10th November 2021: Submission on the Towards a Digital Strategy for Aotearoa – Discussion Document

On the 10th November 2021 we provided our feedback on the Government’s discussion document on “Towards a Digital Strategy for Aotearoa”.

The basis of our submission was the Digital Priorities for Aotearoa Report and the communique issued as part of the recent Techusers Day held in August 2021.   Our main point was that to lift our nation to the level of leading globally, the Digital Strategy for Aotearoa needs to be ambitious, challenging and a stretch. It needs to have audacious goals which are targeted and a call to action.  And while we think the vision and goals in the discussion document “Towards a Digital Strategy for Aotearoa” is a good start, it does not embody the ambition this strategy needs to realise the benefits for Aotearoa New Zealand.

We also made the point that the whole of business (economy) must be involved in developing and delivering on a holistic digital strategy. The discussion document alludes to this, however, there is no specific action to support the wider business environment or obligation placed on the wider economy. These businesses are not SMEs but are large users of digital services and we would like to see recognition of the importance of the wider business community – both in terms of how Government will support their digital transformation, but also how larger businesses will play their part in securing our digital future.

You can read our brief submission here.

15th October 2021 : Submission on the Improving Retail Service Quality; Draft Baseline Report

On the 15th October 2021 we submitted to the Commerce Commission in relation to their draft baseline report as part of their worksteam on improving retail service quality.

In our submission we agreed that the Commission had identified a strong list of retail service quality matters which need improving.  We participated in the consumer group workshops and shared out own list of issues that we want to see addresses.  Specifically we support the those that are in the areas of:

  1. Billing – customers experiencing errors, struggling to understand their bill and some still experiencing bill shock from unexpected charges.
  2. Customer Service – long wait times and long wait for resolution
  3. Product Disclosure – providers use confusing marketing, service does not match the information, and product disclosure is inadequate
  4. Switching – there is an element of inertia due to consumers believing it to be difficult and time consuming

Our submission specifically provides commentary and possible solutions around Product Disclosure and Switching.  As part of our concern over these two topics  we commissioned the Behavioural Insights Team (BIT) to review and update an earlier report provided to the Commerce Commission in 2019 entitled “Addressing inertia and complexity in New Zealand’s telecommunications market”.  We will be releasing the report in it’s entirety as part of our contribution to work to be undertaken in developing industry codes in this area and advertising of alternative services.

You can read our submission here.

27th August 2021 : Submission to Commerce Commission on marketing of alternative services

On the 27th August 2021 we submitted to the Commerce Commission in relation to their open letter to stakeholders on the topic of the marketing of alterative services to consumers during copper and/or PSTN withdrawal.

TUANZ has over time received anecdotal evidence that the information being provided to consumers facing the decision to switch services as a result of a switch off of the PSTN or the underlying copper network is confusing at the least and misleading at worst. While we know that the requirement to switch in this situation is valid, in our experience there are also cases where this is being used to market alternative services where neither of the underlying reasons is currently being undertaken.

Furthermore, we have been concerned over the general marketing of alternative access services not only in this specific situation but across the board, especially where the consumers are less technologically aware.

Based on the information provided in the open letter, the report that we commissioned from BIT and our general anecdotal evidence we recommended the following actions:

a. We agree with the Commission issuing the principles and outcomes to the industry as guidelines under section 234 in the expectation that RSPs would incorporate them into an Industry code through the TCF;

b. That any code development be with the involvement of user representatives including TUANZ, and utilise the idea of testing prior to implementation;

c. That this new code cover not only the marketing of alternative services in the situation of copper/PSTN withdrawal but across all marketing of all connectivity options; and

d. That this new code replaces or updates the Product Disclosure Code with requirements to present information about services clearly in simple to understand statements which are easily accessible for all users.

You can read our submission here.


18th December 2020 : Submission re the TDRS (Improving Retail Service Quality)

18th December 2020

Today we made our submission to the Commerce Commission on our views around the current Telecommunications Disputes Resolution Service.  We outlined a number of high level concerns:

  • The independence and powers of the TDR Council
  • The Customer Complaints Code should be a required regulated code
  • The scope of the TDRS
  • There should be a requirement for all providers of telecommunications services in New Zealand to end users to be part of an approved disputes service such as the TDRS.
  • As a minimum, there should be a requirement on members of the TDRS to advertise the fact through their website and customer communications.

You can read the full submission here.

3rd July 2020 : Submission re Mobile Termination Access Service Draft Review

3rd July 2020

Today we made our submission to the Commerce Commission on their draft position on the Mobile Termination Access Service review.  Put simply, we support their decision that there is no grounds to begin a review to look at whether the service should be de-regulated.

You can download our brief submission here.

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