Issue No 29: 28 November 2018



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Communications Alliance Looks Forward to Further Engagement on Consumer Safeguards Review Recommendations

Communications Alliance welcomed the decision to retain the Telecommunications Industry Ombudsman (TIO), but cautioned against Government recommendations that could threaten its independence.

Communications Alliance CEO, John Stanton, also expressed concern about recommendations in Part A of the Government’s Consumer Safeguards Review that could drive up the costs of the TIO scheme, to the detriment of consumers and industry alike.

Mr Stanton welcomed the opportunity, offered by Government, to engage with stakeholders during coming months on the practicality of the 32 Part A recommendations and their potential implementation.

He said the independence of the TIO was one of its core strengths as the external dispute resolution body for the telco sector.

“Industry has never controlled the TIO – nor should we.

“By the same token, we do not believe that the TIO should be placed under the control of the industry regulator, the ACMA.”

“Also, given the very extensive record keeping rules that have just been put in place by the ACMA, and the fact that the new Complaints Handling Standard is still being implemented – as highlighted by the Government’s paper – we would have concerns about too hastily implementing the recommendations related to those brand-new instruments.

“Many of the recommendations would act to drive up the cost of what is already an expensive scheme; and the cost of delivering telecommunications services to consumers and small businesses.

“We need to look critically at whether additional layers of regulation would add real value, or just extra expense.

“A Regulation Impact Statement (RIS) would help do that, but, in its absence, we look forward to working with Government, consumers, the TIO and other stakeholders to help draw out the best and most practicable elements of the recommendations.”

Communications Alliance and AMTA Joint Submission on the Emergency Call Services Determination Review

Communications Alliance and the Australian Mobile Telecommunications Association (AMTA) have made a joint submission to the Australian Communications and Media Authority (ACMA) on the review of the Telecommunications (Emergency Call Service) Determination 2009.

The Associations believe the review of the Determination provides a welcome opportunity to test whether the Determination remains fit for purpose and delivers the desired outcomes required for the effective management of emergency communications.

In the submission, the Associations note the technological changes which have taken place since the Determination took effect and raise the proposal to make the Determination more technology neutral, while also looking to put in place a set of guiding principles to make the obligations in the Determination more practical.

If this principles-based structure was to be considered, the submission also proposes, as an alternate approach, that the ACMA consider whether the obligations in the C536 Emergency Call Services Industry Code may be better placed into the Determination to avoid the need for carriers and CSPs to consult a multiplicity of regulatory instruments to understand how emergency communications should operate. This single instrument could then be supported by an Industry Guideline.

Communications Alliance Submission on Draft API Standards for Consumer Data Right

Communications Alliance has made a submission on the Draft API Standards developed as part of the CSIRO Data61 Consumer Data Standards Program.

The submission notes concern with the current focus of the Program on the facilitation of an Open Banking regime while the Standards and their underlying principles are meant to find their application more widely in other designated sectors, including the telecommunications sector.

Communications Alliance highlights that the assumption that the telecommunications sector ought to meet the overarching CDR objectives by adopting a very similar approach to the banking sector must be thoroughly tested and that such assessment would need to examine the costs and benefits associated with the proposed approach, the net consumer benefit and the alternative approaches that might be adopted.

The submission puts forward that, for the telecommunications sector, the CDR objectives are likely to be achieved, or are already being achieved, by existing Industry practice and legislative and regulatory obligations. Any measures contemplated to close potential gaps ought to be focused on the achievement of the declared objectives rather than the specific means of achieving those.

The submission also points out that the use of APIs ought not be made mandatory but only constitute one option to facilitate a transfer of data from data holders to consumers and other data recipients. We also note that, where an API is used, it ought to allow for a direct transfer of data to the consumer or their devices and not only to an accredited data recipient.

Communications Alliance SSWG Submission on 28 GHz Spectrum Band Planning

The Communications Alliance Satellite Services Working Group (SSWG) has made a submission in response to an ACMA planning paper on the 27.5 GHz to 29.5 GHz spectrum band (the 28 GHz band).  The ACMA is taking a wider look at the use of the band in consultation with industry, before consulting on specific changes to current access arrangements, allowing a more holistic consideration and balancing of all potential uses of the band, including both existing and future uses.

This submission highlights that innovation, developments and investment in this band (the Ka-band) are at unprecedented levels and are bringing much greater capacity, speeds, significantly lower prices, lower latency and extended mobility capability. There are well over 130 Ka-band satellites in operation, with a further order of magnitude increase in global filings (another 1500 satellites) for this band. The satellite Ka-band applications and service developments have significant implications for the future of 5G, as well as a critical role to play in the Internet of Things (IoT) and for backhaul applications.

The SSWG has raised concern about planning decisions that would deny long term security for satellite in this band, as this could jeopardise existing and ongoing investments in satellites and on network and system upgrades, vital for the ongoing commercial viability of the satellite industry. This is an issue of utmost concern for the satellite community. The SSWG is recommending that the ACMA adopt a new, more advanced and comprehensive model based on satellite broadband ubiquitous use in this band.

Communications Alliance Disappointed in Government’s Approach to Copyright Bill

Communications Alliance is disappointed in the Government’s rushed and one-sided approach to the Copyright Amendment (Online Infringement) Bill 2018, which today passed the Senate. Comms Alliance last week made a submission to the Senate Environment and Communications Legislation Committee’s truncated inquiry, calling for a rational approach to this complex area of law and for evidence of need for the changes proposed the Bill.

The submission to the Committee can be found here

New Member

Communications Alliance is pleased to welcome the following new member;

Aussie Broadband



Aussie Broadband are locally owned and locally operated. In this time of cost-cutting and shifting telco support services offshore, Aussie Broadband  have invested in local jobs and services, because that’s what Australia needs.

Aussie Broadband call centres are based in regional Victoria, supporting you with all-Australian technical expertise and assistance.

We welcome your feedback on our newsletter.

Contact Tel: (61) 2 9959 9111