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Melissa McCarthy
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VOL 61, NO 2 (2011)
VOL 61, NO 2 (2011)
Table of Contents
Introduction to this issue: NBN policy gaps and Christopher Newell prize papers
Peter Gerrand
Major policy gaps in Australian telecommunications
Allan Horsley, Peter Gerrand
The policy gaps: NBN infrastructure and regulation
The NBN policy gap
Paul Budde
Telephony and the NBN
Peter Darling
Gaps in Telecommunications public policy: End to end service delivery in the NBN world
Mike Rocke, Kit Wignall
Peering policy gaps with the National Broadband Network
Simon Hackett
Too many cooks- have we got our regulatory structures right?
Ros Eason
Addressing policy gaps in Australian telecommunications
John Stanton
The policy gaps: end user needs
Addressing the telecommunications policy gaps
Rosemary Sinclair
Australia’s missing accessible information and communications technology procurement policy
Wayne Hawkins
Infrastructure gaps must be filled to make e-health a reality
Andrew Pesce
The digital divide: the Australian Government's role in addressing 'ability'
Dave Lee
Introducing multi-user environments into Australia’s virtual classrooms: a value proposition for
Australia’s National Broadband Network
Mandy Salomon
The Telstra-TJA Christopher Newell Prize papers
Using technology to support children with sensory disability in remote areas: the RIDBC
Teleschool Model
Melissa McCarthy
One down, two to go: public policy in service of an available, affordable and accessible
National Broadband Network for people with disability
Robert Morsillo
Enhanced captioning - Speaker identification: text vs. images
Quoc Vu Vy, Deborah Ingrid Fels
Embracing learners with disability: web 2.0, access and insight
Katie Ellis
Broadband, Disability and the Role of Standards
Wayne Hawkins
Telecommunications economics
From futility to utility - recent developments in fixed line access pricing
Warwick Davis
About the authors
About the authors
Our sponsors
2011 sponsors of the Telecommunications Journal of Australia
Peter Gerrand
Managing Editor, TJA
We at TJA are grateful to Allan Horsley for his role as Guest Editor for the major theme of
telecommunications policy gaps in this issue, in helping us to structure and source the
eleven valuable papers we are publishing on this important theme. Allan of course brings to
bear his past experience in helping influence Australian telecommunications policy, as
Managing Director of the Australian Telecommunications Users Group (from 1996 to 2001),
as a Commissioner of the Australian Communications Authority (2001-5), and more recently
as an Honorary Life Member of the industry group Communications Alliance.
The Guest Editorial, which follows, brings out the more recent historical background to this
theme, and summarises many of the important policy gaps identified by our eleven
contributors: all of which focus on the National Broadband Network.
TJA is also grateful to Telstra for sponsoring this year’s Christopher Newell Prize
competition, which encourages authors to contribute original papers on how
telecommunications can be used to assist people with disabilities. The independent Judging
Panel (comprising Professor Gerard Goggin, Dr Mark Bagshaw, Dr Milosh Ivanovich, Alex
Jones and the Managing Editor of TJA, as chair) received five strong papers, with a diverse
range of ideas. All five papers are published in this issue.
The three prize winners will be announced at an Awards Ceremony to be held in Melbourne
on Tuesday 10 May. We are very pleased to announce that Telstra, who acted as sponsor for
the Christopher Newell Prize in both 2010 and 2011, has volunteered to sponsor the Prize
competition again in 2012 – underlining its long-term commitment to assisting people with
Finally, this issue benefits from a timely paper by Warwick Davis, from Frontier Economics,
on telecommunications economic regulation. This paper draws attention to the implications of
the Australian economic regulator, the ACCC, finally stepping away from the use of
hypothetical, and ultimately futile, cost models in setting access prices for Telstra’s fixed line
network. His paper brings out the implications for the new national broadband company NBN
Co, whose broadband access infrastructure will progressively replace Telstra’s copper access
Cite this article as: Gerrand, Peter. 2011. ‘Introduction to this issue: NBN policy gaps and
Christopher Newell prize papers’. Telecommunications Journal of Australia. 61 (2): p. 14.1.
Allan Horsley
Peter Gerrand
This article introduces eleven papers published in TJA's May 2011 issue (Vol 61 No 2) on the
theme of policy gaps in Australian telecommunications. It provides a historical context for
recent telecommunications policy development, and then provides a framework in which the
individual papers' identification of policy gaps can be usefully placed.
The Australian government's sole current review relevant to telecommunications is the
Convergence Review, announced on 21 April 2011, and due to report by March 2012. Its
prime purpose is 'to review the operation of media and communications regulation in
Australia and assess its effectiveness in achieving appropriate policy objectives for the
convergent era'.
This review is timely – it would have been timely even in 1997 – but with its emphasis on
media and communications regulation for convergent digital media, it runs the risk of not
giving much – if any – emphasis to several important policy gaps arising in the
implementation of the National Broadband Network. These concern the design of the
national public network infrastructure, the ongoing provision of traditional services, and the
necessary education of end users.
When we put out feelers in February to a wide range of expert industry commentators and
industry lobby groups, we found an enthusiasm to contribute short articles on a wide range of
perceived policy gaps in Australian telecommunications, and this issue of TJA shows the
results: eleven thoughtful policy papers.
The purpose of this introductory paper is to provide a framework in which the individual
policy recommendations can be best understood in a holistic manner.
SINCE 1981
Development of the Australian telecommunications sector over the past three decades, both
economically and in regulatory aspects, has been based upon a consistent pattern of public
consultation on new policies before proceeding to legislation.
In each of the three major steps, during 1988/89, 1990/91 and 1996/97, the Government
published a 'White Paper' setting out its policy objectives and goals and sought community
input. An 'Exposure Draft' of the implementing legislation was then published, again seeking
public comment. Finally the legislation was presented to the Parliament and passed, largely
with bipartisan political support.
The result was that the community and the industry had a reasonable understanding of what
the intended outcomes were and how they would be achieved.
It was of course not all beer and skittles, especially after the overturn in 1997 of the industryspecific regulator Austel – which over eight years had learned a lot, the hard way, about the
industry and was getting good at exercising its powers of arbitration – in favour of an
economic regulator, the ACCC, which took several years to 'climb the learning curve'
concerning the tricks played by technically sophisticated telecommunications operators.
In that period, many parties sought to exploit gaps in the legislation and regulations to avoid
complying with the intent of the legislation. The ultimate disaster was around the turn of the
century, when twenty plus disputes were sitting with the ACCC at the one time. The
'undertakings' element of the Trade Practices Act extensions, provided in 1997 to enable
parties to develop practical and industry-based solutions, was deliberately not being used, as a
means by some to game the system and delay outcomes that were not to their advantage.
