Media release: Cross submission asks ComCom to do the job right

InternetNZ, TUANZ and Consumer’s submission on UCLL asks Commission to do the job right

InternetNZ (Internet New Zealand Inc), TUANZ and Consumer have today lodged a cross-submission with the Commerce Commission, requesting that parties take a careful and measured approach to setting the price of the Unbundled Copper Local Loop (UCLL) service as part of the Final Pricing Principle process now under way.

In its submission, the group says that getting this phase of the pricing review right is absolutely crucial. The submission states that if the Commerce Commission acts too quickly, “that may be regretted later.”

InternetNZ CEO Jordan Carter says that rushing now could find the sector back where it was last year – mired in confusion and frustrating debates that serve no purpose.

“The Commission needs to take the time to design the FPP process properly, and to minimise the areas of conflict within the industry. Taking the time to do so now will mean the process works better and gets to a faster outcome in the end.

“Everyone wants to see certainty, but that has to be based on reality. The alternative is further industry chaos, and the risk of wrong and higher prices for Kiwi broadband users.

The submissions released by the Commission already show that the industry is a long way from landing on a collective view for an ideal process and design. We need to get that right,” said Mr Carter.

“Our submission also notes that there are serious problems with the suggestion by Chorus that its own professional advisors do the initial modelling process for the FPP. The Commission has to do that work, to avoid the obvious conflict of interest in Chorus modelling a pricing structure it would be later be bound by through the FPP.

“The public interest in fair pricing for broadband is at risk if the regulated party designs its own cost model,” Carter says.

“We look forward to hearing the Commission’s decision on the next steps. We hope that it takes the views in this submission into account as it does so,” Jordan Carter says.

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The telecommunications review discussion document has lead to quite a bit of, shall we say “discussion” about the review and what it all means. 

As you’ll have seen, TUANZ is part of the “Axe the Tax” campaign as we strongly believe that taking money that was long promised to customers and giving it to Chorus shareholders is simply wrong.

But what do others think? What submissions were received? 

If this was a Commerce Commission process, we’d have a full list of submissions (and cross-submissions) to look at and pick through. We’d see the economic analysis, the legal justifications and the rhetoric from all parties.

Sadly, MBIE tells me they haven’t decided yet on when or even if they’ll put those submissions online.  Given we’re still waiting for the TSO submissions to go public, we could be waiting a long time.

It’s good to have all the submissions in one place and it’s good to have them out there in public. We need to have access to them so we can work out what rationale is being used and why for each position.

So on that score, I invite any and all submitters on the telco review discussion document to send me a copy of their submissions and we’ll make them all public here at TUANZ. 

I’ll email all those I can think of directly seeking a copy but there are bound to be some who have submitted that I don’t know about. It’s a shame – I would have thought the ultimate outcome of calling for submissions on a discussion document would be to have a discussion. 

It seems to be something of an old-fashioned approach these days. 

If you’ve got a submission you want included, send it to: and I’ll add it to the list. If it’s already online, send me the URL (or add it in the comments below) and we’ll save on bandwidth.