Chapter 3
Regulatory Measures Customer Service
Terms of Reference (c) (d) and (e):
(c) the effect on delivery and quality of services for rural, regional
and remote areas and for smaller States and territories;
(d) whether the provisions of the Telecommunications Act
1997 and the Telstra (Transition to Full Private Ownership)
Bill 1998 provide effective and adequate consumer protection safeguards,
including:
i. access to untimed local calls;
ii. free directory assistance;
iii. public telephone facilities;
iv. customer service guarantee; and
v. price caps;
(e) the effectiveness of the standard telephone service, as guaranteed
under the Universal Service Obligation, in ensuring that rural and regional
customers have access to modern telecommunications services and whether
the standard telephone service definition needs to be expanded to take
account of rapidly changing communications technology
Customer Safeguards Provided by the Bill
3.1 The preamble to the Bill, which is the subject of this inquiry, reaffirms
the Parliament's commitment to the community and regulatory safeguards
enacted in the 1997 telecommunications legislation.
3.2 In his second reading speech, the Minister for Finance and Administration,
the Hon John Fahey MP, stressed the government's commitment to `comprehensive
community and regulatory safeguards', including the following which are
all currently enshrined in legislation and which the government has pledged
to maintain:
a) a clear universal service obligation to ensure that standard telephone
services and pay phones are reasonably accessible to all people in Australia
on an equitable basis, wherever they reside or carry on business, as required
by part 7 of the Telecommunications Act 1997;
b) continued access to untimed local calls, which is required by part
8 of the Telecommunications Act 1997;
c) the customer service guarantee imposed by part 9 of the Telecommunications
Act 1997;
d) special benefits for rural and regional customers of carriage service
providers under section 226 of the Telecommunications Act 1997;
e) a price-cap regime established in part 6 of the Telstra Corporation
Act 1991; and
f) a flexible regulatory structure designed to stimulate competition
in the telecommunications market and thus deliver cheaper prices, and
new and improved services, to Australian residential and business telecommunications
users, as set out in the Telecommunications Act 1997 and parts
XIB and XIC of the Trade Practices Act 1974. [1]
3.3 The Department of Communications and the Arts (DoCA) also pointed
to those regulatory aspects in its submission:
In recognition of the potential for differing levels of competition in
different areas, the current regulatory regime contains a number of safeguards
which will protect all consumers, but which are particularly important
to those living in the smaller States and/or rural and remote areas where
competition may be slower to develop. These obligations, such as untimed
local calls, contributing to meeting universal service obligations and
customer service guarantee, are imposed on all carriers, including Telstra.
These are set out, in detail, in legislation and associated legislative
instruments (eg licence conditions). Price caps only apply to Telstra
but these will be retained in the legislation and are independent of the
issue of ownership of Telstra. [2]
3.4 The Secretary of the Department stated in evidence to the Committee
that:
The overall telecommunications regulatory regime provides a range of
powers for governments to intervene on the provision of services through
the universal service obligation and licence conditions. All of those
are applicable to carriers, regardless of ownership.
He later added:
I believe the customer service guarantee we have here is as good as anything
in the world. [3]
The Universal Service Obligation
3.5 As mentioned above, the Bill maintains the Universal Service Obligation
contained in the Telecommunications Act 1997 and standard carrier
licence conditions. The USO currently costs about $260 million per year,
of which Telstra pays about 90 per cent.
3.6 In their submission to the Committee, the Country Women's Association
called for assurances that those obligations would be maintained:
This Association seeks a guarantee from the present Government that interests
of country people in the area of telecommunications, for private, business
and educational purposes, will not be disadvantaged by this proposed Bill
and if legislation is enacted on the proposed sale of the remaining two-thirds
of Telstra, it enshrines a clause which will ensure that any subsequent
government will maintain the intent of the 1998 legislation. [4]
3.7 The Minister's second reading speech not only gave that undertaking
but he assured mobile phone users in regional Australia, that while the
phasing out of the analogue AMPS mobile phone network was proceeding,
the government would:
Introduce a package of measures designed to ensure that all areas of
regional Australia which currently receive mobile coverage will continue
to have reasonably equivalent coverage after 2000. [5]
Universal Service Plans
3.8 Any telecommunications carrier can be declared the national universal
service provider for Australia. Telstra currently fulfils that role and
will continue to do so until (and if) the Minister's declaration is revoked.