Further, good quality customer service and a high level of end user satisfaction were not
natural outcomes, and as a consequence heavy regulatory impositions were sometimes
This whole process since 1989 was, amongst other things, meant to bring an end to a huge
monopoly by an enormous Government Business Enterprise, and to promote both
infrastructure and service competition, all intended to be in the long term interests of end
Given the historical precedents, and the ongoing desire of the community and the industry to
be consulted on changes in policy, it is surprising the development of the National Broadband
Network was not preceded by any public policy White Paper.
In contrast, the community has had to largely rely on media releases to gain its understanding
of Government objectives for the NBN.
The key elements of the NBN policy are currently:
1. 100 Mbps access for 93% of Australian premises by optical Fibre to the Home
(FTTH) technology, and a minimum of 12 Mbps to the remaining 7% premises, using
fixed radio, terrestrial (4%) and satellite (3%), to be implemented by 2018;
2. A Government Business Enterprise, NBN Co, to build the broadband access network
'tails', to operate as a wholesale carrier only, and to be connected via Points of
Interconnect (POIs) to private sector broadband carriers;
3. NBN Co to be potentially sold off (although this will be resisted by the Australian
Greens) after it completes the national rollout of the NBN;
4. Telstra to be structurally separated into Retail and Wholesale arms, to solve the 20year competition problem of a dominant, integrated wholesale and retail carrier;
5. The competition regulator, the ACCC, to decide the number and location of the POIs;
6. The wholesale pricing of the NBN to be uniform across Australia. (The Minister's
declared aim of uniform retail pricing has been undermined by the ACCC's POI
decision, as we will see below.)
Realistically the Policy Gap considerations fit into four baskets,
infrastructure, involving matters relating to the design, construction and operation of
the transport platform and the competition rules (including access and pricing
principles) that should apply;
service provision and service delivery operational policy;
end user issues, including customer service and take-up, which impact on every
member of the community;
trans-sector policy for the digital economy, to ensure that the NBN delivers benefits
across the entire economy.
Ros Eason points out that there is now confusion as to which body is expected to carry out
technical regulation of the NBN: the ACMA or the Minister's Department – neither of which
have taken an active public role to date – or the ACCC (which is meant to be the economic
regulator of competition law).
By giving the ACCC sole responsibility for the POI decision, the Government has caused the
ACCC, in its December 2010 decision on POIs, to make implicit engineering decisions on the
future design of the NBN, for which the ACCC has arguably no engineering competence. Its
December decision, in increasing the number of POIs from 14 to 121, drastically reduces the
footprint and interconnectedness of the NBN, as well as undermining the NBN's original
pricing policy goal of permitting uniform national retail pricing of basic access.
The numerous city-based Retail Service Providers without national broadband networks of
their own will now need to use third-party wholesale infrastructure backbone carriers (such as
Telstra) to connect them to regional POIs if they wish to provide national coverage. The
wholesale charges set by the third party wholesalers will then undermine the ability of Retail
Service Providers to provide uniform broadband access services across Australia.
Furthermore, as raised by Mike Rocke and Kit Wignall, NBN Co will no longer have any de
facto role as a national transmission network planner for end-to-end Quality of Service (QoS)
performance across multiple carrier networks – a role traditionally discharged by Telstra,
which is vacating that role. There is no public agency or private company that has been
designated by the Government to carry out this important function, vital to ensure that the
national broadband network – on which our entire national economy will soon depend – will
satisfy basic engineering requirements for end-to-end network reliability, redundancy and
Rocke and Wignall raise other serious network or transport layer issues which appear to have
been ignored or at least not communicated to date. Failing to address how relevant
international standards recommendations will be accommodated seems to be a big policy
Paul Budde also makes the point that a Strategic Framework for rollout is needed, which
would no doubt address the performance and QoS issues.
Parts of the David Lee and Wayne Hawkins papers raise the equity of access and service
issues, which need to be addressed in the infrastructure design and the related pricing
principles to ensure all Australians share the benefit.
Ros Eason notes the marginalisation of ACMA at critical times in the development of the
NBN. Rocke and Wignall also share the concern, making the point that there is a great
opportunity for ACMA to lead.
Simon Hackett highlights the need for equality amongst all Retail Service Providers in the
way they are offered NBN services by NBN Co and how they interoperate in a fair and
reasonable way.
Using the examples of local number portability (LNP) and peering, he makes it clear that new
arrangements are needed for these two matters (and we imagine many others), if effective and
fair competition and good service is to result.
There are many contributions in this area.
Peter Darling makes the point that Australia has detailed policy and regulations addressing
telephony services, which have yet to be translated into NBN policy. The most important
issue is what will replace the Standard Telephone Service when virtually all public
telephone calls are carried out using Voice over Internet Protocol (VoIP) technology via the
He lists several examples of standards and regulations which have been put in place to protect
the rights of end users. How many remain relevant in an IP world is a good question: the
Untimed Local Call and distance based charging are hardly a contemporary need, but LNP
and QoS in the form of the Customer Service Guarantee remain an ongoing need.
What principles should apply to the further development of the National Numbering Plan,
which has in the past promoted geographic numbers as a means of understanding call cost?
The concept of the Universal Service Obligation, and the composition of the USO package,
are promoted by David Lee (of the NSW Farmers Federation) and Rosemary Sinclair
(ATUG) as worthy of review.
Not surprisingly John Stanton (Communications Alliance) reasonably advocates that the
opportunity should not be lost to reduce the regulatory burden carried by the supply side,
and to only take forward absolutely essential regulatory arrangements. This is a very sensible
proposition, but he uses a very unfortunate example of wanting to reduce Consumer
Protection controls at a time when consumer satisfaction is at an all time low – as evidenced
by the fact that consumer complaints with the Telecommunications Industry Ombudsman
have recently been at an all time high.
What seems to be forgotten is that the community takes many of these historical benefits for
granted. If they just disappear without consideration and appropriate notice, there will be an
uproar and a political backlash. This is a potential danger zone for the Government and it will
make the backlash during the phase out of analogue mobile phones pale into insignificance if
not properly treated.
The matter of consumer confidence and trust being of crucial importance is made by
Rosemary Sinclair and is a telling point. Without it the whole concept of e-commerce and
innovative applications will fail.
The recent experience of some banking customers highlights the effort that must be put into
ensuring services are safe and secure.
Wayne Hawkins addresses the important issue of equity policy, seeking to ensure people with
disabilities don't miss out on the opportunities offered to the general community.
While the concept of universal design is a catch cry for the disability sector, in reality they
have been badly let down it the past. For example, the loss of portable TTY's, when AMPS
mobiles were replaced with GSM, is still a very sore point. They don't wish to see that sort of
disadvantage repeated.
The papers by Mandy Salomon (on new education applications) and Andrew Pesce (on new
e-health and medical applications) are terrific. They address the real benefits that can be
achieved on the NBN with innovative thinking.
