Implementation of the National Broadband Network Migration Assurance Policy Consultation Paper

Transcription

1 Implementation of the National Broadband Network Migration Assurance Policy Consultation Paper iinet Feedback - Introduction iinet welcomes the opportunity to provide feedback on the Australian Government Department of Communications Migration Assurance Policy Consultation Paper (Consultation Paper). iinet s feedback on the Consultation Paper is in two parts: Part 1 identifies the role in the migration process that retail service providers (RSPs) such as iinet play and important issues that RSPs face and how the Migration Assurance Policy could assist in helping to address those issues. Part 2 provides iinet s response to the specific questions raised in the Consultation Paper. Part 1 - The Role of RSPs and Difficulties Faced All stakeholders have an interest in ensuring that end users experience an orderly and smooth migration to the NBN without experiencing any unnecessary service disruption. While RSPs such as iinet have a very important role to play in the migration process, it needs to be acknowledged that that role is limited in a crucial respect. The limitation is that RSPs cannot force their customers to migrate to the NBN. Therefore, the role of an RSP that supplies both copper and NBN services is limited to the following three functions: informing and educating its customers on the need to migrate; offering replacement services on the NBN; and providing disconnection orders to Telstra (where appropriate). iinet has experienced difficulty in performing each of these functions under the current migration processes. As regards providing information to customers, this can be made difficult where information about roll out and disconnection dates change. There is a risk to a service provider that they could be seen to be misleading customers, or they could lose credibility with their customers, if they provide inaccurate information about when NBN services will become available and/or when copper services will be disconnected. Offering replacement services is difficult in circumstances where there is no equivalent replacement service on the NBN. This is the case as regards a number of services that are deemed to be special services. It is also difficult to convince a customer to migrate to the NBN if the customer s equipment will not be compatible with the NBN. As regards the disconnection process, iinet obviously has no difficulty in circumstances where a customer has voluntarily migrated during the migration window. In iinet s view, the more

2 difficult issue that needs to be addressed is what happens to services still connected after the migration window has closed. iinet believes that the Case Management Protocols Framework adopted by NBN Co is not feasible on a large scale. If RSPs are to play a role in the disconnection management process post disconnection date, then: that role must be clearly defined; and the role should be based on the utilisation of business as usual practices. iinet believes that an RSP cannot reasonably be expected to do any more than: take reasonable steps to ensure that customers are aware that their copper services will be disconnected and the date that this will occur; offer to provide an NBN service (assuming one is available) and provide a disconnection order to Telstra where the customer has agreed to the service being disconnected. The provision of any safety net that ensures that vulnerable end users are not disconnected without their knowledge is an issue that is bigger than an individual RSP. As such, this issue is best addressed more broadly by NBN Co and/or the Government. In this regard, iinet believes that initiatives such as NBN Co s medical alarm register are sensible and appropriate. That said, in circumstances where services are being voluntarily migrated from an old network to a new network and the old network is switched off, it needs to be acknowledged that customers who steadfastly refuse to migrate, despite the efforts of their RSP and NBN Co, will eventually be left without a service. While there is obvious scope for the Communications Alliance to develop a guideline or code that addresses the reasonable steps that an RSP must take to ensure that the RSP s customers are aware that their copper services will be disconnected, it is important that this guideline or code is not unnecessarily prescriptive. In iinet s view, to be feasible, the guideline or code should be flexible enough to incorporate the existing business as usual practices of RSPs. In light of the issues discussed above, iinet s view is that the Migration Assurance Policy can usefully add value by adopting principles which aim to achieve the following outcomes: Rollout and disconnection information provided by NBN Co is accurate and timely. Communications Alliance develops a guideline or code that is flexible enough to allow RSPs to comply using their business as usual practices. The RSP s role in the disconnection process is limited to complying with the Communications Alliance guideline or code. Any requirement for a broader safety net is the responsibility of NBN Co and/or the Government. NBN Co is appropriately incentivised to ensure that a full range of replacement services are available as quickly as possible. In addition, there is currently considerable uncertainty about what the consequences will be if an end user premises fails to migrate to the NBN by the disconnection date in circumstances where all reasonable steps were taken to inform the end user of the need to