As the national universal service provider, Telstra is required to give
to the Minister for Communications, the Information Economy and the Arts
a draft universal service plan for approval. The plan must set out how
the selected carrier intends to progressively fulfil its universal service
obligation. The Australian Communications Authority (ACA) assesses the
plan and makes recommendations to the Minister.
3.9 The Minister approved Telstra's universal service plan on 18 May
1998 [6] after Telstra had made amendments to
an earlier draft plan which had not been approved on the recommendation
of the ACA in November 1997. The plan details how Telstra will give effect
to its Universal Service Obligations. Under the plan, Telstra commits
itself to specified timeframes for providing telephone connections, repairs,
payphones and services for people with disabilities.
3.10 The commitments made on connection times are to be incorporated
into the Customer Service Guarantee standards. For example, the maximum
connection time for a remote area settlement of less than 200 people with
no existing infrastructure has been reduced from 27 months to 12 months.
Customer Service Guarantee
3.11 When the Government developed legislation to enable the sale of
one-third of Telstra in 1996, it amended the Telecommunications Act
1991 to require that the carrier meet certain standards for connection
of services, rectification of faults and keeping of appointments. The
legislation provides for penalties (to be credited to customers) for failure
to comply with these requirements. These provisions were carried subsequently
over to Part 9 of the Telecommunications Act 1997 and have applied
to all carriage service providers since 1 January 1998.
3.12 The Customer Service Guarantee standard (CSG) has been developed
by the Australian Communications Authority (ACA) and is set out at Appendix
5 of this Report.
3.13 The CSG standard sets out minimum service levels that the specified
carrier is required to meet, such as for example:
i) Connection of a service within three working days where there is already
an `in-place' connection;
ii) The repair of faults in metropolitan areas before the end of the
next full working day after receipt of a customer report (two working
days in rural areas and three working days in remote areas);
iii) All agreed appointments at customer premises are required to be
kept, with penalties applying where the phone company attends more than
15 minutes later than the agreed appointment time.
3.14 The Committee heard evidence from Western Australian witnesses of
Telstra's failure to meet its Customer Service Guarantee obligations.
The WA Department of Commerce and Trade submitted to the Committee that
a resident in Lake Grace, Western Australia was asked to wait over 6 months
for an `in-place' connection to be made. It also gave examples of Telstra's
failure to provide prompt repair services in the Hyden region of the State
in October 1997 and February 1998. [7]
3.15 Both the WA Department of Commerce and Trade and Dr Walter Green
of the Communications Expert Group in Western Australia called for amendments
to be made to the legislation to ensure that Telstra (or any future carrier
subject to the Universal Service Obligation) meet its Customer Service
Guarantee obligations.
3.16 The Committee is aware that following a direction from the Minister,
the ACA is currently looking at ways of ensuring that the service providers
provide better information to their customers about their legal rights
under the CSG scheme and put more effort into training front-line staff.
3.17 The Telecommunications Industry Ombudsman (TIO) told the Committee
that lack of awareness of the existence of the Customer Service Guarantee
and of the carriage service providers obligations towards telecommunications
customers is a major problem. [8] The evidence
before the Committee from individual consumers and small organisations
suggests that there is indeed a need for the public to be better informed
about their rights in accessing telecommunications services.