The Government, on behalf of the general community, needs to invest in stimulating the
practical development of a great range of such beneficial high-speed broadband applications.
The active addressing of 'human factors' or 'user design factors' in the development of new
applications is crucial.
Andrew Pesce calls upon governments to 'build the overarching infrastructure that is
necessary to connect patient information across the health care sector', ie to invest sufficiently
to make a secure shared electronic medical record system universally feasible, and one
where the medical records can be personally controlled by their owners.
Mandy Salomon's paper points out that 'well over 100 Australian education institutions' are
now trialling multi-user virtual environments (MUVEs), and argues for the pedagogical
value of MUVEs as virtual classrooms, citing case studies. MUVEs are a learning innovation
that require the fast access speeds and ubiquity of the NBN, and can thus be used to
demonstrate the NBN's value in enhancing Australian education. She notes that while there
are some signs of exploratory interest, the federal government's Digital Education Revolution
is slow to support trials and implementations of MUVE technology.
Paul Budde points out the need for a strategic trans-sector policy framework in order to reap
the maximum social and economic benefits from the NBN. Current policy to a large degree
seems to stop at building the NBN infrastructure.
Several of our authors (e.g. Dave Lee and Rosemary Sinclair) point out the need to promote
community engagement, including 'awareness raising' initiatives as well as tailored training
sessions, to motivate the community to wholeheartedly 'opt in' for the NBN and to then use it
beneficially. Without a high take-up of the NBN across Australia, many community benefits,
including extended government services, will not be delivered most cost-effectively, i.e.
Paul Budde also points out that to achieve the long-sought benefits of the Digital Economy,
we need a coherent national trans-sector policy for the Digital Economy. These benefits
include the cost-effective delivery of remotely delivered health and educational services, the
support of a national electricity grid and other environmental management systems, and the
support of teleworkers in rural areas. It will not be possible or appropriate to leave these
broader policy initiatives to NBN Co, especially as NBN Co has deliberately and quite
reasonably restricted its role to that of a wholesale broadband data stream provider, in order to
maximise market opportunities for the private telecommunications service providers.
The eleven authors in this special issue of TJA have identified many policy gaps concerning
the implementation of the NBN, perhaps because the NBN project has been carried out
quickly without much thought being given to transition from current telecommunications
arrangements. This is rather typical of an incoming management team that seeks to clear the
decks to avoid being constrained too much by past history.
Yet both the telecommunications industry and the community have rich experiences of
telecommunications use and longstanding expectations, and these are deserving of
consideration. If not adequately addressed, the very worthy NBN concept could founder or at
the very least be significantly delayed in providing its expected community benefits.
The policy gaps identified in the Infrastructure area need to be addressed to ensure that the
combination of the NBN and its numerous Retail Service providers have the end-to-end
capability to deliver the outcomes expected.
The policy gaps in the Service Provision area must be addressed if the innovation and
ingenuity latent in this sector is to bloom and not be handicapped by inequitable cost
The policy gaps in the End User segment must be resolved to ensure community members
have the confidence, technical awareness, user skills and trust to take up the innovative
services that will be offered.
And there is a compelling need for trans-sector broadband policy development to ensure
that its estimated cost of $43 billion, including $27 billion of taxpayer funds, really pays off in
terms of boosting all relevant industry sectors and hence the national economy.
Lastly, the government and its relevant department (DBCDE) needs to recognise that the low
profile task of national network planning, so important to the security, reliability and quality
of our national telecommunications, is now carried out by no organisation. This task was
carried out by the incumbent monopoly Telecom Australia prior to 1991, and carried out de
facto from 1991 to 2005 by the largest network infrastructure owner, Telstra, in collaboration
with the technical regulators Austel and ACA. The job always had a low public profile
precisely because it was carried out effectively; its purpose was to ensure that end-to-end user
requirements of technical Quality of Service (including reliability, resilience, safety and
quality of transmission of voice, data and images) would be met across a multi-carrier
environment, using the most relevant technical standards developed internationally.
Given that Telstra will soon be quitting the market for fixed access residential networks, and
handing that function over to the NBN and its thousands of retail service provider customers,
a policy vacuum exists. Some of us thought that NBN Co itself would carry out that essential
function, but the ACCC decision in December 2010 on POIs has changed the NBN network
from a nationally interconnected set of broadband access networks to 140 separated 'island'
networks with little in the way of transit network functions. It thus becomes far less
appropriate for NBN Co to voluntarily take on the national network transmission planning
But some competent and independent engineering organisation needs to be given this national
role. Otherwise we will have created a patchwork of networks whose only duty of care is to
their own customers, within the limits of services carried entirely within their own networks.
The high standards of end-to-end communication expected by the Australian community
since the 1960s will in future be only available to those affording premium services, if this
most important policy gap is not filled.
Cite this article as: Horsley, Allan; Gerrand, Peter. 2011. ‘Major policy gaps in Australian
telecommunications’. Telecommunications Journal of Australia. 61 (2): pp. 15.1 to 15.6.
Paul Budde
While Australia is leading the world with its National Broadband Network project, there still
is a lack of a strategic trans-sector policy framework in order to reap the maximum social and
economic benefits from the NBN.
The extraordinary progress Australia has made in relation to the transformation of its
telecoms industry has received a great deal of attention from the international community.
Under the leadership of Minister Conroy the all-important regulatory and NBN Co legislation
was finally passed in March 2011.
Many countries, including the USA, are following the example of Australia and are looking at
national broadband plans as nation-building policies that would generate significant social
and economic benefits. However without strong political leadership it is impossible to
undertake such fundamental cultural changes.
In Australia, as elsewhere, there remains a long-term policy gap, which involves aligning the
NBN business plan with the national purpose for which we are building this infrastructure.
The lack of such a plan is already apparent in areas such as e-health and smart grids, where
separate infrastructure plans have been developed because of the lack of an overarching transsector-based strategic framework. However, with the NBN legislation now in place the
Minister will introduce new policy initiatives in relation to the digital economy at the end of
There is an increasing call from a few but very vocal people, to stop, review or abandon the
ambitious broadband plans in Australia.
The situation now is as follows: …
Most people agree that Australia has the right vision for its national broadband plans, based
on Fibre to the Home (FttH), the social and economic benefits linked to a trans-sector
approach, and the structural separation of the incumbent. It has been a battle to reach this
point, since initially the incumbents vigorously opposed these plans. But now, three years
later, we are finally getting somewhere. In some ways it is a compromise, but the overall plan
remain largely the same; and it is pretty good.
However new people are now jumping onto the bandwagon – academics, politicians,
engineers and other experts, and they are all claiming that different things need to be done to
make it work (better).
The proposed variations are all different from each other, as most of the individual
alternatives are based on diverse fields of expertise, political views, vested interests, etc.
There is no – or very little – uniformity in these comments.
