TUANZ Submission on proposed additions to the Telecommunications (Property Access and Other Matters) Amendment Bill

This is the content of the letter we submitted to the Parliamentary Commerce Committee on 10th November 2016.

"Thank you for the opportunity to submit on the proposed additions to the Amendment Bill currently before the Committee.  TUANZ has been consistent in its support of encouraging the improvement of communications services in the rural areas of NZ, and have stated our encouragement for looking for innovative approaches.  In our original submission (a joint submission with InternetNZ) we encouraged the Committee to review the SOP that was submitted by NorthPower and so here we provide further support.

Specifically we support the following:

Fibre on Power Poles - The right for fibre optic cables to be added to existing electricity corridors, without the need to renegotiate the terms of access with each landowner. In return, landowners will be able to connect to an Ultra-Fast Broadband service.

Free Fibre Connection – The free installation of a fibre connection point and a 200m overhead fibre service line connection where there is an existing aerial installation is a fair and reasonable recompense and in line with the existing and successful UFB model.

Restricted to Lines Companies - Only the company (and their preferred contractors) who owns the poles and network should be allowed to install fibre in order to minimise any impact on landowners.  This would mean that only one party is accessing the property for maintenance or to remedy any storm damage (when fast and safe restoration is required).  However, use of the fibre could be licensed to others.

Fibre to the Farm – This is an enabler to get UFB type speeds deep into the rural community, improve consumer choice of broadband products, reduce data caps and improve broadband reliability and speeds. This will allow rural businesses to be more efficient and participate fully in e-commerce, enable educational opportunities for rural children, improve social inclusiveness and access to entertainment options for rural populations.  All these factors will also help attract employees and their families to rural areas.    

While we have chosen to submit on our own at this point, we have seen the InternetNZ submission and encourage the Committee to consider the issues raised in their submission"

TUANZ Submission on the Telco Act Review options paper

TUANZ last week (2nd September) submitted our views on the Government's options paper released earlier in the year as part of the current review of the Telecommunications Act.  In our response we reminded the Government that our position is consistent and clear: The availability of competitively priced, good quality, fast connectivity in all parts of NZ is a critical economic enabler for the future of the NZ economy.

The specific issues we are looking to be addressed for users in this current review are;

  1. Price Certainty – absolutely no price shock for users

  2. Continued Improvement – no unhelpful constraints on enhancements to the network underpinning our digital future

  3. Rural Connectivity - our goal is that the rural connectivity experience should be equivalent to that within the urban environment

  4. Mobile Developments – renewing our call for a wide ranging independent review of the mobile market

  5. Transparency – to help overcome the information asymmetry between the industry and users

  6. Consumer Disputes Process – a strengthening of the independence of processes

  7. End User Involvement – ensuring users have resources available to provide credible engagement in these processes

You can read the full submission here.

TUANZ Cross Submission on UCLL/UBA FPP Price Reviews

TUANZ has submitted to the Commerce Commission as part of the Cross-Submission process in regards to the current Final Pricing Principle review for UCLL and UBA.  The details are as follows.

Re: TUANZ cross-submission comments in regards to the UCLL/UBA Final Draft Determinations

Thankyou for the opportunity to provide a view on the most recent submissions received by the Commission in response to the final draft decisions released on the 2nd July 2014.

This letter contains no substantive arguments in relation to the determinations, but highlights the few issues that TUANZ considers to be important at this juncture.  TUANZ as an organisation that represents a wide range of members, looks to focus on outcomes for the ultimate users of the relevant services, the end customers in the form of businesses, organisations and individuals.  

Submission by Wigley & Company

TUANZ has been involved with the development of the submission provided to you by Wigley & Company and this letter is in support of that submission.

Our general concerns

We would ask the Commission to consider our comments in light our published principles, that we are interested in the outcomes for the ultimate users and so our comments here hinge on the need to be cognisant of the long term benefits for end users as per section 18 of the Telecommunications Act.

We would like to draw particular attention to the following issues as discussed further within the submission by Wigley & Company that are of particular concern to TUANZ:

  • The appropriateness of the Total Welfare Approach  - We support the argument contained in the submission by Wigley & Company, that the use of this approach is inappropriate in that it is not in the interests of end users.  We believe that the act is clear on its focus is on the users of telecommunications and not to consumers total welfare.

  • Transparency of modeling changes - we agree with other submitters that we lack that transparency to comment appropriately on modeling changes.

  • The apparent generosities in input costs - earlier submissions by parties pointed out the draft decisions did not reflect genuine “central estimates” but contained “generosities”.  We point to the comment made in the Wigley & Company submission that these generosities may lead to cost estimates significantly higher than other comparable jurisdictions.

  • We continue to support the notion that Backdating in this situation does not provide long term benefits for End Users and therefore should not be applied.

TUANZ looks forward to continuing its involvement in this process.

What is the TDR?

The TDR, Telecommunication Dispute Resolution, is a free, independent service to help residential and small business customers to resolve disputes with their telecommunications company.

For further information, please visit their website: www.tdr.org.nz

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TUANZ submission on the five year spectrum outlook

​The Ministry of Business, Innovation and Economy (MBIE) now looks after the old Ministry of Economic Development's spectrum unit. The spectrum team manage how the government issues licences for spectrum management - effectively a monopoly on the use of those spectrum lots for a set period of time. MBIE has asked for comment on its discussion paper surrounding the next five years and what should be done to encourage economic development in New Zealand.

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