3.18 In this context, the Committee notes that:
The ACA is in the process of devising an information strategy for the
[Customer Service Guarantee] CSG that will complement and support its
customer information focus. The information strategy for the CSG will
include the use of fact sheets, newspaper, radio, TV, as well as other
targeted media and information outlets. The ACA will also be monitoring
performance against the CSG standards, and will be informing customers
about CSG entitlements. [9]
3.19 The Communications Law Centre (CLC) argued in its submission that
it was not sufficient for the Customer Service Guarantee Standard to require
that customers be informed of the service providers' obligations in relation
to connection and fault repair times outside of the prescribed timelines:
The Standard should ensure that customers are informed of all service
provider obligations and penalties under the Standard. [10]
3.20 The Committee shares the CLC's view that better public information
would lead to a better standard of service. It recommends therefore that
the requirement to keep customers informed should be enshrined in the
Standard.
Recommendation 1
The Committee recommends that Clause 6 of the Telecommunications
(Customer Service Guarantee) Standard 1997 require that customers
be informed of all service provider obligations and penalties under the
Standard
and
That Section 480 of the Telecommunications Act 1997 be
amended to require providers of all services subject to the Telecommunications
Industry Ombudsman's jurisdiction to supply to each customer a reasonable
summary of the terms and conditions on which the service is supplied (and
an updated summary where those terms and conditions change), including
all service provider obligations and penalties set under any Customer
Service Guarantee standard under section 234.
Expanded powers to the ACA
3.21 The Committee notes also that the current Bill seeks to amend the
Telecommunications Act 1997 to expand the powers of the Australian
Communications Authority (ACA) in regard to the CSG. In particular, the
ACA will be able to require telecommunications carriage service providers
to take remedial action to correct any systemic problems in meeting CSG
performance standards.
3.22 The ACA could initiate such an action (in which case it would first
need to consult with the Telecommunications Industry Ombudsman (TIO))
or it could be directed to do so by the Minister. The Bill provides for
penalties (under Section 236A) of up to $10 million for failure to comply
with an ACA direction under this new power.
3.23 The Committee notes that the size of the penalties that would apply
under Section 236A of the amended Telecommunications Act 1997 should
put pressure on telecommunications carriers to identify and solve recurring
problems.
3.24 The ACA has also been asked to review the current standards after
12 months of operation (by 1 January 1999), in consultation with the Australian
Communications Industry Forum and other groups and to suggest tighter
standards where they might be practicable.
3.25 The Committee notes that the amendments in the Bill to enable the
ACA to give directions to carriage providers to require them to take action
to ensure that CSG performance standards are met are supported by the
TIO. [11] The Committee agrees with the TIO
that the details of the enforcement mechanism need to be made clear.
3.26 The Committee is mindful of the evidence from both the TIO and the
Australian Telecommunications Users Group (ATUG) [12]
which shows that customers would rather have the carrier adhere to its
CSG obligations than receive compensation for non-compliance.
3.27 However, the Committee is concerned that at the current rate at
which penalties are imposed, it might be cheaper for a carrier to pay
the penalty rather than provide the service. The Committee believes that
in order to deter telecommunications carriers from adopting this approach,
the penalties applying in non-metropolitan areas should be increased.
Accordingly the Committee recommends:
Recommendation 2
The Committee recommends that the penalty for failure to meet the
Customer Service Guarantee standard in non-metropolitan areas be amended
so that after a week, the $11 per day penalty could for example, accelerate
incrementally or to $100 per day for each extra day that the service is
not provided.
3.28 The Committee believes that when the measures described above have
been implemented, the Australian Communications Authority's scope for
monitoring the performance of the carriers, and for ensuring compliance,
will be greatly enhanced for the benefit of consumers. The Committee believes
that both the TIO and the ACA should closely monitor levels of consumer
awareness and of consumer satisfaction after the above measures are implemented.
3.29 In the event of further non-compliance, the Committee's view is
that ATUG's suggestion of introducing carrier performance standards through
legislation (similar to the United States model) could be worthy of consideration.