First of all, let me say that no country in the world – and no single expert in the world – has
the ideal solution. Nor do I believe anyone ever will have. Even when the experts in charge of
these projects are putting their best solution in place, the reality is that in real world
compromises will need to be made in order to make at least some headway. So, while we
might have identified what the best possible solution should be, we will inevitably end up
with a practical compromise.
This creates the following dilemma. As we have discussed before elsewhere, there are many
ways to skin this particular cat and a range of issues play a role: politics, environment,
investments, geography and so on.
Some of the suggestions made for improvement by the experts are good – there is no doubt
about that. But what should we do? Start again and look at all these different new options?
This would, without a doubt, result in significant delays (as in 3-5 years) and the most likely
outcome would be that no agreement would be reached on any of these (excellent) new
options and the whole project would collapse.
Or do we stick to the original plan, even in the knowledge that it is not perfect?
I am in favour of the latter course. I think getting underway within the context of the plans
that have now been developed in Australia – which I think are, in principle, pretty good – is
more important than delaying in the hope of finding a better solution. I believe that projects
like this offer a once-in-a-lifetime opportunity.
If it isn’t pushed through now it will simply collapse. At this point my company BuddeComm
is holding discussions with key parties about building in sufficient flexibility to allow for the
integration of good ideas and different solutions, without derailing the project.
And, in general, this is what is happening. However, the political reality is that flexibility
affords the sceptics and those opposing the project (mostly based on strong political
libertarian convictions) an unlimited opportunity to criticise – they will use any change, any
correction, any discussion to declare that this is evidence that the whole project is flawed.
While the above creates a few short-term problems, a more serious long-term issue is the
policy gap that exists between the infrastructure policies and the trans-sector policies.
Exhibit 1 - Economic effects of trans-sector broadband
(Source: BuddeComm: Australia – National Broadband Network – Trans-sector model)
Research Company
World Bank
10% increase in penetration of broadband services
increases economic growth by 1.3%.
McKinsey & Company
10% increase in broadband household penetration
produces 0.1% to 1.4% rise in GDP growth.
Allen Consulting Group
Broadband will add 0.6% to Australia’s GDP growth per
Research Company
Net present value of benefits of smart technologies on
fibre optic network by 2018 – $35-$80 billion.
The reason we are building the NBN is not simply to provide high-speed access to the Internet. The
aim is also to achieve the social and economic benefits it will deliver to the nation. These benefits fall
largely outside the balance sheets of the telcos and it is therefore essential for the government to
become involved in this infrastructure building process.
Broadband infrastructure will stimulate the digital economy, creative innovation and export
opportunities, as well as e-health, tele-education, smart grids, e-government and digital media.
It will become the foundation for smart buildings and cities – indeed, a smart country.
While a great deal of lip service has been paid to these benefits, comparatively few hard
policies have been put in place that will force important government departments such as
Health, Education, Energy and Climate Change to use the NBN for the delivery, and
improvement, of their services.
There is widespread acknowledgment that many of the serious problems we are facing as a
society cannot be solved via the linear processes that were developed 50 or more years ago.
Innovative government solutions are required to address problems such as an ageing
population, increases in chronic illnesses, climate change and energy shortage – and to
promote an environment of first-class education and international competitiveness in the wake
of the growth of countries such as China and India.
In order to address these issues in new, innovative and far more cost-effective ways a transsector policy is required – one that will involve significant budget reallocation in order to
change the way services are delivered, from the traditional analogue processes to the new
digital processes that will supply these services to people’s homes and businesses via the
Once clear political and budgetary commitments for such policies are in place, a range of
supporting policies will be developed. These new services require universal coverage and that
necessitates an all-inclusive policy, aimed at also actively engaging the 20% of the population
not currently online.
This is not just an infrastructure connectivity issue. It is one of education and information, and
it will require the first-line-of-response people involved in healthcare, community services,
education, etc, to become actively engaged with the wider population to ensure that all
Australians can participate in these new services. Probably the 20% of people who are not
currently online will be the ones who will benefit most from many of the all-inclusive
This is an enormous challenge and requires much more than infrastructure policies.
Exhibit 2 - Key developments in FttH and Trans-sector strategies
(Source: BuddeComm: Global – Fast Broadband and Trans-sector Policies)
E-health, e-education, digital media and sustainability are the key reasons why
developed nations need Next Generation Networks.
Smart communities cannot be built from the current silo structure that
dominates our thinking and require a holistic approach.
In terms of FttH connections, Japan continues to lead the world with around 14
million homes and businesses connected.
In terms of actual FttH penetration, South Korea leads with around 44%.
Improvements in international fibre and other infrastructure in Africa are
leading to a growing number of FttH initiatives. However, mobile broadband
will be driving Trans-sector developments here.
There has been substantial recent investment in next generation infrastructure
in the richer countries of the Middle East. Some projects have been completed
and others are moving forward rapidly.
Russia accounts for over half of all Eastern European FTTx subscriptions.
Reforms in New Zealand will create a number of Local Fibre Companies
(LFCs) which will operate FttH access network infrastructure in specific
geographic areas.
Current developments in social networking indicate the importance of community
engagement. An extensive network across all the states and territories, and indeed across all
cities and other communities, should be developed to engage the broader population. Some
good ad hoc initiatives have been taken by the government, but the process needs to be
formalised and structured, with staff available across the country to work with the local
communities, government organisations and volunteers on how to maximise the benefits that
they can achieve themselves.
There are already examples of broadband leading to a repopulation of regional and rural
areas. Communities, towns and cities can use broadband to promote their skills, businesses
and activities to create opportunities. New businesses can be developed leading to
employment opportunities, often generated by the people themselves.
The negative effect of not having a cost benefit assessment done is not the actual figures that
this would produce but the realisation that sound policies will need to be in place if we want
to reap the other benefits. These benefits do not emerge automatically. It will be necessary for
ivory towers and silos to be broken down if we are to embrace the new digital environment
and a cost benefit analysis would have pointed out that budgets would need to be allocated to
guide and implement that process.
Of course this can be achieved without a cost benefit analysis, but that requires the political
will to take responsibility for developing the essential strategic framework.
The addition of the responsibility for ‘Digital Productivity’ to Minister’s Conroy’s portfolio is
a step in the right direction and the first results of this appear promising. Several targeted
conferences (eg on healthcare and retail) have been organised; the e-health record legislation
has been passed; and a subsequent e-health fund of $467 million has been announced.
However digital productivity needs to be discussed and analysed within an independent, wellstructured strategic policy framework, which needs to be properly funded and resourced so as
to bring the infrastructure rollout in line with what the Americans call the ‘national purpose’.
At the moment the industry enjoys the full support and commitment of the Minister, and he
has been delivering the goods. However we cannot rely on one person to move this
enormously complex project forward on their own. The Minister’s activities and
responsibilities need to be expanded into a full-blown strategic operation.
