::Welcome to July's edition of Communicate

:: New Members

:: New Members

Communications Alliance is pleased to welcome the following new members:

Opera Telecom Pty Ltd
www.operatelecom.com.au

Opera Telecom provide a SMS, MMS and IVR platform and also a system to give users the power to control and view (in more detail) their Telephony and SMS accounts online.

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:: A Helping Hand in Hard Times
By Anne Hurley, CEO, Communications Alliance

In the current climate of economic uncertainty it is timely to remember how far our industry has come in recent years with measures to assist people facing financial pressures.

The revised Credit Management Industry Code, which came into force in 2006, instituted a range of new measures to help customers avoid racking up big debts and to assist those in financial hardship. The credit management measures contained within the code have since been incorporated in the new Telecommunications Consumer Protection (TCP) Code.

The code requires suppliers to:

• Either credit assess new customers or provide them with a service where their spending or usage is limited;
• Provide customers with access to information about their unbilled telecommunications charges;
• Use or provide to customers credit control tools (eg call barring, caps on expenditure, pre-paid services, download limits etc) to help them manage their spending;
• Develop and use a financial hardship policy to assist customers who are experiencing hardship paying their accounts.

As noted, a major component of those measures is a requirement that carriage service providers (CSPs) implement a financial hardship policy. The policy must include provision for relevant staff training, be sufficiently flexible to accommodate the individual circumstances of customers and include options for the management of a customer’s situation.

Over the past two years Communications Alliance has been working with CSPs to assist them in developing internal policies and processes to manage customers who are experiencing difficulty in paying their accounts as a result of financial hardship. In this context it should be noted that “financial hardship” involves an inability of the customer to pay bills, rather than an unwillingness to do so.

Underpinning the approach to credit management is the philosophy that both the CSP and the customer have an interest in maintaining their relationship. This is in stark contrast to the often-expressed view that suppliers in many industries tend to resort to punitive action to recover debts without considering the long-term consequences on customer relationships.

In agreeing to the approach enshrined in the Credit Management Code (and now the TCP Code), our industry took a big step forward. This occurred in strong economic times but we will show our true maturity as we enter a more unsettled climate.

By considering the plight of financially strapped customers in light of the mutual benefits of maintaining long term relationships, our industry can continue to demonstrate social responsibility and business acumen simultaneously.

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:: Draft Mobile Premium Services Code Consultation
By Margaret Fleming, Program Manager, Communications Alliance

Mobile Premium Services have increasingly become a focal point for consumer complaints in recent years, prompting Communications Alliance to place a high priority on improving the situation.

As Custodian of the MPS Scheme, we have first-hand experience of the complex issues that arise when consumers have difficulties with MPS products and try to resolve their concerns with carriers and content providers.

In order to address these problems we have been developing a new MPS Code and Guideline incorporating Standard Industry Arrangements (GSIA) to replace the MPS Scheme. As part of this process we have tried to ensure broad consultation with stakeholders prior to beginning the formal approvals procedures.

Therefore we recently held a second consultation session on the draft Mobile Premium Services Code and Guideline pre public comment.

The purpose of the meeting was to inform key stakeholders of the substantive changes arising from the revision to date and the conversion of the Scheme to a Code, and to provide stakeholders an opportunity to provide input prior to the release of the documents for public comment.

Representatives from the following organisations attended:

• Australian Communications and Media Authority
• Australian Competition and Consumer Commission
• Australian Mobile Telecommunications Association
• Choice
• Consumers Telecommunications Network
• Department of Broadband, Communications and the Digital Economy
• Disability Council
• Office of the Privacy Commissioner
• Telecommunications Industry Ombudsman
• Review Working Group members: Optus, Telstra, Sybase 365, MobileActive

In addition, comments on the draft documents have been sought from the Communications Alliance Consumer Council and Disability Council.

The consultative process has been extremely effective in highlighting areas that may need further consideration and validates our decision to ensure wide-ranging discussion of the issues before finalising the draft Code and GSIA.

The two major issues raised by attendees at the most recent consultation session relate to subscription services and complaints handling, while obligations of disclosure and advertising practices were also raised.

The Working Group will consider the issues raised along with other matters raised by ACMA in its review of the pre-public comment versions of the draft Code and Guideline.

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:: Voice over IP is Over
By Mike Johns, Project Manager, Communications Alliance

The Communications Alliance VoIP Working Group has recently been disbanded. Does that mean that all the issues surrounding VoIP services have been addressed and it is time to move on? Not quite.

The VoIP Working Group was established just on three years ago with the aim to provide advice to Communications Alliance on the opportunities for industry self-regulatory responses to issues arising in the emerging converged regulatory and technical environment relating to VoIP.

During that time the industry, through participation in the Working Group and its subgroups, various Working Committees, annual forums and industry breakfasts, have contributed to a number of outputs which are now assisting providers in delivering VoIP services and users in understanding these services.

Early on in the work, Communications Alliance released the VoIP Interconnect and QoS Issues discussion paper for industry consideration. One of the outcomes was the development and publishing of the Quality of Service parameters for networks using the Internet Protocol Guideline (G632:2007) and the Quality of Service parameters for Voice over Internet Protocol (VoIP) services Guideline (G634:2007) and their accompanying testing guidelines. These documents provide information for service providers in areas such as performance of IP Network Quality of Service (QoS) Classes, packet marking and voice quality.

