, including:
- If so, what services should require preselection?
- If not, how should one manage the lifecycle of preselectable services?
An argument in favour of preselection for VoIP services is that it continues the ability for end users to choose a preferred provider, particularly where VoIP is used to deliver a standard telephone service that emulates an existing PSTN service. This is consistent with the view that requirements should be as technology neutral as possible.
An argument against preselection for VoIP services is that preselection is an outdated concept on IP networks. This is because preselection is a concept where the telephone service is tied to a PSTN exchange. This contrasts with the ability for end users to subscribe to multiple VoIP providers over the one broadband connection. Also, some users may want to be able to forgo preselection (and possibly other functions) as a tradeoff for obtaining other benefit(s) e.g. lower price, different call quality.
Another view is that preselection will become irrelevant in the future because a telephone service will eventually be bundled as part of most broadband plans.
One thing has become apparent from industry discussions to date – the need to be clear about what one means when referring to ‘VoIP services’. This is because a VoIP service can range from a very simple voice connection with highly variable performance using an underlying IP connection through to a fully featured, highly reliable voice service that is equivalent to, or even surpasses, the performance of a PSTN service.
You input to the working group and the Code review is welcome, so please contact Communications Alliance with your input.
* A review of a Code typically involves an assessment on whether or not the Code should be reconfirmed (i.e. no changes) withdrawn or revised (i.e. make changes or clarifications to the Code).
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ACMA recently revived the VoIP Emergency Call Service (“ECS”) debate by calling for public submissions as part of its Calling the Emergency Call Service – Review of Arrangements project (“the ECS Review”). The ECS Review looks at the application of ECS requirements to IP-based technologies, including the technological and regulatory barriers that prevent some VoIP users from accessing ECS.
ACMA, DCBDE and industry and community bodies alike have launched different initiatives to address the VoIP – ECS problem. The problem exists on many levels: how do we ensure ECS access is available from different types of VoIP services? How can we make certain that the Emergency Call Person (“ECP”) can access a caller’s correct location information? These issues are not unique to Australia and are being dealt with in varying manners by different countries around the globe.
The United States Federal Communications Commission (“FCC”) requires all VoIP providers to provide users with access to the ECS number “911”. Many VoIP providers complained that VoIP access to ECS was being blocked by some ECS controllers, particularly where the ECS controller was a traditional PSTN communications provider. In reply, Congress has enacted legislation requiring ECS controllers to allow VoIP providers to connect to the ECP.
The new legislation places the onus of ECS access on the (traditionally) PSTN carriers controlling the ECS, in contrast to the Australian approach which focuses on the obligations of the VoIP provider.
Japan’s approach to VoIP regulation prioritises the promotion of competition over regulation. Japan is the home of the world’s largest commercial VoIP subscriber base. In order to stay ahead of the competition, Japanese companies have been keen to offer not only ECS access from fixed VoIP services, but also innovative ECS technologies including an “e-call” service that allows the user to call an ECS and transmit location information obtained by GPS to the ECP from the user’s car. Market forces have dictated the need for ECS access as opposed to a Government decree.
The EU is another market that favours increased competition over a regulatory framework. The European Regulators Group’s “light touch” approach is hesitant to impose strict ECS obligations on VoIP providers (and ECS controllers) for fear that it would restrict market freedom and hinder further development of IP technologies.
Australia’s next step
The ECS debate embodies the competing tensions between the need for a regulatory regime that provides user protections and the commercial need to promote growth in the VoIP marketplace. Who is to say that a highly competitive marketplace can’t dictate the necessity for ECS, as is the case in Japan? Arguably the smaller Australian VoIP marketplace is not yet in a position to achieve this outcome. Perhaps an American approach, although unfavourable for our bigger telecom players, is the preferred approach from the perspective of the VoIP provider.
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Communications Alliance was formed to provide a unified voice for the Australian communications industry and to lead it into the next generation of converging networks, technologies and services.
Communications Alliance offers a forum for the industry to make coherent and constructive contributions to policy development and debate.
By providing leadership on new trends and directions, Communications Alliance fulfils a vital unifying role on behalf of the industry and its members, particularly in areas of competition, innovation and industry development.
The prime mission of Communications Alliance is to promote the growth of the Australian communications industry and the protection of consumer interests by fostering the highest standards of business ethics and behaviour through industry self-governance.
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