Untimed local calls
3.30 Among submissions which opposed the sale, fear was expressed that
a privatised Telstra would want to do away with the cross-subsidies which
keep access to the national network affordable for all Australians wherever
they live. [13] The Flinders Council, in Bass
Strait emphasised:
It is also important that there is access to untimed local calls and
the same guarantee is given to customer service, regardless of point of
origin of customer. Pricing should also be based upon equity in that all
customers receive the same costing. [14]
3.31 The Committee notes that access to untimed local calls is guaranteed
by Part 8 of the Telecommunications Act 1997. This is a requirement
that is imposed on all carrier service providers supplying a standard
telephone service. Changes in ownership of Telstra will not change these
provisions. [15]
Definition of standard telephone service
3.32 The Universal Service Obligation (Part 7 of the Telecommunications
Act 1997) also covers the provision of the Standard Telephone Service
(STS). Although the standard telephone service is defined as voice telephony
(or an equivalent service for a person with a disability), the voice service
generally has the capacity to carry digital data such as facsimile, e-mail
and Internet communications with varying success. The rate of digital
transmissions on the standard voice grade telephone line is generally
up to 55 kbps. [16]
3.33 A number of submissions and witnesses raised the STS as an issue,
suggesting that the provision of a standard telephone be upgraded to include
certain levels of broadband capacity to rural and regional areas. [17]
The need for a 64 kilobits per second capacity was a recurring theme.
In evidence before the Committee, the National Farmers' Federation considered
that the obligation to provide a standard telephone service countrywide
be upgraded to a guarantee to provide a `standard telecommunications system'
so that rural communities would have access to the Internet and other
data services. [18]
3.34 The Communications Expert Group, based in Western Australia, deplored
the fact that in some areas of the State:
The delivery of ISDN or data services … has been delayed due to
investments in high density areas. This has occurred under the existing
legislation… Of particular concern is the diversion of funds to the
“Cable Rollout Program” which has delayed the “FMO”
[Future Mode of Operation] program.
The Group then recommended that:
… the Minister declare a program with fixed milestones for the introduction
of ISDN services throughout Australia [and] that the standard telephone
service be upgraded to 64kb/s and the existing data transmission speed
of 2,400 bits/sec be deleted. [19]
3.35 In reply to the concerns raised, the Department of Communications
and the Arts pointed out that:
Telstra will continue to upgrade its services in regional areas, building
on its current program of upgrading all of its exchanges to digital around
Australia, which is expected to achieve effective completion by December
this year.
Already, over 95 per cent of Australians can receive high quality, high
bandwidth ISDN services within 90 days of request. Under licence conditions,
Telstra must extend availability of such services to 96 per cent of the
population by the end of this year. Failure to meet this licence condition
can result in similar penalties to those envisaged under new s.236A. [20]
Delivery and quality of services to Rural & Regional Areas
3.36 The implications for rural areas of the lack of access to telecommunications
services readily available in metropolitan areas are profound. Access
to all essential services, from health services as telemedicine expands
[21], to education and financial services all
depend on quality telecommunications services at an affordable rate.
3.37 A number of organisations suggested that rural and regional telecommunications
services could be enhanced if part of the sale proceeds were allocated
to improvements to rural and regional telecommunications infrastructure.
3.38 The Committee notes the position of the National Farmers' Federation
and others in requesting an immediate upgrade of the Standard Telephone
Service definition. They also suggested that rural and regional services
would be enhanced if part of the sale proceeds were allocated to regional
improvements. The National Farmers Federation Council adopted a resolution
calling for `the social bonus component of the funds from the sale [to
be] directed to capital projects', with $1.25 billion of proceeds from
the sale of Telstra to be earmarked for the installation and upgrade of
rural telecommunications services. [22] The
Western Australian Department of Commerce and Trade supported the use
of most of the sale revenue to retire debt but suggested that `a significant
part of the remainder be used to improve access to telecommunications
services throughout regional, rural and remote Australia.' [23]
3.39 It was also suggested to the Committee that at least $3 billion
of the sale proceeds be allocated to the Universal Service Fund to ensure
rapid roll-out of the significantly upgraded service that would be required
if the existing definition of a Standard Telephone Service were expanded.
