IAA Newsletters
Thank you to all Corporate and Affiliate members who have completed our member survey. As a member-run association, your input is vital to ensuring that we provide the network you want and need. As we have seen a good amount of growth across the exchanges, we are wanting to expand our network into Hobart, Darwin and other data centres. We’re also keen to get your input on the content you would like to see on the network, so if you haven’t completed the survey yet, please get to it! The survey closes on Friday 4th March 2022, 5:00pm AEDT.
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One of our staff members caught up with founding member, James Bromberger, to learn more about the history of WA-IX. Here’s what James had to say:
What was the fundamental reason for building WA-IX?
WAIA, the former name for IAA, was founded in 1995 principally to represent the civil liberties of Internet users and organisations that wished to have private communications. With network engineers and stakeholders from the fledgling ISP and Telco sector involved, it became clear there was a need for a non-profit, carrier-neutral peering exchange. Up until this point, the incumbent telco in Australia had been charging volume based carriage fees for inbound and outbound traffic; this was making connectivity expensive for those who received traffic – which possibly was not solicited or requested by them. For example, if someone sent you a large email, you’d be paying to receive it, and the sender may not have optimised the email down to cost less (think of attached images not being scaled to a smaller resolution/file size).
Did you think that WA-IX would be as large as it is today? Why did you think that?
I recall the first organisations being the ISPs, as they were shouldering much of the comms bills from the growing ISP subscriber base, but it was when some of the commercial organisations, particularly in the mining sector, started to connect to the exchange we saw there was a real solid future for wider customer use. CoLo providers extended the peering fabric to multiple facilities, and then more and more end organisations started to swell the throughput. Given a fixed, predictable monthly cost, the service expanded rapidly.
What was the uptake of the exchange like in the first ten years?
Within a few years, nearly all of the smaller ISPs had connected locally in Perth. It seemed to be a right of passage to connect in and then subsequently be consumed by iiNet!
What would you say was WA-IX’s most significant contribution to the Internet in Australia today?
Ensuring that B-party charging was not extended to the Internet bill of consumers was a key element of opening up the Internet to consumers; in a country of the size of Australia, making communications more affordable with less personal cost risk to consumers meant the adoption surged in the community. This drove scale, and further reduced cost, to the point where consumers were being offered unlimited volume download (and upload) plans. Prior to this, traffic quotas were commonplace, and consumers would make decisions if it was worth sending or downloading content. With large content providers and CDNs putting cache nodes within the peering network meant that consumers would start to use large amounts of local traffic without making a conscious decision to do so, further driving the ISP-incurred bandwidth costs down.
With the expansion to multiple peering fabrics across Australia, we saw the fundamental economics of the digital online ecosystem become more commodity, accessible, and thus spurring the digital skills; most people now have email, browse websites, do online banking, and order groceries. If the adoption of online services had continued to be throttled by a single organisation, then society would still be using fax machines, and the ability to comfortably isolate during the pandemic would have been much harder.
There’s still progress to be done in the telecommunications space in Western Australia. For customers in the north of Western Australia, there is very little (i.e. no) peering locally between telcos; that traffic often comes down to Perth, jumps across providers, and then transits back to the North of Western Australia, a round trip time that is at times a performance impact on applications. Having a small community peering in Port Hedland, Carnarvon, Geraldton, Broome and asking the ISPs servicing these areas (typically via NBN these days) to exchange traffic locally could have a cost-saving and performance improvement, but thus far, we don’t see this happening.
[CEO comment – if you agree with James’ view on the utility of regional peering, don’t forget to complete our survey!]
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On Wednesday 9th February, Google (AS15169) went live on VIC-IX with a 10G port! Now, you and your customers can access a wider range of Google content via our network.
We’re keen to add more content providers as it is an important part of building a more efficient, open and reliable Internet. If you have any content providers that you would like to see on our network, let us know at peering@ix.asn.au
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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.