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First of all I must extend a huge thank you to all the members who took the time and effort to read through all the papers and material associated with our proposal to convert to a company limited by guarantee. We’ve gone through quite a process to consult, check and review mountains of paperwork to ensure that we have a solid basis for the transition and a constitution that can serve us well into the future. Now that we’ve been through this process, we’re keen to put the new constitution to members for approval and the Special General Meeting to set the mechanics of transition in motion has been formally called. I hope to see you there on the Wednesday 28 July.

This has also been quite the month for internet regulation. Luckily, we held our From Encryption to Take Downs: Internet Regulation Update earlier this month to get us all fired up! The ACCC has recently started a review of the NBN Standard Access Undertaking, and we have been invited to participate. This is meant to be a short circuit to improve the regulatory environment and bring all the fibre-to-the-node (also known as MTM) technologies under the same regulation as the original fibre-to-the-premises. NBN Co has proposed a number of regulated pricing changes, none of which – sadly – guarantee a net price decrease. We will be seeking more member input as the process evolves. Please feel free tell me what you think!

We’ve also started participating in the code development for the newly passed Online Safety Bill. This bill requires a range of processes to ensure certain offensive content is promptly removed, but there are a range of definitional problems and potential process proliferation, not to mention the possibility of duplicating all the existing complaints and other take down procedures. There’s also talk of having to have a string of codes for each part of the internet. Again, if members have thoughts on how to make this a practical, useful system, please get in touch.

The team in NSW also started settling into our new office in North Sydney. Of course, the latest Covid outbreak has us working at home again, but we’re thoroughly enjoying sharing the space and the ease of problem solving when everyone’s in the same room! Members should come by if they’re ever in North Sydney. We are hoping to schedule an office warming as soon as we can, too.

All the best,

Narelle Clark

Our tech team had a rude reminder of when to use bi-directional failure detection (BFD), and when not to, that led to a rather full excursion into bug hunting. We all know that BFD is best used when you have a multi-point layer two connection with multiple pieces of active equipment in the path, such as a tunnel or series of devices in bridging mode. The logic being that BFD will detect a failure on the end-to-end path when the individual physical links are mostly – but not all – working and save the effort and time of a routing protocol reconvergence. The issue that arose was that one of our switches was retaining a path in hardware, when the software had marked it as deleted, so the hardware would forward, but the software would not. Turns out, there’s a bug which causes point-to-point OSPF sessions to fail. If you see some early morning VLANs being rearranged, rest assured your packets are being passed while we purge the state tables. It also means we’re removing unnecessary protocols on direct point-to-point links but will retain it where is makes sense such as our intercapital links.

ACCC and NBN long-term pricing reform

The ACCC recently announced they will be convening an industry roundtable to discuss long-term NBN pricing and a revised special access undertaking applying across all NBN access networks. As many IAA members have a vested interest in NBN pricing and access regulation, we will be participating in the roundtable. We plan on encouraging measures which will simplify and make NBN Co pricing more affordable.

Model Defamation Provisions

We recently sent a submission through for the Model Defamation Provisions Stage 2 Discussion Paper. In our submission, we argued that ISPs and hosting providers should be considered basic internet providers who should not be held liable for defamatory content. Instead, they should receive statutory immunity from liability in defamation, especially as they do not actively participate in publication or contribute to risk of harm to reputation. We see taking this step as providing legal certainty for our members and allow them to focus on providing better services instead of on compliance obligations.

Online Safety Bill

IAA has begun working with the eSafety Commissioner and other industry associations to develop industry codes under the Online Safety Bill 2021. The codes will stipulate that industry should foster an online environment which is safe, transparent and limits access to harmful content. At this stage, we are working through the logistics of the code itself with other concerned industry bodies, but we plan on highlighting that ISPs and hosting providers do not play an extensive role in content management, and should therefore not have as many provisions to meet.

Future Submissions

In the coming month, we plan to respond to the NBN Co Pricing Review Consultation Paper 2. In this paper, NBN Co proposes changes to bundle discount charges and CVC inclusions along with a soft cap on overage CVC charges if specific criteria are met. We will also be sending a submission through the ACCC’s Non-Discrimination Provisions for Access Providers. The ACCC asks for feedback on two tests to assess whether an access provider has either implicitly or explicitly treated itself or other access seekers favourably or less favourably than other access seekers.

