The proposed rule is part of a broader effort by the ACMA to improve consumer experience when migrating to the NBN

Credit: NBN Co

A proposal by Australia’s telco industry regulator mandating that National Broadband Network (NBN) carriage service providers reconnect consumers to their legacy systems while migration to the NBN takes place has come under scrutiny by local industry.

Australian communications industry body the Communications Alliance claims that the proposal, which was put forth in April as part of three sets of proposed rules by the Australian Communications and Media Authority (ACMA) drafted to improve consumers’ experience when moving onto the NBN, is unlikely to be effective.

According to the Government’s telco industry regulator, 55.7 per cent of all network-related complaints about the NBN were about service quality for the three months to 30 June 2017, according to analysis by the ACMA.

As such, the ACMA said on 21 December it would impose the new enforceable rules on NBN retail service providers (RSPs) to minimise issues experienced by consumers during their migration to the NBN.

The first raft of proposed rules included the requirement that RSPs specify the minimum information that telcos must provide about their network services before they sign consumers up and the requirement that telcos ‘line test’ new services on the network to ensure that lines are working and that faults are identified early.

In order to ensure that consumers are not left without working voice or internet services when migrating to the NBN, the ACMA also proposed the so-called Service Continuity Standard.

This item enables consumers to be temporarily reconnected to their old legacy service unless a consumer has agreed to be temporarily provided with an alternative service.

According to the Communications Alliance, however, industry argues that the proposed Service Continuity Standard should be refocused away from reconnecting consumers to legacy networks.

Instead, the industry body said, the proposed rules should look toward maintaining continuity of service through interim alternative services, such as mobile-based broadband, while the permanent NBN connection is completed as a matter of urgency.

The arguments against the proposed ACMA rules come as part of a submission to telco industry regulator, as part of its public consultation process determine the final form of the rules.

In its submission, the Communications Alliance argued that a reconnection to a legacy network should be treated as a last resort.

“We agree that there is scope for Industry to further improve the customer migration experience,” Communications Alliance CEO John Stanton said. “However, we are concerned that some of the proposed rules may not achieve this or, even worse, bear the risk of being detrimental to an efficient migration and enhanced consumer experience.

“In particular, the Service Continuity Standard, apart from lacking clarity and often not being operationally or technically feasible, is likely to introduce significant additional distraction and divert resources away from moving consumers to the NBN with the best possible experience.

“It is hard to conceive situations where it would be in a consumer’s interest to be reconnected to a legacy network rather than providing an interim alternative service while focusing all efforts on addressing any migration issues that may have occurred,” he said.

Additionally, Stanton said that the Communications Alliance has concerns with some of the testing that the ACMA proposes in relation to the Line Testing Determination.

“The large volumes of tests that will certainly challenge providers at a time when they are trying to focus on migrating consumers to the NBN,” Stanton said.

According to the Communications Alliance, industry has also raised concerns around the technical feasibility of some of the tests, and the misalignment of the proposed new rules and already existing guidance on speed claims published by the ACCC and implemented by large parts of the industry.

“Given the multi-million dollar cost to industry flowing from the three proposed instruments – costs which are, in large part, ultimately borne by consumers – our industry is committed to work with Government and the ACMA to ensure that the measures are efficient, workable and do generate an improved consumer migration experience,” Stanton said.