The best outcome of the ‘Digital Productivity’ policy would be for it to provide a policy
framework that ensures that the vision, ideas and strategies that have been developed over the
last few years are given a secure future. It should also make sure that the NBN is implemented
for the purpose for which it was developed – to provide Australia with a range of social and
economic benefits that will allow its people to better address some of the challenges the
country is facing. And, finally, it should operate as a tool to improve our lifestyle and make us
international leaders in the digital economy, thus delivering major national social and
economic benefits, including export opportunities.
Cite this article as: Budde, Paul. 2011. ‘The NBN policy gap’. Telecommunications Journal of
Australia. 61 (2): pp. 16.1 to 16.5.
Peter Darling
Pondarosa Communications
Most of the discussion about Australia’s National Broadband Network (NBN) has been about
the costs, the benefits and the implementation of “super-fast broadband”. This article looks at
another important use that will be made of the optical fibre to the user provided by the NBN –
the provision of telephony service as a continuation of the current standard telephone service
available across Australia.
The article looks at the extensive range of current policies that will have to be considered and
quite possibly modified with the implementation of the NBN. Work has begun on only a few,
but many more policy areas will have to be resolved to enable a smooth transition to the new
network and identify the ubiquitous services that the NBN will provide.
The National Broadband Network or NBN represents a major change in Australian
communications. For the large majority of Australian users it will result in a change from the
current copper-based fixed network to a new network based on optical fibre, moving from
current networks to next generation networks (NGNs).
There has been considerable discussion about all aspects of the NBN, including (but certainly
not limited to) the following areas.
Political – the NBN represents one of the major differences between the Government
and the Opposition, and indeed has been credited with gaining the support of the
Independent Members to allow the current Government to function.
Economic – with varying views on the merit of the estimated 43 Billion Dollar
expenditure required for the NBN, and the need for a rigorous cost benefit analysis
Technical – the best means of providing 100 Mbit/s or more to the majority of users,
and the relative roles of optical fibre and radio technologies.
Implementation – rolling out a fibre-based network to 93% of users in less than eight
years, together with radio-based networks to serve the other 7%.
What has often seemed to have been forgotten is that we already have in place a national
public switched telephone network that provides voice telephony across Australia, working
with mobile telephony networks that serve the centres of population. The bandwidth required
for telephony seems small by comparison with many of the services talked about for the
NBN, but the requirements for a real-time, two-way service such as telephony are not trivial.
Telephony is a “socially important” service – the majority of telecommunications policy and
regulation to date has been directed to telephony, which historically has been regarded as too
important to leave to the market. This paper looks at telephony and similar services in the
NBN, and the transition from the current environment to the NBN.
Telecom Australia was formed in 1975 to take over the provision of national telephone
service in Australia, previously the responsibility of the Postmaster-General’s Department or
PMG. It was a fully-owned Government Business Enterprise with a monopoly on network
provision. As a fully Government-owned organisation, Telecom Australia was guided by the
Government of the day with limited direct formal Government direction. Telecom’s main task
was to provide Universal Service – a telephone that worked and, ideally, a telephone that
worked all of the time, to be available to all premises. In almost all cases Telecom’s engineers
used the technology of the day – twisted copper pairs to each residence, connected to
analogue local exchanges and trunk (or toll) exchanges.
Telecom Australia was merged with the Government-owned Overseas Telecommunication
Corporation in 1992 to form what we now know as Telstra. Network competition to Telstra
was introduced in two stages, with two additional mobile and one additional fixed operators
from 1991 and full network competition from July 1997.
As technology developed, the core of the network was replaced with digital equipment, but
the Customer Access Network (CAN) remained largely analogue.
The extent of (potential) competition varied for different services:
Trunk services (long-distance national and international) were very competitive,
with preselection prescribed by regulation to encourage customers to use competitors’
transit networks beyond the Telstra local network.
Local (fixed) services were not very competitive, with most carriers using Telstra’s
network to provide retail services based upon Telstra’s (regulated) wholesale rates;
Mobile services were competitive, initially amongst the new mobile network
operators who purchased the right to use the necessary radio spectrum, and later with
virtual mobile network operators who used the wholesale services of another mobile
The (public) Internet was also open to full competition from 1991 (in practice from
1992), with Internet Service Providers (ISPs) using the carriage services of other
providers. As Digital Subscriber Line technology developed, ISPs began to use this
technology, primarily as ADSL, over Telstra copper lines, which they were able to
access at regulated rates. More recently, Internet access has been available as part of
the range of services offered over 3G mobile networks.
In 1997 the Government of the day moved to sell one third of Telstra in conjunction with the
introduction of full network competition, and sold the remainder in two subsequent tranches
in 1999 and 2006.
Telstra remained as a single integrated entity, with ownership of:
The Customer Access Network;
An inter-exchange
The largest mobile network;
A hybrid fibre-coaxial cable pay TV network; and
The largest ISP, among other assets.
including substantial
and local
The Government’s policy resulted in a direct conflict between the duties of the Directors,
responsible to shareholders for the best return on their assets, and the responsibility of
Parliament to the nation as a whole to provide telecommunications services (and to the
political parties that did their best to please voters).
The solution adopted was to give substantial powers to the economic regulator, the Australian
Competition and Consumer Commission (ACCC). The ACCC could “declare” a service, and
require a service provider (generally Telstra) to provide this service to others at regulated
prices. This resulted in considerable gaming by both Telstra and access-seekers, and the
development of (to this non-economist) increasingly esoteric models to determine the
regulated price.
Each tranche of Telstra privatisation was accompanied by legislation to ensure that Telstra
met continuing obligations to society as well as to Telstra shareholders. These obligations
were generally expressed in terms of delivery of the “standard telephone service”, a basic
voice telephony service which enables a telephone user to call any other user of a standard
telephone service, whether or not the users are connected to the same network.
The Government ensured that Telstra has the role of Primary Universal Service Provider,
with a universal service obligation (USO) to ensure that Standard Telephone Services are
reasonably accessible to all people in Australia on an equitable basis, wherever they reside or
carry on business. This means that consumers can generally expect to be able to receive a
voice telephony service on request from Telstra (as the Primary Universal Service Provider)
wherever they work or live.
The provision of a standard telephone service is regulated by a complex set of legislative
arrangements with various features and service standards, such as enabling access to
emergency call services. Telstra has also been required to provide additional services when
supplying a standard telephone service in fulfilment of the Universal Service Obligation. A
list of regulated features and standards for a standard telephone service is set out in Appendix
A (from the Department of Broadband, Communications and the Digital Economy Discussion
Paper “Implementation of Universal Service Policy for the transition to the National
Broadband Network environment”).