3 migrate but the end user is, for example, on NBN Co s medical alarm register. iinet believes that the Migration Assurance Policy needs to tackle this issue head on. 1. What do you see as being the most significant barrier to migrating your customers to the NBN As discussed in part 1 above, the barriers to migrating customers include: unreliable information about the availability of NBN services and the disconnection of copper services; a full range of replacement services being unavailable; and customer equipment being incompatible with the NBN. In iinet s opinion, all of these barriers are significant and need to be addressed. Therefore, there is little to be gained from seeking to identify any one factor that is the most significant. 1.1 What role do you think you can play in breaking down the barrier? iinet accepts that as the provider of copper based services, iinet has a key role to play in the communication and education of both the migration and disconnection process for those customers. iinet has in place a detailed campaign strategy to ensure iinet customers are fully armed with the information and education required;this strategy includes a portfolio of direct mailings, electronic mail, web based tutorials, frequently asked questions, regular online educational blogs and outdoor and radio advertising. iinet has an ongoing commitment to clearly educate our customers in understanding the copper migration and disconnection process. As such, iinet is playing its part. That said, iinet believes the commitment to educating end users is ultimately a shared responsibility between RSPs, NBN Co and Government. 1.2 What approaches would you encourage Communications Alliance to pursue? iinet strongly recommends that the Communications Alliance develop, in consultation with Industry, a guideline or code that clearly defines the relevant roles and reasonable responsibilities of key industry stakeholders across both the migration and disconnection processes. As discussed in part 1, to be feasible, this guideline or code should not be unnecessarily prescriptive and it should be flexible enough to incorporate the business as usual practices of RSPs. iinet believes that the guideline or code should acknowledge that the provision by Telstra Wholesale to each RSP of a list of copper services supplied to that RSP that remain connected six months before the disconnection date, would add value to the migration process.

4 2. What role do you think you should play in the migration of your customers to the NBN? Where do you think you can value-add the most to the migration process? iinet s experience confirms that successful migration ahead of mandatory disconnection requires a coincidence of service availability and customer awareness as early as possible within the migration window. As the RSP iinet is able to directly communicate with our customers and raise awareness about migration and disconnection and the consequences of migration. iinet seeks to do this as early in the process as possible. In iinet s view the NBN is most effectively presented as a positive (i.e. the NBN will give you a much better user experience than your current service ) rather than a negative (i.e. you must migrate or you will lose your service ). iinet is able to add the most value to the process by being a strong marketer of NBN services and offering incentives to our customers to migrate. However, iinet can only work within the service and information availability framework provided by NBN Co. 3. Are there any incentives, outside of government funding, that would encourage greater industry engagement and cooperation in the NBN migration process? iinet believes that addressing the issues identified in part 1 of this response would go some way to achieving greater industry engagement and cooperation from industry. 4. Are there any processes or solutions that, if implemented, would discourage industry from engaging and cooperating fully in the NBN migration process? iinet does not support the introduction and or implementation of any prescriptive process without the engagement and or support of RSPs, such as was introduced by NBN Co in May 2014 of the form of The Case Management Protocols Framework. Instead iinet seeks reasonable guidelines, established via active industry involvement, that provide for the necessary scope that allows RSPs to continue to work within their already established business processes. 5. What is your vision for the migration of services to the NBN? What should the migration arrangements look like in 2015? iinet s vision for the migration of services to the NBN is based on the aspiration that an industry wide guideline or code is effectively implemented detailing the roles and responsibilities of each party and the reasonable measures iinet must follow in order to successfully migrate our customers to the NBN. Having hard-line dates for ready for service and disconnection will increase iinet s ability to successfully educate, communicate and migrate customers.

