IAA Newsletters
On Friday 11th February, a bug that had been affecting a number of peers across NSW-IX was identified. To resolve this issue, our engineers initiated an emergency outage across the entire IX to resolve the issue permanently, and prior to the outage, conducted an emergency reboot and firmware upgrade on the affected switch.
The firmware upgrade, in addition to resolving this bug (outlined on our status page), will be progressively rolled out to all exchanges to bring them in sync in preparation for our new portal’s automation platform.
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“A user interface is like a joke. If you have to explain it, it’s not that good” – HackerNoon
If you are a Developer/Programmer in Sydney looking to work with a dynamic team with flexible work options, then check out our latest job post! We’re looking for someone who has an excellent technical aptitude, shows a willingness to learn and can work independently.
Working as part of the Development Team in building and maintaining the next generation IAA Member Services Portal, so having a good working knowledge of the telecommunications industry is desirable.
If this sounds like a career opportunity you or someone you know would be interested in, then head over to our careers page to apply. Applications close Friday 14th March 2022.
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Completed Submissions
We’ve had a busy month in February, responding to four consultations, three of which were for the Minister of Home Affairs!
Draft Rules Register of Critical Infrastructure & Mandatory Reporting Scheme | 1 February 2022
These Draft Rules would introduce additional security obligations for select industry members who are deemed as critical infrastructure assets. In our response, we emphasised the need for a measured approach that will reduce the obligatory burdens for businesses on behalf of our members in the domain name system and data processing or storage sectors who could become subject to the new rules.
Exposure Draft Security Legislation Amendment (Critical Infrastructure Protection) Bill | 1 February 2022
This Bill, forming part two of the Security Legislation Amendment (Critical Infrastructure) Act enacted in December 2021 would introduce a Risk Management Program and enhanced security obligations for industry members. We requested that thresholds and definitions be clearly and appropriately regulated to ensure only necessary entities will become subject to the likely burdensome obligations under the new Act.
Electronic Surveillance Framework Discussion Paper | 11 February 2022
In addition to the joint organization letter, we responded to the proposed major overhaul of Australia’s electronic surveillance system, particularly on behalf of our members. In our response, we focused on the potentially adverse impacts, particularly for smaller businesses as well as advocating for the broader public interest in ensuring government powers remain balanced and subject to appropriate oversight.
Telecommunications Service Provider (Customer Identity Authentication) Determination 2022 | ACMA | 15 February 2022
Following our submission to the Customer Identity Authentication Determination last December, ACMA has invited us for further consultation on the revised Draft Determination along with other targeted stakeholders. We responded to their queries regarding existing systems on behalf of our members and requested greater time to be provided to businesses prior to the Determination coming into effect so that members can implement the requisite systems and processes. Furthermore, we opposed the inclusion of the Determination into the revised Telecommunications (Listed Infringement Notice Provisions) Declaration following its sunset in April 2022. We expressed it would be unfair to impose penalties on entities for failure to comply with new systems in the near future whilst systems were still being implemented.
Open Submissions
2022 Broadband Speed Claims Guidance Consultation | ACCC | 25 February 2022
ACCC is seeking to review its Broadband Speed Claims – Industry Guidance 2020 (Guidance). This updated Guidance includes six principles regarding expectations for network operators, RSPs and consumers, and is part of ongoing periodic reviews by the Commission.
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A big thank you to all those members who responded to our survey on where our next IX should go. The survey is still open, and we are still keen to hear from you. We’re seeing good growth across all the exchanges, so it is definitely time to expand the footprint some more. Even if you aren’t likely to join us in Darwin or Hobart, please let us know which additional content or data centres on existing IXes you’d like to see. Our aggregate traffic is creeping closer and closer to daily heights of 800Gbps, so if there’s anything we can get on board that will boost us even further, let me know. VIC-IX participants have already noticed the recent increase in Google availability!
More thanks also go to the members connected to NSW-IX that suffered through the rolling firmware upgrade we put through last weekend. Our technical team are most certainly glad to see the last of that bug (touch wood!) as it was darned inconvenient. It will be progressively rolled out across the rest of the exchanges as need, resourcing and notice allows.
Over the last month, we’ve managed to hit our advocacy targets and coordinated a joint letter to the Minister for Home Affairs on the review of electronic surveillance legislation. With the upcoming election likely to have national security as a major theme, we thought it important to make sure industry took a united stance, so we teamed up with Communications Alliance, AIIA, Internet Australia, IoTAA, Digital Rights Watch and EFA. Other organisations were also approached who couldn’t make the short time frame for the letter, but as in the case of the ACS took an even stronger stance in their own submission. There are a number of issues with the proposal, from definitional problems with the meaning of ‘communications’ to the approaches to granting access to content and metadata. I’m sure we all agree the current regimen is fragmented, out of date and ridiculously complex, with holes the size of the last big pwnage. It’s a topic I’m sure we’ll hear more about over the coming months, so expect more FUD and noise.
We’re also expanding the team some more to make sure we can deliver on the software development we have planned with the Member Portal. Check our careers page if you are looking for a coding job or know someone good to refer. This is a truly great place to work and makes a genuine contribution to the internet!
