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Unfortunately, last month, New Zealand Internet Exchange’s plan to launch the much-anticipated WLG-IX was pushed back due to lockdown restrictions preventing important work needed to get it up and running. Thankfully, as Wellington lifted to level three restrictions, work resumed, and the new IX is now completed and in production, with the official launch date set for November 1 2021. WLG-IX is starting with a 12-month FREE period. Happy peering! 

All those eager to hear about the launch should keep an eye out on NZIX’s social media accounts.

 

We are excited to announce that Google has joined VIC-IX! With Google being only one hop away across VIC-IX, your customers can now access a wide range of their favourite content through our network.  

It’s always good to have quality content providers joining. If you have any content providers that you would like to see on our IX’s, we would love to hear from you! 

 

October’s Advocacy Corner Update

The Federal government is continuing to ramp up its program of legislation aiming to control the perceived and real threats from the online world. We’ve written about our participation in the defamation workshops, but just recently it has become clear that the government would like to see defamation regulated the same way as it wants to regulate more obviously dangerous material, ie through the eSafety Commissioner and alongside the Online Safety Act. 

There are some very real risks we see with this approach: it is not clear where the liability and responsibility for defamatory material will lie, nor even whether this can be efficiently or effectively implemented. It became increasingly clear throughout the workshops that while it was accepted that straight carriage service providers won’t be liable (as “mere conduits”) other services usually included in an internet access service such as DNS, email, and web hosting, where ISPs have no effective part in the publication of material, may well have liability. Rest assured, we are doing our darndest to reinforce the fact that making a domain name available via the DNS is not an act of defamation, but unfortunately there are no guarantees that legislators won’t do something really stupid. They seem to find it difficult to separate certain large social media platforms from “the Internet” and are increasingly keen to enforce takedowns further and further down the technology and infrastructure stack. 

An amended Critical Infrastructure Bill through the House of Representatives last week. Introduced as part of the PJCIS’ report on the Critical Infrastructure Bill, this legislation will see the introduction of a new mandatory notification scheme for cyber incidents. It will also provide Home Affairs with the power to issue information gathering, intervention and action direction requests. Part II of the Bill, which will focus on risk management plans and the declaration of Systems of National Significance (SoNS), is expected to face further consultation with industry. 

Communications Alliance released a new code C666:2021 Existing Customer Authentication, which provides an improved framework to authenticate the identity of customers making transactions involving their telecommunications service. So new rules there for people to apply when gaining or transferring customers. 

Recent Submissions

In October, we made submissions to: 

 

Open Submissions

Reporting of Telstra delivery of voice services | Department of Communications 

The Department of Communications has proposed that Telstra should improve their reporting of their voice services delivery in regional areas and provide quarterly reports to ACMA and Department of Communications relating to service quality and delivery. 

Record Keeping Rules Consultations | ACCC 

The ACCC is consulting on changes to the Record Keeping Rules for Telecommunications Infrastructure Assets. The Record Keeping Rules requires specific carriers to report on their core network and customer access network infrastructure to help the ACCC analyse competition within the telecommunications market.  The ACCC is seeking to update their list of record-keepers and introduce new reporting requirements for end-user equipment and mobile infrastructure.  

The ACCC is also seeking to amend the NBN Record Keeping Rules, including introducing reporting for enterprise ethernet services and businesses satellite services. They will also gather additional data on CVC capacity and utilisation data and ask NBN Co to report on performance against service standard commitments set out in the Wholesale Broadband Agreement. The latter agreement is still open to review, despite some members reporting they felt pressured to sign version five already. 

There’s nothing like setting the dates for the end of year change freeze (22 Dec – 10 Jan) to make you sit up and notice the year is almost over! At least most of us are out of lockdown in time to do some seasonal shopping. On our shopping list is a brand new out of band network, and a few extra switches to accommodate all the member growth we keep seeing! The big Facebook outage recently demonstrated just how important your out of band access is when the network is broken, and that out of band access is vital for ensuring you can get access to sort whatever problem the network or our own humanity causes. Our existing out of band network is old and barely serviceable, so it’s definitely time for a replacement. 

Speaking of replacements, we are currently advertising for a new Policy Officer and Network Engineer, both of whom are off to new roles. If you know of anyone that might be suitable, drop us a line – they need to be totally fluent in internet acronym-speak, albeit somewhat different ones for each role, and be truly dedicated to serving our industry and making the Internet better. 

