21st October 2019 : Submission to the Commerce Commission on the Emerging Issues Paper for 111 Contact Code

21st October 2019

Today we have filed with the Commerce Commission our submission responding to the emerging issues that they identified in a paper released as part of their requirement to develop a 111 Contact Code.  This code is to protect vulnerable consumers by ensuring they have reasonable access to an appropriate means of contacting the 111 emergency service in the event of a power failure.  (You can see that paper here).

In our submission we recognise that defining who vulnerable customers are is problematic, but that all users who receive a service must be able to make a 111 call when an emergency occurs, and that it should be using technology they are comfortable with.

You can download the full document here.

5th July 2019 : Submission to the Commerce Commission in response to their Preliminary Issue Paper, Mobile Market Review.

5th July 2019

Today we have filed with the Commerce Commission our submission responding to the preliminary issues that they identified in a paper released as part of their Mobile Market review on the 16th May (You can see that paper here).

In our submission we cover our position supporting the multi-player market that has developed in NZ but with the desire to see a further development of the wholesale market (especially MVNOs), spectrum allocation and our continued support for infrastructure sharing – particularly outside the major urban areas

You can download the full document here.

21st Dec 2018 : Submission to the Commerce Commission on the proposed approach to the new fibre pricing framework

21st December 2018

Today we have filed with the Commerce Commission our submission on their proposed approach to implementing the new regulatory framework for Fibre services.  In our submission we highlighted three issues:

  • Reliance on the Commission and s162 – with our limited resources we trust in the independance and the expertise of the Commission to ensure their decision focuses on the needs of end users
  • Building Blocks model – generally supportive of the model
  • Service Quality – we will put most of our effort into ensuring that end user needs are reflected in any service quality dimensions used in the process

You can download the full document here: 18Dec TUANZ Submission to ComCom Fibre Process

2nd Feb 2018: Select Committee Submission on the Telecommunications (New Regulatory Framework) Bill

2nd February 2018

Today we have filed with Parliament our select committee submission on the current bill before the house to amend the Telco Act.  Our focus is in ensuring the Act can respond quickly to changes for the benefit of users.  At the recent board meeting, the discussion was very much around how any changes to the Act needs to be forward looking in line with technology advancement and user requirements. 

In our submission we picked out a small number of specific issues:

  • The Pricing Model – generally supporting the proposed utility model but with real concerns that the anchor products may not be flexible enough in definition
  • >Unbundling Fibre – encourage the requirement for unbundling of fibre to remain in the Act
  • Withdrawal of Fibre – asked for a very strong copper withdrawal code to protect end users
  • Service Quality Monitoring – pushed for as much transparency around monitoring and reporting
  • Consumer Disputes – strongly supported strengthening the Commerce Commission’s powers in this area
  • Line of Business Restriction – withheld our opinion on this matter at this point
  • End User Involvement in Advocacy  – once again pushed for the introduction of a model similar to the Australian model where funding is provided to develop high quality consumer focused advocacy.  This is to help overcome the imbalance in resourcing between parties who participate in regulatory process for this market.

You can download the full document here: 18Feb02 Select Committee Submission re Telecommunications Bill Final.

31Jul17 Letter to Telecommunications Commissioner supporting call for review of Mobile Telecommunications Market

31st July 2017

On Friday the 28th July, we wrote to Dr Stephen Gale, the Telecommunications Commissioner, supporting the call for a review of the mobile telecommunications market.

17Jul28 Letter to Dr Stephen Gale

Submission on the Telco Review Options Paper – TUANZ Submission

2nd September 2016

TUANZ (The Telecommunications Users Association of New Zealand) response to the Government’s Telco Review Options Paper.

Read the Submission here.

Review of the Telecommunications Act 2001 ­- TUANZ comments paper

4th November 2015

TUANZ (The Telecommunications Users Association of New Zealand) response to the Ministry of Business Innovation and Employment’s discussion paper: Regulating communications for the future – Review of the Telecommunications Act 2001.

Read here: TUANZSubmissiononTelcoReviewNov15.

TUANZ Cross Submission on UCLL/UBA FPP Price Reviews

5th October 2015: 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.

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

Thank you 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./li>
  • 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.

TUANZ Issues Paper for the upcoming Telco Review

10th August 2018

TUANZ today (10th August) is releasing its paper written earlier this year which outlines the broad issues it believes should be covered as part of the upcoming review of the Telecommunications Act.

You can read the paper here

TUANZ Submission on the Land Access for Telecommunications proposals

26th July 2015

TUANZ has submitted to MBIE our response to the proposals to their discussion document around proposals to make it easier for the rollout of fibre infrastructure through changing the rules for gaining access to property’s.

You can read the submission here.