Speaking of appointments, I have just joined the Advisory Board of the Electrical Engineering School at the University of NSW where I will contribute to the training program for telecommunications engineering and related disciplines. Apparently the number of students in this area has been going backwards (and not just for UNSW) for some time, despite the growth in industry need. It’s a discipline that has given me great joy and genuine career satisfaction, so how do we make it more attractive to students?
Don’t forget to nominate for the Public Policy Advisory Panel, too. It’s a great way to give back to the association and the industry more broadly. Nominations are still open.
Drop me a line if you want to follow up on anything. Or why not drop by our North Sydney office if you’re in the area?
All the best
Narelle
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The ACCC will extend the expiry date of the wholesale ADSL (WADSL) service until 30 June 2024. IAA commented on this consultation in September 2021. We advocated for the WADSL to be extended as it is still used in regional areas where competition remains weak and Telstra operates its copper network without much alternative. The ACCC referenced IAA’s submission in their Final Decision paper.
SBAS Access Determination Inquiry | ACCC
IAA responded to the Superfast broadband access services (SBAS) access determination inquiry Discussion Paper in December. In our submission, we advocated that the Regional Broadband Scheme levy should be absorbed by SBAS providers instead of being passed through to RSPs and users. We also argued that SBAS and FAB providers should disclose key network service quality/reliability metrics to RSPs.
Telecommunications Draft Determination – Consumer Data Rights | The Treasury
After conducting a Telecommunications Sectoral Assessment last year, the Department of Treasury decided to recommend the telco sector be designated for the CDR. In December, we commented on the Draft Designation, wherein we pointed out that the cost of implementing and running the CDR, especially for smaller telecommunications providers, is excessively high in comparison to the benefits. We also flagged the importance of a clear demarcation point of the threshold for telco providers captured by CDR, as this can provide certainty for industry.
Customer Identity Verification Determination (CIV) 2021 | ACMA
ACMA introduced a determination which seeks to impose multi-factor authentication (MFA) requirements on CSPs for all customer interactions at high-risk of fraud. We responded to this determination in December. A code released by Comms Alliance covered similar ground to the Determination, but provides CSPs with much more flexibility on how to meet the requirements. In our submission, we extended our support to measures CSPs can implement that reduce customer fraud, however, argued that for smaller CSPs, some MFA and reporting requirements may be difficult to meet.
Privacy Act Review | Attorney General’s Department
The Attorney General’s Department is conducting a review of the Privacy Act 1988 which seeks to expand the scope and application of the Act and how it is regulated and enforced. As part of its review, the Department released a Discussion Paper looking at the expansion of definitions to include greater types of technical data, consider the appropriateness of exemptions including for small businesses, and the introduction of a direct cause of action and statutory tort. We advocated for the development of an effective and practical privacy regime which balances the legitimate commercial need of businesses to monetize the data they collect whilst also protecting the rights of individuals to maintain privacy and control over their data.
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Draft Rules Register of Critical Infrastructure & Mandatory Reporting Scheme | 1 February 2022
Following the amendment of the Security of Critical Infrastructure Act 2018 (SOCI Act) in December 2021, the Minister is proposing to apply additional security obligations, including requiring certain new assets to provide operational and ownership information to the Register of Critical Infrastructure Assets, and the introduction of mandatory cyber incident reporting. The telecommunications sector will not be deemed subject to these obligations, as opposed to the initial recommendations and proposals. However, the Rules will apply to asset classes including broadcasting, domain name, and data storage or processing.
Exposure Draft Security Legislation Amendment (Critical Infrastructure Protection) Bill | 1 February 2022
The Exposure Draft proposes further amendments to the SOCI Act. This Bill is part two of the Security Legislation Amendment (Critical Infrastructure) Act enacted in December 2021. It will introduce a Risk Management Program and enhanced security obligations. IAA will respond regarding concerns about the expanded powers that would give the Minister the ability to privately declare an asset as of national interest which would increase the requirements and burdens on deemed businesses.
Electronic Surveillance Framework Discussion Paper | 11 February 2022
The Department of Home Affairs is embarking on an overhaul of Australia’s electronic surveillance framework. This review would repeal the various legislation which currently contains powers to create a comprehensive framework. Whilst IAA supports the harmonization of regulations to replace the current complex and inconsistent regime; there are concerns that the new framework will be overreaching and excessive.
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The Attorney General’s office will be concluding its public hearing on the Social Media (Anti-Trolling) Bill 2021. This Bill addresses the High Court decision in Fairfax Media Publications v Voller [2021], which saw Australians who maintain a social media page may be liable for defamatory comments posted on their page by others to provide some protection from defamation liability.
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Members are reminded that our old racks in Global Switch were turned off on Thursday 27th January 2022 at 4:30pm AEDT. If you had any cross connects to MMR3 Rack 4 or MMR2 Rack 48, please don’t forget to remove or relocate them. Let us know if you need any assistance by emailing us at peering@internet.asn.au
