4th November 2015
TUANZ (The Telecommunications Users Association of New Zealand) yesterday submitted its response to the Ministry of Business Innovation and Employment’s discussion paper: Regulating communications for the future – Review of the Telecommunications Act 2001 .
Building on 30 years of representing telecommunications users, TUANZ response is based on its new strategic direction to ensure New Zealanders can make the most of the digitally connected world. “TUANZ position has been consistent and clear: The availability of competitively priced, good quality connectivity in all parts of NZ is a critical economic enabler for the future of the NZ economy.” said Craig Young, CEO of TUANZ. “We want to work collaboratively with industry and government to deliver our vision but the outcomes for Users will always be our most important driver.”
The submission is a result of a series of TUANZ member workshops which presented further information and allowed for debate and discussion on the issues. “Our focus in our submission is the outcomes of any review for users rather than specific details. However we have suggested a view on the issues we believe are critical to the continued development of our connected economy” Mr Young said.
Of critical importance to TUANZ and its members is that the hard work done by all parties to get us to a point where we have fierce competition at the retail level for broadband services, and an independent pricing regime in place for the bottleneck access assets is not lost in the review. TUANZ supports the Government's proposal that regulation of the Telecommunications sector is still required, and agree that it should be targeted at the access layer. Members are also clear that the future pricing of these access services must be settled by the time the current arrangements expire in 2020.
TUANZ also supports the investigation of alternative approaches to the current pricing modelling approach in the Act which were developed in quite a different time in the telecommunications market. TUANZ awaits for further detail on how any alternative model (eg Utility pricing approach) would be applied before commenting further.
A key issue for TUANZ members is the state of competition with the mobile market. Since the Act was originally passed we have seen continued investment by the two major mobile networks in initially extending coverage, and more latterly in the upgrading of the networks for greater speeds which we recognise has led to significant head to head competition. We have also seen the arrival of a third mobile network operator, but that only came about after significant challenges around gaining spectrum and a workable roaming agreement were overcome. In our view, we have seen no successful Mobile Virtual Network Operators develop within the New Zealand marketplace. During our consultation with members, it was expressed that we are unlikely to see the investment in a fourth mobile network and so we believe that, for the long term benefits for end users, there should be an independent review of the wholesale mobile market around all aspects, from the cost and availability of roaming arrangements to MVNOs, through all forms of infrastructure sharing. The aim should be to ensure that the right access and incentives are in place to create innovate competition at the retail level. This review could be undertaken by the Commerce Commission similar to other investigations it has undertaken.
TUANZ looks forward to continuing to represent the views of users in this critically important process.