Issue No 30: 21 December 2022

NSW Electrical Safety Regulations 

Communications Alliance has provided a submission to the NSW Department of Fair Trading during the discovery phase of its project that is reviewing the Gas and Electricity (Consumer Safety) Act 2017 - leading up to a formal public consultation being conducted by Fair Trading next year.

In addition to providing comments on certain proposed changes to the Act, our submission brings to the attention of Fair Trading a potential conflict between NSW electrical regulations and telecommunications regulations concerning how equipment electrical safety is being addressed under the two regimes. 

International Standards, which Australian telecommunications regulations and Standards have adopted, manage equipment electrical safety though an approach of systemic identification and analysis of hazards, known as Hazards Based Safety Engineering. Integral to this is the adoption of a new electrical energy classification (ES1, ES2 and ES3) which allows for the safe use of current-limited voltages that exceed the existing voltage limits under electrical regulations. This is seen to have consequences concerning the jurisdiction of electrical regulations over telecommunications equipment/cabling and the ability for registered communications cablers to be able to perform cabling work.

5G Standards for Mobile Phones

The latest revised version of the Communications Alliance AS/CA mobile customer equipment Standards (the AS/CA S042 series) are now applicable Standards to be used for equipment compliance in Australia, with the recent making of the ACMA Technical Standard that calls up these Standards. The ACMA Technical Standard has now been registered and is available on the Federal Register of Legislation website. 

The AS/CA S042 Standard includes the new Part 5 which specifies requirements for IMT-2020 (5G) Customer Equipment. This Standard applies to IMT CE based upon the IMT-2020 technologies for 5G New Radio and 5G New Radio + E-UTRA (LTE).  

A new  project is shortly to get underway to commence the next iteration of changes to the AS/CA S042 Standard to maintain alignment with national requirements and the evolving mobile telecommunications Standards being developed under the 3rd Generation Partnership Project (3GPP).

Streamlining Radiocommunications Regulations

The ACMA is undertaking a program to modernise radiocommunications equipment regulation. Communications Alliance has provided a submission to the ACMA’s latest component of this program; the streamlining of regulations by incorporating thirteen current radiocommunications mandatory technical standards and the Radiocommunications Labelling Notice into amended Radiocommunications Equipment Rules.  

Communications Alliance broadly agrees with the proposed approach, responding to some specific issues raised by the consultation including how Standards are referenced.  Importantly, our submission recommends that with the increasing complexity of radiocommunications regulations, there is a demonstrable need for guidance material to be developed to assist industry with their equipment compliance obligations.

Reviewing the 2 GHz Spectrum Licence Technical Framework

The Communications Alliance Satellite Services Working Group (SSWG) has provided a short submission in support of the ACMA’s consultation on the review of the 2 GHz band spectrum licence technical framework. This review forms part of a broader work program as outlined in the ACMA’s Five-Year Spectrum Outlook 2022–27, catering for new developments such as 5G and Advanced Antenna Systems. The SSWG noted in its submission general support of changes being proposed by the ACMA.

Licencing the use of Low Interference Potential Devices

The ACMA are proposing variations to the class licensing arrangements for Low Interference Potential Devices (LIPD) in a recent consultation to support increased capability for wireless access services and other technology innovations. Being proposed are new arrangements in certain bands for radiocommunications receivers communicating with satellites, frequency-hopping radiocommunications transmitters and radio local area network (RLAN) radiocommunications transmitters.

Communications Alliance in its submission notes that it is opposed to class licensed outdoor RLANs in the 5150 – 5250 MHz band due to the high likelihood of generating significant aggregate noise in licensed Mobile Satellite Service (MSS) feeder uplink satellite receivers over Australia. We also voiced concern with the proposed introduction of arrangements in the LIPD class licence to facilitate underground communications in the 700 MHz, 800 MHz and/or 900 MHz bands. Finally, we note that systems that utilise space-based transmitters that operate in the 915–928 MHz and 2400–2483.5 MHz bands, at power levels higher than currently permitted under the LIPD class licence, should not be regulated under the LIPD class licence, but under the Communication with a Space Object class licence.

Financial Counselling Industry Funding Model

Communications Alliance has provided a submission in response to the Department of Social Services (DSS) consultation on a financial counselling industry funding model.

The submission confirms industry support for the overarching recommendation of the Sylvan Review – supported by Government - that nationally-coordinated, equitable and sustainable measures be introduced to ensure the long-term viability of the financial counselling sector. Unfortunately, however, industry believes the model proposed in the discussion paper to be fundamentally flawed as is not inclusive, equitable or sustainable. It cannot, therefore, support it in its current form. The submission details industry’s concerns and proposes a number of alternative options that it believes would be more likely to deliver a successful outcome.

Current Consultations

Below is a list of currently open telecommunications-related consultations being conducted by Government and other organisations that provide an opportunity for you to have your say.