In August 2015, the TIO commented on the government’s draft Migration Assurance Policy Statement and Framework, aimed at setting the rules for migrating consumers to the National Broadband Network (NBN). In our submission we commented upon aspects of the Policy Statement and Framework that we considered constructive and some areas where we perceived there to be gaps.
Our submission was informed by complaints we have received from consumers who have tried to switch from a copper service to an NBN service.
Issues covered in our submission
Principles and guidance on roles and responsibilities
We welcomed the clear principles and guidance in the Policy Statement and Framework on the roles and responsibilities of different key stakeholders – the nbn as wholesaler, retail service providers and consumers. This guidance would, in our view, help promote the seamless migration of existing services onto the NBN. We also welcomed the clear statement of the TIO’s role and function as a redress mechanism for consumers with complaints about their services as they transition to the NBN.
Availability of NBN at specific premises
Some consumers have told us that although their property is listed in an NBN-ready area, when a technician arrived to connect the service, it was discovered that infrastructure work would be needed to complete the connection. For example, a technician might need to replace an old conduit between the consumer’s house and the street. This additional infrastructure work can cause some delays and lead to frustration for consumers who may be under the impression that because they live in an NBN-ready area, their premises can be connected immediately.
To address this issue, we suggested in our submission that the Framework confer responsibility on nbn (the network wholesaler) and its customers (the retail service providers) to give consumers accurate information about service availability or alternatives when an NBN service cannot be readily connected.
Seamless migration of privacy features
Our submission also noted that some consumers made complaints about losing enhanced service features such as silent numbers and calling number display when they moved from copper to an NBN service. These enhanced service features are important for some consumers in high risk situations or professions where their privacy or safety is critically important. The loss of such service features has had serious consequences for some consumers, including some who had to relocate to new premises and others who had to arrange additional security measures for their homes. We recommended that the Policy Statement and Framework outline the providers’ and wholesaler’s responsibilities to ensure that these features are transferred to NBN services seamlessly.
Copper disconnection before NBN connection
We receive a small but steady number of complaints from consumers who have their copper service disconnected while they are waiting for an NBN connection. We welcomed the inclusion of a clear outline of responsibilities for completing and testing a connection to ensure that the disconnection of a copper service does not happen until the NBN connection is ready.
In a small number of complaints, consumers said that their service provider told them they needed a new number before migrating to the NBN, but they were not told why this was necessary. We recommended that the Policy Statement and Framework include responsibilities for service providers to inform consumers if there are any limitations to porting a number onto the NBN.
Our full submission is available on our website.