As is now well known, the current Australian Government plans a “National Broadband
Network” or NBN, using fibre to the user’s premises for 93% of users, and a mixture of radiobased techniques for the other 7% of users (who will be distributed over by far the largest part
of Australia). This network will provide a “fixed” wholesale broadband transmission service
to user’s premises, and together with mobile networks (3G and 4G) will provide support for
both current and next-generation services.
This NBN will be realised using a new Customer Access Network to be implemented by a
government-owned company, the NBN Co Limited. This company will have responsibility
for providing the optical fibre CAN for 93% of users, and the radio-based access (fixed
wireless and satellite) for the other 7% of users. The NBN Co will provide a wholesale
bitstream service to Retail Service Providers, who will deal direct with users and provide the
other facilities necessary to support the services they offer.
I believe that much of the discussion in the industry and within the NBN Co has been based
on the assumption that the NBN will be the extension of the current public Internet. The NBN
will support the public Internet, and be able to use the Internet protocols (amongst others), but
the view that the NBN is just the Internet sells the NBN short. It should be the basis for the
future network, supporting current services such as telephony and the Internet as well as new
A previous article in the Telecommunications Journal of Australia by this author (Darling
2010) described the techniques the NBN Co will use to provide an optical fibre CAN. The
NBN Co is to provide an Optical Network Termination Unit (NTU) at each user’s
premises, and will provide a Layer 2, bit-stream connection from that point to a Point of
Interconnection (PoI). Each end-user will obtain their services from one or more Retail
Service Providers who will manage the relationship with the end-user, accessing the enduser via the nearest PoI.
NBN Co will have no direct commercial relationship with end-users, but will provide
connectivity from an end-user’s premises to the nearest PoI. To use a railway analogy, the
NBN Co will provide the tracks, but not the trains that run over the tracks, which may be
freight trains, commuting trains or even private trains – end-users will have a relationship
with the train operators and through that relationship will contribute commercially to track
operations and maintenance.
The NBN Co originally suggested there would be two types of PoI. The first would be
provided in each large Fibre Serving Area (FSA) (mainly in cities) and the second (mainly in
rural areas) would cover several Fibre Serving Areas.
The draft Business Case produced by the NBN Co suggested that they had been influenced by
the current Internet industry and the Government’s wish for uniform wholesale pricing. Their
draft Business Case proposed a limited number of PoIs, located at each State capital city. This
was not greeted warmly by existing suppliers of long-distance transmission, as it would
bypass their existing infrastructure and thus potentially reduce competition in this area.
As discussed below, it would also make it difficult to use the NBN for local services such as
telephony (if the current arrangements for untimed local calls continue) and utilities which
may be based on regional rather than State boundaries.
The Government referred the NBN proposal to the ACCC, which developed a new set of
criteria for the location of PoIs, proposing they should be established on a “semi-distributed”
basis where it is technically and operationally feasible to allow interconnection and there are
(or are planned to be) a least two competing long distance providers.
There is now a list of 121 PoIs agreed between the ACCC and the NBN Co This is a little
closer to current telephony interconnection arrangements than the initial NBN Co proposal
but will still make it difficult to provide a local telephony service in all rural areas, as FSAs
and telephony exchange charging areas do not necessarily coincide.
The first presentations by NBN Co said that the Optical Network Termination Unit might
contain one or more Analogue Telephony Adapters, based on using SIP, an extension of the
HTML protocol used in the Web. This represented a departure from the basic concept of
services to be provided by the NBN Co, as the telephony adapters would use an Internet,
Layer 3 protocol, not the Layer 2 that would otherwise be supplied by the NBN Co. The
underlying Layer 2 would be configured to support the high quality, low loss and low latency
connection needed for telephony.
Telephony did not get a high profile in the initial technical discussions, despite its current
social importance. Current technology used in telephone exchanges provides a central battery,
independent of the commercial electricity supply. When the need for battery backup to
replicate the current arrangements was raised in the Communications Alliance Working
Group looking at customer equipment, this was given a low priority by the industry.
The Minister, Senator Conroy, had a different perspective, perhaps based on the importance
of telephone service availability in recent fires and floods when domestic power is (often
deliberately) not available. He indicated that he expects the NBN Co to provide battery backup to all premises in the fibre footprint to ensure a standard telephone will continue to provide
voice services during blackouts, until the Government completes consultation with
stakeholders, including emergency services, on the appropriate way of ensuring access to
battery back-up services for those who need them.
There was general recognition that the NBN is much more likely to be successful if Telstra
agrees to use the NBN Co facilities for both broadband and telephony, and makes the Telstra
cables, ducts, buildings and other facilities available for NBN Co use. If agreement could not
be reached, Telstra could provide strong competition for many NBN services.
Protracted negotiations on the financial consequences of such a deal continued during the first
half of 2010. On 20 June 2010 Telstra announced a “non-binding Financial Heads of
Agreement with NBN Co to participate in the rollout of the National Broadband Network
(NBN)”. The 2010 Federal election, in which the NBN was a significant issue, delayed the
detailed discussions, but the Telstra CEO announced at the company’s Half Yearly meeting
on 10 February 2011 that commercial terms have been agreed. The final deal will have to be
endorsed by the shareholders of both companies as well as (in some form) by the competition
regulator, the ACCC.
Under the agreement, the NBN Co will be able to use Telstra’s existing ducts and pipes under
a 30 year lease arrangement (which would be presumably leave Telstra with responsibility for
their maintenance), making it much easier for NBN Co to implement its Optical Fibre rollout.
The NBN Co would also be able to use other Telstra infrastructure; for example exchange
buildings could be used for the equipment required in each Fibre Serving Area.
Telstra has agreed to migrate both its telephony customers and its broadband customers (on
both its copper and Hybrid Fibre-Coaxial [HFC] networks) to the NBN facilities, and to decommission both the copper network and the cable broadband network.
As the Telstra statement to the ASX said, “the transaction would see Telstra progressively
migrate its voice and broadband traffic from its copper and cable networks to NBN Co’s
network as the latter is rolled out. Telstra will continue to use its cable network to meet its pay
TV contract with FOXTEL.” There would be a payment from the NBN Co to Telstra as each
customer is migrated.
This agreement, if finalised, makes the NBN implementation a transition from the current
Telstra copper CAN to the NBN Co optical fibre CAN. It means that, in future, people will
have to use the NBN optical fibre if they want a fixed telephone service, or rely on mobile
telephone service where available.
It is likely that users will have their current household telephone wiring moved from Telstra’s
copper pair NTU to the Analogue Telephone Adaptor on the NBN Co’s Optical NTU
(ONTU). A telephony service provider with a “softswitch” situated beyond the PoI would be
able to provide service. It would also be possible for a Retail Service Provider to offer
telephony from other customer equipment which it provides beyond the network termination
The extent to which current telephony obligations would apply (as detailed in Annex A), to
either NBN Co or the Retail Service Provider, needs to be resolved.