[24] The National Farmers' Federation supported
this approach but did not put a figure on the `provision of new and upgraded
telecommunications services to rural and remote Australia'. [25]
3.40 The Western Australian Department of Commerce and Trade proposed
that the existing Regional Telecommunications Infrastructure Fund (RTIF),
established by the present government in December 1996, be allocated a
further $1 billion and be used to distribute funding. The WA Government
considers that the Fund is presently constrained by an `unrealistically
low' allocation of $250 million over 5 years and by the current emphasis
on `non-metropolitan populations'. This disadvantages Western Australia.
[26] The National Farmers Federation also supported
the RTIF being topped up by proceeds from the sale of Telstra.
3.41 The Committee supported the position put to it by these organisations
but considered that the mechanism of delivery of the rural upgrade, the
sum allotted and its geographic distribution should be left to the government
to decide.
Recommendation 3
The Committee recommends that a portion of the proceeds from the sale
of the remaining two-thirds of the Telstra Corporation Ltd be used to
upgrade the existing infrastructure available for telecommunications services
in rural areas.
Quality Service At what price?
Small Business
3.42 The Small Enterprise Telecommunications Centre Limited (SETEL),
one of the groups representing the small business sector needs in relation
to telecommunications issues, stated in its submission that there is general
support for privatisation in the small business sector. It stressed however,
that small businesses should be recognised as a separate class of consumer,
distinct from residential consumer and noted the recent improvements in
recognising the telecommunications needs of small business in the Telecommunications
Act 1997. [27]
3.43 The Council of Small Business Organisations of Australia Ltd (COSBOA)
also supports the full privatisation of Telstra but it had some reservations:
COSBOA recognises the need to balance the Federal Budget and acknowledges
the Government's mandate, but were it not for these, we would have difficulty
supporting the transfer of such an increasingly essential service to the
vagaries of the private sector. [28]
3.44 Small businesses are increasingly made up of single employees or
family employees only and are often home based. This confuses the residential/business
line rental issue. There is also an increasing reliance on electronic
commerce and the Internet in operating a business. It is for these reasons
that COSBOA considers that a major issue for small business is the fact
they are charged on a business rather than a residential basis, without
the benefits of being able to negotiate bulk discounts. [29]
Rural small business
3.45 SETEL considered that small businesses that were home-based, non
employing and micro-businesses should be treated as residential customers
under the Telecommunications Act 1997. [30]This
would include some rural small businesses.
3.46 There is a concern in the small business community, particularly
in rural and remote areas, that there are insufficient Points of Presence
(POPs) for Internet Service Providers to ensure access to electronic commerce
and other Internet services at local call rates. [31]
What do small businesses need in telecommunications?
3.47 COSBOA argued that the usage pattern and telecommunications needs
of single to five line firms are identical to those of residential users,
and it is therefore inappropriate for 37% of Telstra's profits being derived
from 32% of its lines used by small business. [32]
However there is some concern about the current accuracy of the data and
COSBOA itself suggested that `we re-examine the data that we brought out
several years back because it is dated'. [33]
Rural Schools
3.48 The Committee was told by the Australian Secondary Principals' Association
(ASPA) that in the past two years, schools have been required to pay commercial
rates (rather than residential rates) to Telstra for fax services that
dropped out, poor quality of line and very slow Internet service. [34]
The amount quoted by Telstra was $240 pa compared to $140 pa. While this
was not considered by the Association to be significant for larger schools,
it could be a problem for small primary schools. [35]
3.49 The Association could only prepare preliminary figures for a comparison
between the costs for telecommunications facilities for rural and urban
schools, as requested by the Committee at the Melbourne hearing. The figures
show a range of costs for schools of similar size:
$ 2 400 at Point Gellibrand, Vic (city - 1998 estimate)
$18 000 at Orbost, Vic (country – 1998 estimate)
$ 23 400 at Nightcliffe, NT (country – 1997 actual)
$ 34 400 at Katherine, NT (country – 1997 actual).