 

 

This month we’ve seen a few developments in the regulatory space that have us wondering about the future. We expect to see a new Online Safety Act pass in early June and with it will come the obligation to have a number of Codes in place to govern how we as an industry react to online content deemed harmful. This will apply to all types of content, similar to that in the past for content deemed harmful to children. On the upside, it is good that we have received an invitation from the eSafety Commissioner to participate in the Code development, so we will be arguing the case for workable Codes where we can. This also means we should be able to assist members in getting the right processes in place once the regulation comes into place.

We’ve also been contacted by the ACCC to participate in its upcoming industry roundtable discussion on future NBN regulation. Members should let me know what your hot topics are for this one! Rest assured we will be raising CVC charging, barriers to becoming RSPs, visibility of performance and installation issues. Any others you want me to raise, please don’t hesitate to be in touch.

It’s good to see that the round of firmware upgrades have been completed too! Meaning all our core switches are now 100Gbps capable and those pesky software issues are resolved. We still need to upgrade our smaller switches, so those members still on 1Gbps ports will see a round of short outages to bring that software up to date. It’s all for a good cause.

Like many of you also, we have received notice that the old Primus DC at 55 King St Melbourne is closing. We are currently rearranging our fibres in the Melbourne ring to ensure our high standards of redundancy and diversity are maintained, and we will be relocating RS2 to another site. Our plan is to keep our gear operating until pretty much the lights go out there, however, as we know you will need things in service as long as possible. Stay tuned for the specific dates.

Our governance update is also proceeding well, and we published a draft Constitution last week. Members are invited to comment on the proposed Constitution by sending me an email with your thoughts by 3 June 2021. As ever the plan is published on our website.

All the best

Narelle Clark

IAA has been notified of the upcoming closure of Melbourne’s old Primus DC, located at 55 King Street. We have been advised by Vocus that we need to vacate the premises by August 1st. Unfortunately this means members with ports within the datacentre will be affected as IAA will no longer be able to continue offering services from this facility. Members should rest assured that we are working hard to ensure your services are not affected by this closure and ask anyone with a current service at 55 King to migrate to any of the other sites in VIC-IX. All location options can be found on our website. If you need more information or help with your migration, email peering@internet.asn.au

IAA Engineers, Washif and Aaron will be taking a road trip (COVID willing) to Melbourne next month to undertake scheduled upgrades at Melbourne’s NextDC M1. The work is necessary as the current BDX8 has reached the end of its service life and we are replacing it with our brand new X870. The new switch offers better port density and 100Gbps, something the current BDX8 lacks.

This month we welcome Megan Smith to assist us in reviewing our technical documentation. Megan is a fibre engineer with broad experience from her time with NBN Co and Optus and will be an invaluable help in getting our processes and services properly documented. Welcome Megan!

Following a request for greater capacity at our B2 site, IAA Engineer Aaron Chidiac headed up to Queensland this week to upgrade the Brisbane site to support 100Gbps ports.

The upgrade was scheduled for last year however COVID delayed our plans to complete the job.

Back at the start of this year you may remember IAA dropped set up fees for 100Gbps ports at all of our IXes, so if you are looking to increase your capacity through QLD-IX you now have options at both Next DC B1 and B2 sites.

The IAA team from Perth spent a lovely morning inspecting the newest NextDC site in Perth this month. Just a short walk from our CBD office, the flash looking, Tier 4 certified datacentre is a significant building on the Perth skyline.

The tour looked at the main areas of the datacentre including the racks and the breakout spaces located throughout the building, designed to make working there more comfortable. The team also got to hear the expansion plans over the next few years as capacity and space in the current tower fills, as well as the security measures and fallback procedures that are in place to ensure complete fault tolerance and no down time at this facility.

IAA currently does not have a presence in NextDC P2. Please let us know if you would like us to add P2 to our current list of PoPs on the WA-IX.

 

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