The Government has agreed to remove Telstra’s current universal service obligations with the
establishment of a new USB Co. It has issued a Discussion Paper “Implementation of
Universal Service Policy for the transition to the National Broadband Network environment”
(DBCDE 2010) that highlights the policy issues to be resolved, particularly in relation to the
telephone service.
The current telephony system uses a national numbering system administered by the technical
regulator, the Australian Communications and Media Authority (ACMA), consistent with the
international system specified by the ITU. The Plan is service based, with unique numbering
ranges for each service.
Numbering for mobile services is based on number blocks allocated to service providers with
the possibility of number portability when a user changes service provider.
Numbering for fixed services (geographic numbering) is much more inefficient. Each service
provider is given a number range for each area in which they operate (or may operate), with
the possibility of number portability when a user changes service provider. Under the current
Numbering Plan there are over 2000 such areas, and the move to the NBN is likely to result in
a significant increase in telephony service providers active in each area.
One of the main reasons for such a complex arrangement has been the policy requirement that
providers of a standard telephone service must provide the option of an untimed local call (see
Appendix A). The concept of a local call is based historically on analogue technology, but
there has been a strong political requirement for it to continue. The Numbering Plan has been
configured, and numbers are allocated, so that it is possible for a service provider to analyse if
a call is “local” or “long distance” from the dialled number.
The Internet uses a very different approach. Connection points on the network are allocated
an IP address (either dynamically or statically). These addresses are allocated on a
(supranational) regional1 basis rather than a national basis, with each IP address coming from
a pool allocated to the chosen Internet Service Provider (or directly to large organisations).
For most applications, this IP address is not accessed directly by an end-user but obtained by
accessing the Domain Name System with a unique URL (Universal Record Locater) that is
then translated into an IP address.
Telephony services on the NBN will probably have both an IP address and a telephone
number, and may also be accessed by a URL.
There are a number of policy issues to be resolved:
The continuing need for many of the current STS requirements, in particular for local
and long-distance service distinctions and untimed local calls;
Changes to the Australian telephony numbering scheme to reflect the NBN
requirements, and the fact that the NBN is likely to accelerate the trend to new
services (such as “near telephony” or Internet telephony/VoIP). The ACMA is
consulting on possible changes at present.
The relationship between IP and telephony numbering and addressing; and
The current systems and facilities that use telephone numbers rather than IP addresses
(for example, emergency services, legal interception and the IPND 2).
In an NGN environment, service could be provided at a number of “layers”. A service
provider could provide:
Transport (at Layers 2 and 3 of the OSI model 3), both for access from a user and in
the core network;
Applications (at higher layers of the OSI model)
These applications could be real-time “communicative services” such as
telephony, two-way video or multi-person gaming; or
Other applications that often do not require real-time, two way communication
such as web browsing and video streaming;
Content, associated with the provision of an application or applications.
The current policy division into Carriage Service Providers and Content Service Providers
does not seem adequate in this environment. There needs to be a further division into new
categories of service provider, splitting Carriage Service Provider into:
Transport Service Provider (TSP): Providing transport of data (a transport service);
Application Service Provider (ASP): Providing applications for an end user (or
multiple end-users). (Some applications could be further classified as
“communicative services”).
(The NBN Co will be a specialised form of Transport Service Provider, providing Layer 2
transport to other (retail) Service Providers, from the end-users premises to the PoI.)
Provision of service to a user requires an underlying Transport Service with an application
running over that service. The same entity may be both TSP and ASP, but it should be
possible for a user to select an ASP separately from the TSP. Alternately, an ASP may
purchase a wholesale transport service from a TSP to offer a complete “carriage service” to a
There should be an end-to-end transport facility able to support the full range of
applications/services for all users. The NBN Co will not provide this, as they will be restricted
to providing Layer 2 services between the edge of a users premises (the ONTU) and the PoI.
There is at present no certainty that one or more retail service providers will be available to
offer this service in areas that are not commercially viable.
This raises the question as to whether the future USO should be based on an underlying
requirement for a Layer 3 service, probably based on the Internet Protocols 4.
Conceptually, from a regulatory perspective, higher-layer communications applications (or
services) in an NGN environment could be divided into two distinct categories:
Communications services of social importance (this category generally encompasses
communications services which meet a defined, minimum standard and which are
available on an ubiquitous (or near-ubiquitous) basis), as an extension of the current
USO concept; and
All other communications services and applications.
There will be a continuing community need for a service (or services) to support social
communication requirements. This provides a policy challenge – not whether an STS (or
similar service) ought to be mandated, but rather how this should be done. I believe the
underlying policy need for an STS will not change, but many policy details have to be agreed.
Policy issues to be resolved include:
Whether the current Standard Telephone Service ought to be expanded to include
other services or purposes; and
Whether the list of regulatory requirements, outlined in Appendix A, which currently
attach to the STS ought to be contracted (or expanded).
In the NGN environment, there are likely to be other services that are similar to the main
telephone service, but have other features. Current VoIP / Internet telephony services provide
a good example of this – they appear to be telephony, but do not have all the features of the
STS. This is the basis of current regulatory work which is trying to accommodate VoIP
within the STS framework.
One policy option may be to specify a new Basic Communication Service (BCS) which is to
be made generally available and would be integral to any universal service obligation.
The features of this “basic communications service” would desirably include:
Ubiquitous coverage;
Ubiquitous availability;
Ubiquitous interoperability;
Satisfactory Quality of Experience5 (QoE);
Emergency calling;
Support for people with disabilities: physical, hearing, sight;
Naming/numbering/addressing which is adapted to an NGN; and
Conformity with international standards.
This BCS may comprise a bundle of services, for example interactive voice (telephony);
Interactive text; and Interactive video, alone or in combination. Whatever is decided, there is
no doubt telephony will be part of the future NBN and most of the community will continue
to depend on it.
This issue of the Telecommunications Journal is looking at policy gaps. We know that current
Policy is to provide develop the NBN (with 93% of users of the NBN served by optical fibre).
We know that, if the agreement between NBN Co, Telstra and the Government is confirmed
(as now seems likely), existing copper will no longer be used for all fixed services, including
Much of the current discussion about the NBN is about the techniques (and economics) of
high speed broadband, particularly in the access network. As this paper has indicated, the
transition from the current, highly regulated telephony-based network to the network of the
future requires the resolution of many policy issues. Some of these (for example the provision
of universal service) are at least being recognised, but are a long way from resolution. Many
others, both during the time of transition to the new network and when the NBN is the major
network, still need to be identified and appropriate policy developed.
The timescale for the NBN means a large number of users must be connected each year – by
June 2012 the NBN Co Business Plan suggests that over 250,000 users will be served by
optical fibre, ramping up to almost 1 million by June 2013. Not all of these users will choose
to use the active services provided over the NBN, but the large majority are at present, and are
likely to remain, telephony customers.
