ACCAN’s submission to the Universal Outdoor Mobile Obligation (UOMO) draft legislation

ACCAN recently submitted to the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts’ (the Department) consultation on the Universal Outdoor Mobile Obligation (UOMO) draft legislation. ACCAN supports the introduction of the UOMO, which ensures access to a baseline level of reliable mobile connectivity in Australia. This submission recommends the Department:

• Focus on the capabilities a Universal Outdoor Mobile Obligation should deliver, such as reliable access to the Triple Zero service, digital government services, and social connections.

• Develop a dynamic institutional framework that establishes minimum standards for contemporary service needs and enables improvements in service capability and standards as technology and consumer expectations evolve.

• Establish fit-for-purpose government arrangements that ensure Primary Universal Outdoor Mobile Providers are accountable and transparent.

• Develop a clear and effective regulatory framework by applying Australia’s domestic telecommunications regulatory framework to satellite services.

• Ensure all mobile plans, current and future, provide access to baseline outdoor mobile coverage that the Primary Universal Outdoor Mobile Provider is obliged to provide under the Universal Outdoor Mobile Obligation.

• Clarify how the Universal Outdoor Mobile Obligation will impact Mobile Virtual Network Operators.

• Monitor the introduction of Direct-to-Device technologies to ensure they are performing as expected.

• Establish an independent monitoring body that includes consumer representation.

• Create measurable performance indicators for ongoing compliance monitoring.

• Promote digital literacy programs to improve understanding of the implementation and access to baseline outdoor mobile services.

• Develop consumer information in accessible formats that clearly explain how consumers can access baseline outdoor mobile services.

• Consider actively supporting domestic mobile roaming arrangements in regional, rural, and remote Australia.

• Develop the standards noted in Section 12N before the Universal Outdoor Mobile Obligation commences.

• Ensure affordable options for low-income and vulnerable consumers to access compatible devices and plans.

• Create precise enforcement mechanisms with significant penalties for non-compliance.

• Implement text-to-000 functionality in Australia.