3.50 ASPA explained that there are a host of reasons for the variations,
one of which is the size of the State and added that ` there is no
doubt that the difference between rural and city schools of similar size
is out of proportion to any additional funding they may receive. A factor
of perhaps 2 or 3 would seem to be the norm'. The figures show:
…just how significant access to reliable and effective telecommunications
facilities is to country schools seeking to redress the disadvantage suffered
by their students. [36]
3.51 The Committee fails to see how Telstra can justify its new approach
to schools. The proportion of schools around Australia that are run on
a commercial basis is infinitely small. In the Committee's view, Telstra's
decision to charge commercial telephone rates cannot but disadvantage
rural schools in an area (telecommunications) where their needs are arguably
greater than their urban counterparts.
3.52 The Committee believes that Telstra should reverse this decision.
Small rural schools in particular should have access to telephone services
at residential rates. The current price control arrangements imposed on
Telstra under the Telstra Corporation Act 1991 may be the most
appropriate way to ensure that schools are given a choice on how they
should be charged for telephone services. The Committee notes that some
large schools may benefit from the opportunity to use bulking arrangements
available under the commercial rates option.
Recommendation 4
The Committee recommends that schools, and in particular rural schools,
be given the option of having access to telephone services at the rate
Telstra charges residential customers, rather than being required to pay
commercial business rates.
Quality of service
3.53 The needs of indigenous communities in remote areas were presented
to the Committee in a submission from the Aboriginal and Torres Strait
Islander Commission, who explained how some of their concerns about Telstra's
service quality had been met:
ATSIC has been monitoring the services provided by Telstra to discrete
Aboriginal and Torres Strait Islander communities in rural and remote
areas. This has resulted in a more focused attempt by Telstra to address
the backlog of need [in service delivery]. [37]
The Committee notes that Telstra has employed Aboriginal liaison officers
in relevant areas.
3.54 Concerns about the standard of service provided by Telstra to country
areas have been confirmed by statistics contained in the ACA's Telecommunications
Performance Monitoring Bulletin for the December 1997 Quarter. There
were declines in the provision of new services on or before the `agreed
commencement date'; in the number of faults cleared within one day and
within two days; and in the clearing of faults with payphones within one
and two days. [38] It was further put to the
Committee that:
…in regional Victoria, for instance, the number of ACDs met in January
this year still remained 12% below the levels of 12 months ago. [39]
3.55 Telstra released its own quality of service figures for the March
1998 quarter, before the end of the quarter, which showed some improvements
on the December 1997 quarter. The Australian Communications Authority
as part of its normal monitoring activity has not yet released these figures.
[40]
3.56 Mr Blount, CEO of Telstra Corporation Ltd., argued that recent difficulties
in service provision were not limited to the bush:
I am very painfully aware of the fact that in the last quarter of last
year, and even into the first part of this year, we had a blip in our
customer service on at least two elements, and that's service provisioning
for new /access lines and all fault repair. And it was not…focused
on the bush or the country, it was throughout. And it really was caused
by, I think, two major factors: one was weather like I don't think we've
experienced in 10 years in that last quarter with rains and lightning
and the like…we really had a flawed, very flawed introduction of
a new force load management system in our commercial and consumer division…So
let me just acknowledge that we've had some service difficulties, but
let me also tell you that it had nothing to do with privatisation. [41]
3.57 Telstra Corporation told the Committee:
If I take you through the service standards being provided today right
across the board in Australia,commercial, consumer, directory assistance,
access, faults and so on,there is some variability, but the standard of
service being applied across Australia overall is certainly no worse than
a couple of years ago. [42]
Conclusion
3.58 The Committee deplores the apparent drop in the level of Telstra
services during 1997. The onus is on Telstra to provide better service
to its customers. However, the evidence before the Committee failed to
prove that the problem was linked to the partial privatisation of the
company or that full privatisation would exacerbate it. The Committee
is satisfied that the amendments to the operation of the Customer Service
Guarantee obligation introduced through the current Bill will assist in
improving the level of service.
Footnotes
[1] The Hon John Fahey MP, Minister for Finance.
2nd reading speech, House Hansard, 30 March 1998, p. 1891.
[2] Submission No 30 (Department of Communications
and the Arts), p.159.