A total of six factsheets and booklets have also been published providing information on various aspects of VoIP services such as:

• information that service providers should tell their customers
• emergency service access
• security
• guide to technical terms and issues
• information for users selecting VoIP services
• guidance for service providers to assist users in selecting VoIP services

Communications Alliance has developed a manual for its members on Code compliance which includes specific information for VoIP Service Providers. In addition, the results of a review of the introduction of the Location Independent Communications Service (LICS) have been made available to our members.

Much of the initial focus of the VoIP Working Group’s activities stemmed from an earlier DCITA (DBCDE’s predecessor) report on Examination of policy and regulation relating to VoIP services. The recommendations in the report, together with a number of initiatives carried out by the Working Group, have led the industry to consider a number of aspects of VoIP services. Although many of topics came to the Group by way of their relationship to VoIP services, it has become clear that many of these topics are not solely confined to VoIP and that solutions would need to take into account how they also relate to existing services. These include:

• interconnection and peering
• numbering and addressing (including issues related to the IPND)
• location information (including reliability and feasibility)
• fault handling and restoration
• number portability (including types of models)
• relationship to the Customer Service Guarantee

Communications Alliance is now taking the next steps by bringing these issues to the relevant standing advisory groups, Often initiated by specific technology considerations, solutions that have technology-neutrality as a goal tend to lead to more enduring outcomes. With participation from all interested stakeholders, Communications Alliance is looking forward to progressing this work as we migrate to a converged communications environment.

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:: VDSL2 Industry Roundtable – Part 1
By James Duck, Project Manager, Communications Alliance

Communications Alliance established a Working Committee in 2007 with a focus on the technical aspects of VDSL2 technology. Its primary function has been to revise the existing Code* and Standards** for DSL technology to enable the introduction of VDSL2 services.

This activity on VDSL2 technology overlaps with commercial interests in the industry on any shift to a Fibre To The Node (FTTN) network architecture, and possible competitive outcomes from decisions about a FTTN architecture. Therefore the activity is also of interest to potential respondents to the Federal Government’s request for proposals on the National Broadband Network and to regulators.

These overlaps have not presented any challenges with the update of the relevant customer equipment standards to enable VDSL2 capable modems – Communications Alliance published them in April 2008. What is proving more interesting is the overlaps of the various interested parties with the network related decisions on the Code* (i.e. the DSLAM end of the communications wire, and managing interference over the wire).

Therefore Communications Alliance recently invited the largest users and providers of the ULLS to an industry roundtable meeting, with an independent chair, to examine the more commercial matters related to the Unconditioned Local Loop Service (ULLS). At present there remain divergent views but good intent to work together on possible ways forward and to progress the technical work. A draft report with the various views is being finalized for forwarding to Communications Alliance members and interested parties such as regulators, policy making departments and the federal government.

* The ACIF C559:2006 Unconditioned Local Loop Service (ULLS) Network Deployment Code is under revision in Communications Alliance to include VDSL2 technology and is available from:
http://commsalliance.com.au/documents/codes/C559

** Communications Alliance published the AS/ACIF S043.2:2008 Requirements for Customer Equipment for connection to a metallic local loop interface of a Telecommunications Network - Part 2: Broadband Standard in April 2008. It incorporates VDSL2 technology and is available from:
http://commsalliance.com.au/documents/standards/S043.2_2008

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:: Consultation – Process or Outcome?
By Josh Faulks, Manager, Policy and Government Relations, Communications Alliance

I can only go one way. I've not got a reverse gear. Tony Blair

What is consultation really about? What does adequate and effective consultation mean in the telecommunications industry as we move to a broadband converged world? Are current or old models of consultation relevant in this new environment?

These are some of the fundamental questions that the industry must deal with moving towards a converged world. There should be a clear focus on the future and an adoption of Tony Blair’s mantra of no reverse gear. In cooperating and collaborating to achieve the best possible outcomes for the end-user, industry and consumer representatives should not lose sight of what consultation is really about. Process is important but the paramount consideration should always be the outcome. Whether a particular group or organisation has been adequately consulted should not detract from the common overarching objective of achieving a positive deliverable for the end-user.

Governments and organisations struggle with how to effectively consult. Understandably, there are widely differing views on what constitutes appropriate and adequate consultation. However, there are some high-level principles that can be easily agreed upon. The main purpose of consultation should always be to improve decision making. Effective consultation ought to ensure that so far as possible everyone concerned feels they have had their say and their interests have been taken into account. Importantly, consultation encourages openness and accountability.

Old models of consultation may no longer be the best approach. With greater diversity, greater complexity and far more players in the field, traditional approaches may need adjustment or substantial overhaul. An open mind and determination to move forward, not back, will achieve the best outcome for all stakeholders.

The Australian Communications and Media Authority and Communications Alliance have undertaken to work with consumers to develop new consultation guidelines to provide certainty and transparency to the consultation process. These guidelines coupled with the Australian Communications Action Network initiative will hopefully move the focus from process to outcomes and assist the industry and consumers tackle the challenges that a broadband enabled converged world presents. .

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:: Events Calendar

Events 2008
• The ACOMMS 2008 : Sydney – 6 August 2008

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:: About Communications Alliance

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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