5 6. How do we best integrate and leverage the lessons learned from the migration experience in the initial fibre rollout regions into a long term migration model? Continue to openly engage with those RSPs and key industry stakeholders to listen and learn from the challenges they have and are facing in the initial rollout regions. 7. How do the Communications Alliance best connect with industry stakeholders including retail service providers and application service providers in developing processes and solutions for supporting a successful migration? Continue the open and transparent conversations between key industry stakeholders that have already commenced. 8. What performance targets should the Australian Government set for the migration of services to the NBN iinet believes it is unrealistic and unreasonable to expect 100% migration of services before disconnection however desirable this outcome may be. 100% migration of services at the time of disconnection is an unreasonable goal due to the fact that there will always be a subset of vulnerable end-users and/or premises that rely on emergency facilities provided over copper based services. The Australian Government should set reasonable migration targets in consultation with key industry providers. It is important that NBN Co s public registers for premises with medical alarms, lift phones and fire indicator panels are adequately promoted and maintained. In addition legacy device manufacturers should be encouraged to test their services on the NBN at the NBN Co provided test facility and have these registered as NBN ready. Manufacturers of legacy services including medical alarms, back to base alarms, EFTPOS, ATM products, lift phones and indicator panels should be incentivised to move to IP only based solutions and services. 9. How can we best protect and support consumers telecommunications services when migrating to the NBN. End-users can be best protected and supported when migrating to the NBN by ensuring: they are provided clear, accurate and timely information about the NBN connection being delivered; theyare actually able to connect to the NBN at the ready for service date - i.e their premises is released at the ready for service date at service class 2 or 3 (this will minimise the risk of the NBN being unavailable and or their order being placed in held); and end-users whose NBN service during the migration phase is placed in held should not be left without a copper based service until remediation is completed by NBN Co.

6 10. What steps should we be taking to encourage a concerted effort by industry to improve the migration arrangements to the NBN. iinet believes that in order for the migration to the NBN to be successful, all parties involved in the process need to be engaged and to participate in the process. A clearly defined Migration Assurance Policy framework together with the introduction of a Communications Alliance guideline or code with clearly defined roles and responsibilities will assist in facilitating a successful migration to the NBN. In addition disconnection dates must be set and adhered to so that confusion is reduced and communications to end-users is clear, concise and actionable. 11. What characteristics of the proposed Migration Assurance Policy Framework could work well and what areas require further consideration and development? iinet agrees that in order for the migration to the NBN to be successful, all parties involved in the process need to be engaged and to participate. A clearly defined Migration Assurance Policy framework together with the introduction of a Communications Alliance guideline or code with clearly defined roles and responsibilities will assist in facilitating a successful migration to the NBN. While the Migration Assurance Policy framework outlined in the Consultation Paper appears reasonable, iinet believes the success of the framework will be dependent on the level of detail available for each stage. Of particular interest to iinet is stage 2 (the establishment of clearly defined migration processes and solutions) as well as stage 3 (the detail surrounding the introduction of any new instruments and or amendments to existing agreements). iinet strongly believes that any successful Migration Assurance Policy must be reasonable, scalable, efficient and cost effective for all stakeholders. The area that remains unclear to iinet and requires further consideration and development is in understanding what the process and consequences will be if an end-user premise fails to migrate to the NBN at the time of disconnectionin circumstances where all reasonable measures were undertaken to educate and migrate that user. What will occur in this instance regardless of whether the end-user is deemed vulnerable and/or the premise is service class zero or disconnection could expose people to potentially life threatening situations? 12. Do you have any views on the roles and responsibilities for the parties involved in the migration process? iinet s general comment on the roles and responsibilities for the parties involved in the migration process is that all parties should have clearly defines roles and responsibilities and that the responsibilities assigned are clearly and transparently measurable and auditable.

7 Specifically iinet believes: NBN Co provision of information provided by NBN Co needs to be timely, accurate and made available in agreed timeframes. NBN Co must be held accountable for customer complaints where it is undeniable that the fault lies with NBN Co. NBN Co take responsibility for the release of footprint at a minimum of service class 1, ideally premises would be released at service class 2 to minimise the amount of premises placed in held for weeks and months at a time. Telstra - provision of information provided by Telstra Wholesale needs to be timely, accurate and made available in agreed timeframes. A clearly defined process for restoring copper based services must be outlined where an end-user has a copper based service cancelled in error. Role of Industry/Third Parties responsibilities for account management or other relationship issues must be defined and limited to reasonable actions. 13. How can we better coordinate and plan the migration of services to the NBN across the industry boundaries? To reiterate iinet strongly recommend that the Communications Alliance develop, in consultation with Industry, clear guidelines and or a code that plainly defines the relevant roles and reasonable responsibilities of key industry stakeholders across both the migration and disconnection processes. iinet Limited 23 rd September 2014