[3] Transcript of Evidence, p. 190 (Mr Stevens)
[4] Transcript of Evidence, p. 86 (Country Women's
Association, Opening Statement)
[5] The Hon John Fahey MP, Minister for Finance.
2nd reading speech, House Hansard, 30 March 1998, p. 1891.
[6] Alston, Senator the Hon. Richard, Minister
for Communications, the Information Economy and the Arts, Media Release,
18 May 1998
[7] Transcript of Evidence, pp 140-141 (Mr Skelton)
[8] Transcript of Evidence, p. 165 (Mr Pinnock)
[9] Submission No. 26 (Australian Communications
Authority), p. 110.
[10] Submission No. 55a (Communications Law
Centre), p. 827
[11] Submission No. 48 (Telecommunications
Industry Ombudsman), p. 352.
[12] Transcript of Evidence, p. 61 (Mr Horsley)
[13] Submission No. 17 (Mr Sidebottom), p.
2.
[14] Submission No. 49 (Flinders Council),
p. 2.
[15] Submission No. 26 (Australian Communications
Authority), p. 2.
[16] Note: A bit is a unit of digital signal
transmission: binary digit (bit) per second, often used with prefixes
kilo (k) meaning one thousand, mega (M) meaning one million, and giga
(G) meaning one thousand million.A 64 Kilobit service provides a platform
for faster access to a range of services, such as fax, email,
access to the Internet, electronic commerce and educational applications.
For example, a 64Kbit service enables a standard A4 page to be faxed in
4 seconds, compared to 100 seconds on a 2400bps service, or 9 seconds
on a 28.8Kbits service (28.8 Kbits is achieved on many standard voice
grade telephone lines).
[17] Submission No. 15 (Communications Expert
Group) p. 44, 15a (Communications Expert Group), Submission No. 63a (National
Farmers' Federation), p. 648.
[18] Submission No. 63a (National Farmers'
Federation), p. 653.
[19] Submission No. 15 (Communications Expert
Group), p. 44.
[20] Department of Communications and the Arts,
Answers to Questions on Notice, 9 May 1998, p. 14.
[21] Transcript of Evidence, p. 87 (Mrs Smith)
[22] Submission No. 63a (National Farmers'
Federation), p. 660.
[23] Submission No. 32 (Government of Western
Australia), p. 247.
[24] Submission No. 32 (Government of Western
Australia), p. 248.
[25] Submission No. 63a (National Farmers'
Federation), p. 660.
[26] Submission No. 32 (Government of Western
Australia), p. 248.
[27] Submission No. 65 (The Small Enterprise
Telecommunications Centre Ltd), pp 543-546.
[28] Submission No. 78 (Council of Small Business
Organisations of Australia Ltd.), p. 676.
[29] Transcript of Evidence, p. 243 (Mr Bastian)
[30] Submission No. 65 (The Small Enterprise
Telecommunications Centre Ltd), p. 544.
[31] Submission No. 65 (The Small Enterprise
Telecommunications Centre Ltd), p. 545.
[32] Submission No. 78 (Council of Small Business
Organisations of Australia Ltd), p. 677.
[33] Transcript of Evidence, p. 243 (Mr Bastian)
[34] Transcript of Evidence, p. 172 (Mr Eakin)
[35] Additional information to Submission No.
50 (Australian Secondary Principals'Association)
[36] Additional information to Submission No.
50 (Australian Secondary Principals'Association)
[37] Submission No. 62 (Aboriginal and Torres
Strait Islander Commission), p. 481.
[38] Australian Communications Authority, Telecommunications
Performance Monitoring Bulletin for the December 1997 Quarter, 31 March
1998, 25 pp.
[39] Submission No. 47a (Communications Electrical
Plumbing Union), p. 511.
[40] Submission No. 55a (Communications Law
Centre), p. 6.
[41] ABC TV Lateline. Maxine McKew interviews
Mr Frank Blount, CEO, Telstra Corporation Ltd, 15 April 1998
[42] Transcript of Evidence, p. 116 (Mr Shore)