We’ll also be recruiting soon for an Advisory Council. The council will comprise members/member representatives and is to assist us in forming our positions on the various regulatory and policy issues and will meet about four times per year to give us that guidance. We’d love to hear from your policy nerds or even business people that have an interest in sensible rules within our industry. If we can pick the brains of a few of you, our submissions and representation will be even better! 

A huge congratulations to the team and to NZIX with the launch of WLG-IX. With two initial points of presence, this is a great expansion to the existing services across New Zealand. The POPs are in Xtreme and Spark’s Featherstone sites so nicely accessible to many of the Wellington service infrastructure.  

You may have noticed that auDA has finally launched the timetable for direct registrations in the .au namespace. This means you will be able to register your own domain names as a second level domain directly under .au. If you already have some_example.com.au then you will have priority in getting some_example.au as long as no-one else has some_example.org.au etc. Most countries have direct registrations already and it didn’t break their internet when it was introduced, but members should be aware that this change is coming, and it might mean extra effort in your DNS or customer support. Or you might want to try a whole new marketing approach with your shiny new short url. Check the auDA website for the full rules and the timetable. 

Last but not least, I must extend my thanks to member Ciphertel for stepping into the breach when we couldn’t get to QV1 for the power outage this month. It is brilliant to see the value our members bring. I just hope the coffee in the new café is good enough to justify the hassle. 

As ever – please feel free to get in touch to give me your views on any of the topics in this month’s newsletter. 

Narelle Clark  

IAA submitted to Home Affairs Strengthening Australia’s cyber security regulations and incentives paper. In our submission, we highlighted the complexity of existing cybersecurity legislation, especially for smaller ISPs to navigate. We commented on suggested mechanisms which could promote the uptake of cybersecurity, including minimum standards for personal information and health checks for small businesses. We called on Home Affairs to collaboratively engage with relevant industry stakeholders throughout the process of drafting cybersecurity regulation or processes.

IAA supported the extension of the Wholesale ADSL to 20 June 2024 in our recent submission to the ACCC. We raised the point that WADSL as continues to be prominent in rural, regional and remote areas, it needs to be provisioned for.

We also expressed our perspective on ACMA’s Statement of Expectations (SoE) for the Telecommunications Industry with regards to vulnerable consumers. We extended our support to the SoE, however, highlighted that for smaller ISPs, some objectives and examples regarding financial hardship and customer service would be difficult to meet because of resource constraints.

The ACCC published updated Non-Discrimination Guidelines for the telecommunications sector, a process we responded to in June. In the new Guidelines, the ACCC will assess whether NBN Co or access providers have acted in a discriminatory manner by conducting an explicit or implicit discrimination test. A quick summary of how this process will work is available here.

 

The transition to a company limited by guarantee continues as we patiently wait to hear back from ASIC to register under the Corporations Act 2001 (Cth) with deregistration from the Associations Incorporation Act 2015 (WA) complete.   

With lockdowns and now even the earthquake, paperwork processing at ASIC has been delayed. Members should rest assured that we will call the AGM as soon as we hear from ASIC!  

We would like to extend our gratitude to members who participated in the workshops and consultations and voted on the transition. As a member-run association, your input is invaluable.   

At long last we have migrated off the BDX8. When Covid prevented the road trip to Melbourne the team had planned, it was down to crossing our fingers and hoping Delta could be stopped. After 6? 8? 10? weeks of lockdown and countless error messages, the decision was made to pull the proverbial plug, and engage remote hands.  

Aaron has apparently compiled the best set of work instructions ever, and our remote smart hands followed the bouncing ball all the way through to the end. The BDX8 is no longer at the heart of VIC-IX; however, it continues to have three 1Gbps users.   

A special thanks to Aaron for a great job, our remote hands for your assistance over the distance, Nick for the late-night supervision, and to Washif for the checking.  

Brilliant effort, team. A huge well done. 

This morning, members received an email regarding a configuration issue with Netflix caches. The issue was recently identified and has since been resolved. As a result, members will need to complete the following process to access these caches: 

1. Create an AS-SET that lists your residential customers or provide the information to our team. 

2. Tag BGP advertisements to route-servers with the following communities, based on peering location. 

  • 10084:2504 WA OCA Opt-In 
  • 10084:2514 VIC OCA Opt-In 
  • 10084:2524 QLD OCA Opt-In 
  • 10084:2544 NSW OCA Opt-In 
  • 10084:2534 SA OCA Opt-In 

If you require any further information or assistance, please do not hesitate to contact our team at support@internet.asn.au or call us on 1300 793 320. 

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