IAA is committed to working with the Australian government to improve the security and growth of our sector, and Australia more broadly. To this end, we wish to see coherent, consistent, and commensurate regulation and policies to support the operation and use of the Internet in Australia.
REBUILD INDUSTRY-GOVERNMENT TRUST
Trust has suffered in the relationship between government and the internet industry over successive parliaments enacting intrusive legislation and regulation.
- Reduce the number of government bodies regulating the telco sector – Dept of Communications should be the interface for consultation and regulatory change
The sector has seen a proliferation of regulatory bodies and federal departments to deal with; this means duplication, inefficient consultation and unclear regulation.
- Meaningful consultation by government bodies, and prior to legislative proposals
- Stop the rushed regulatory processes
Legislative reviews have been completed in extremely short time frames, with limited change after consultation and review processes.
- Improve review process for interception review: do the agencies understand the principles and practices of legal intercept?
- INSLM recommendations implemented
The Independent National Security Legislation Monitor made numerous well-founded recommendations after reviewing the TOLA legislation.
- Industry impact assessments prior to new legislation/regulation
- Internet impact assessments prior to new legislation/regulation
A formal process to assess the impact of new legislation that properly examines the impact on the internet and the industry would aim to strengthen the internet as a platform for innovation.
IMPROVED ACCESS TO MARKET FOR SMALL ISPs
Small internet Service Providers do not generally have the capacity to implement complex regulation, and in many cases regulation is aimed at larger players. Clearer exemptions need to apply.
- Reduce barriers to market for small ISPs
- 121 POIs are too many for small ISPs to access, fewer POIs
- Reduce the regulatory burden of critical infrastructure and related regulation
IMPROVE NBN PERFORMANCE
The NBN should be a platform for open competition but suffers from structural inefficiencies and serves to reinforce market concentration in the bigger players.
- Get rid of NBN CVC
- Enforce TIO rulings on underlying carriers (where the infrastructure provider has an issue, but the RSP incurs the fine or remedy)
- NBN service performance improvements (in the face of competition from 5G and Starlink and growing consumer and business demand)
- Improve NBN cost efficiency
- Ensure flat or minimal increase in NBN charging
- Create sustainable low-income measures for NBN services
BETTER INTERNET FOR RURAL AND REGIONAL AREAS
Regional network subsidies have favoured large mobile network operators rather than the broader industry. Grant processes are cumbersome and are not geared to support smaller players.
- Focus on long term critical infrastructure: ducting, power, backhaul
- Improved access for regional IXPs to facilities and backhaul at reasonable prices
- Open access to infrastructure that has been created by government subsidy or USO
- Easier access to grants for infrastructure provision for the wider industry
- Encouraging incentives and funding that encourage industry to build connectivity to regional and rural Australia
COMPREHENSIVE STRATEGY TO AMELIORATE SKILLS SHORTAGE
The pipeline for skilled labour is fundamentally broken and is not producing sufficient numbers of skilled people at all stages of the education lifecycle.
- End-to-end plan to improve skills supply for Australia addressing technical education from early education to ongoing industry training
- Long term solutions to ensure a sufficient pool of talent and skills in Australia that is resilient to external factors
Issued: 5 May 2022