Nov-10 DBCDE NBN Universal Service Policy

Nov-10 DBCDE NBN Universal Service Policy
COMMUNICATIONS
ALLIANCE LTD
Implementation of Universal Service Policy for the
transition to the National Broadband Network
environment
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INTRODUCTION
1
Communications Alliance is the peak telecommunications industry body in
Australia. Its membership is drawn from a wide cross-section of the
communications industry, including service providers, vendors, consultants and
suppliers. Its vision is to provide a unified voice for the telecommunications industry
and to lead it into the next generation of converging networks, technologies and
services. 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. For more details about Communications Alliance, see
http://www.commsalliance.com.au.
2
Communications Alliance welcomes the opportunity to respond to the
Department of Broadband, Communications and the Digital Economy (DBCDE))
Discussion Paper Implementation of Universal Service Policy for the transition to the
National Broadband Network environment (the Discussion Paper).
3
Communications Alliance has sought the input its members representing the
carriers, carriage service providers and telecommunications equipment vendors to
identify areas of common interest on the issues raised in the Discussion Paper. Due
to the necessarily short consultation timeframe, this submission represents a limited
view from our membership base.
4
This submission highlights a number of issues that the industry wishes to bring to the
attention of the DBCDE. Due to the nature of the input, the submission does not
attempt to provide answers to all of the questions as presented in the Discussion
Paper.
5
Communications Alliance understands that individual organisations will be
responding to the specific questions posed in the Discussion Paper and will defer to
those organisations to address those questions.
Comments
6
The Australian Government has announced its intention to establish a new entity,
USO Co to manage the delivery of the Universal Service Obligation. This entity is to
have the regulated responsibility for delivering the Government’s public policy
objectives in the telecommunications sector in the areas including access to the
STS, payphones, emergency call handling, the National Relay Services, migration
of voice-only customers and continuity of public interest services.
7
The establishing of this new entity introduces another layer of bureaucracy and
complexity and care should be taken to ensure that it does not lead to the
imposition of additional costs on the industry – and ultimately on consumers.
Industry already is obliged to fund the costs of the ACMA through carrier licences
and numbering plan charges.
8
The Discussion Paper proposes that the administrative costs of USO Co should also
be included as costs to be borne by industry. A cost-reduction or at a minimum a
cost-neutral objective for the administrative costs that are borne by industry would
be favoured.
9
The Discussion Paper notes that at this time it is not anticipated that USO Co will
have any regulatory powers or functions. The industry supports the view that the
USO Co should not have any regulatory or quasi-regulatory powers. Such powers
should remain with the existing regulator, including the power to determine the
annual USO subsidy. It is noted that there is the danger in establishing another
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entity that over time could increase the burden upon industry in such areas as
information gathering, investigative and policy-based inquiries and other functions
which are already vested in existing industry regulators. This will lead to confusion of
function, increased administrative overheads and other costs.
10
With respect to Q3.8(6), the industry supports the establishment of an advisory
board of stakeholders to advise USO Co. As industry has considerable expertise in
service delivery, and will be providing funding towards USO Co’s delivery of
services, industry can appropriately offer guidance and assistance concerning the
arrangements for the delivery of the services involved.
11
In particular it will be important for USO Co to explore more cost effective ways to
deliver USO services, taking advantage of new advances in technology and
applications as they emerge.
12
The Discussion Paper notes that the institutional and operational arrangements for
USO Co will be informed by the framework detailed in the Department of Finance
and Deregulation’s publication Governance Arrangements for Australian
Government Bodies 2005. It is observed that the establishment of USO Co should
operate under existing mechanisms for review and repeal, including those of the
Commonwealth Ombudsman and Senate Estimates.
13
To the extent that the definition of what services are included in the USO is
reviewed in future - e.g. in the Government’s foreshadowed 2011 review of
regulation in a converged digital environment – it may be prudent to
coincidentally review the arrangements for USO Co, to ensure that it remains
relevant to the task.
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