Submission to ACCC Consultation for Benchmark Service Standards for the Second Regulatory Cycle

Background 

ACCAN has submitted a response to the Australian Competition and Consumer Commission (ACCC) on its Benchmark Service Standards: Consultation Paper, which forms part of the broader ACCC consultation on NBN Co Replacement Module Application for the Second Regulatory Cycle.

ACCAN received an Australian Government grant to represent consumer voices and interests in the development of NBN Co’s expenditure proposals and service standards to ensure they meet the needs of Australian consumers and small businesses.

ACCAN’s submission is informed by findings from our nationally representative consumer engagement program.=

Submission

As the default wholesale internet provider for the majority of Australian consumers, it is critical to ensure that the Benchmark Service Standards for the National Broadband Network are set at an appropriate level to ensure that consumers can stay connected and access the internet when they need it, regardless of service geography or technology.

ACCAN strongly supports the ACCC’s proposed service standard uplifts in the Consultation Paper, which have addressed the primary issues of consumer concern, and will promote the long-term interest of end-users. The ACCC’s proposals will modernise and strengthen service standards to ensure they reflect current, not historic performance, and align more closely with consumer priorities. ACCAN considers however that further regulatory action could be considered in future regulatory cycles.

In this submission ACCAN recommends the ACCC:

• Implement its proposed revisions to ensure service standards are modernised, strengthened and aligned more closely to consumer preferences.

• Review the efficacy of the current rebate framework and work with the ACMA to implement a reformed mechanism that delivers direct pass-through to consumers.

• Consider developing a reliability incentive framework to strengthen the economic incentives governing NBN Co’s performance against benchmark service standards for implementation in subsequent regulatory cycles.