Much work needs to be done in the next few months!
From the Discussion Paper “Implementation of Universal Service Policy for the transition
to the National Broadband Network environment”, DBCDE October 2010
Table 1.1 - Features of a standard telephone service that apply regardless of provider
Must provide option of untimed local calls
(mobile telephone services are exempt from
this requirement)
Part 4 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999
Service connection and repair, and meeting
Part 5 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999 and the Customer
Service Guarantee Standard 2000 (No 2)
Telecommunications Industry Ombudsman
membership scheme
Part 6 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999
Access to emergency call services
Part 8 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999
Operator assisted services (including for
dealing with faults and service difficulties)
Part 2 of Schedule 2 to the
Telecommunications Act 1997
Directory assistance
Part 3 of Schedule 2 to the
Telecommunications Act 1997
Itemised billing
Part 5 of Schedule 2 to the
Telecommunications Act 1997
Call interception capability by law
enforcement agencies
Part 15 of the Telecommunications Act
1997 and the Telecommunications
(Interception) Act 1979
Pre-selection (i.e. ability to select an
alternative carriage service provider for
national and international calls)
Part 17 of the Telecommunications Act
Calling line identification
Part 18 of the Telecommunications Act
Number portability
Part 22 of the Telecommunications Act
1997 and the Telecommunications
Numbering Plan 1997
Table 1.2 - Features specific to a standard telephone service supplied in fulfilment of the USO
Must offer customer equipment (the
requirement to offer standard telephone
service equivalent for people with a
disability is explicit)
Sections 6, 9 and 9E of the
Telecommunications (Consumer Protection
and Service Standards) Act 1999
Must provide option of untimed local calls
(including for mobile telephone services)
Part 4 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999
Access to alternative and interim services
Telstra’s Standard Marketing Plan and the
Customer Service Guarantee Standard 2000
(No 2).
Service connection and repair, and meeting
Standard Marketing Plan timeframes
Telstra’s Standard Marketing Plan and Part
5 of the Telecommunications (Consumer
Protection and Service Standards) Act 1999
and the Customer Service Guarantee
Standard 2000 (No 2).
Table 1.3 - Features that apply only to a standard telephone service provided by Telstra
Retail price regulation
Part 9 of the Telecommunications
(Consumer Protection and Service
Standards) Act 1999
Priority Assistance arrangements for people
with life threatening illnesses
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Network Reliability Framework
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Access to Directory Assistance and
operator services
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Low income support measures
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Differential charging for standard telephone
service with and without handsets
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Internet Assistance Program – speed of
dial-up Internet access via a standard
telephone service provided in fulfilment of
the USO
Carrier Licence Conditions (Telstra
Corporation Limited) Declaration 1997
Darling, Peter. 2010. ‘Building the National Broadband Network’. Telecommunications
Journal of Australia. 60 (3): pp. 42.1 to 42.12.
Department of Broadband, Communications and the Digital Economy 2010, ‘Implementation
of Universal Service Policy for the transition to the National Broadband Network
environment’.[Internet] Australian Government. Available from
For example, IP addresses for Australian ISPs are allocated by the AsiaPacific Network Information Centre (APNIC)
The Integrated Public Number Database or IPND is an industry-wide database
containing all listed and unlisted public telephone numbers and associated
information (including physical address). It is a used as a source of
information for emergency and law enforcement purposes.
The Open Systems Inteconnection Model or OSI Model was developed
starting in 1978 by the International Organization for Standardization [ISO].
The model has seven layers each providing data transmission functionality to
the layer above or below. Each layer contains a set of systems, standards or
protocols that communicate with corresponding entities in higher layers. As
each successive layer depends on the one below, data cannot jump or skip
layers. Currently, the Internet uses the more lax TCP/IP protocols that have
absorbed some of the OSI model. See, for example,
This approach appears to be the long-term basis of the USA National
Broadband Plan, and the recent Notice of Proposed Rule-Making (on their
future USO) by the FCC. See
This would include technical parameters to measure Quality of Service, but
would also includes measures based on the users of the service. (The ITU
defines QoE as the overall acceptability of an application or service, as
perceived subjectively by the end users.)
Cite this article as: Darling, Peter. 2011. ‘Telephony and the NBN’. Telecommunications Journal
of Australia. 61 (2): pp. 17.1 to 17.11.
Mike Rocke
Gibson Quai – AAS
Kit Wignall
Gibson Quai – AAS
The future success of telecommunications service providers will depend critically on
achieving end-to-end performance that meets the reasonable expectations of customers for
services carried over IP-based packet switched, multi-services, multi-carrier networks.
In the Australian context the NBN will be a fundamental part of the IP based next generation
networks. Agreed end-to-end performance standards for IP based networks have been
established by both international and Australian regulatory and standards organisations.
However standards for the allocation of the ‘QoS budget’ between segments provided by
different carriers for the various parameters comprising those performance standards have yet
to be adequately developed. While the importance of such standards is recognised, progress in
this regard is very slow. The need for action by the appropriate authorities both in Australia
and internationally is rapidly becoming critical to enable network suppliers, including but not
limited to NBN Co, to build complying networks in a timely fashion.
The business of successful telecommunications service providers is to deliver
telecommunications services that meet the expectations of their customers. The concept of
quality of service (QoS) is universally accepted as providing an objective framework for
defining and measuring the performance of telecommunications network services and their
various components. From a customer’s perspective, however, what matters most is end-toend QoS for the services he/she uses.
In the pre-Internet world telecommunications networks were initially designed for telephony,
with data and other services relying on a range of techniques to exploit the voice bandwidth to
deliver those services. National network monopolies were the norm, with connections
between national networks to provide for international telephone (and data) calls. The design
of national and international networks followed a strict routing hierarchy. The key
components of end-to-end quality of service in this environment were defined for telephony
in terms of loudness loss (or transmission loss), noise, delay and echo. Maximum end-to-end
‘budgets’ were defined, with components of these budgets allocated to national networks and
the international connection. This allocation was managed through the International
Telecommunication Union processes and frameworks, with international and national
standards clearly spelled out. For Australia those standards are now contained in the
Australian Communications Industry Forum’s (ACIF) Australian Network Performance
Plan: ACIF G502: 1998 (Version 1. 0) Published: February 1998, which contains references
to many other national and international standards documents.
The modern telecommunications environment is considerably more complex in terms of the
range of services catered for, but less hierarchical in nature. A much wider range of
telecommunications services is now available, with the current best practice being for all
services to be carried over a single integrated network platform based on Internet Protocol
(IP) packet switching. National networks are less likely to be run by a single monopoly
provider, and are typically operated by multiple network infrastructure providers and multiple
service providers offering wholesale and/or retail services, and requiring interconnection
between networks to provide end-to-end services to customers. Further, the strict routing
hierarchy of analogue telephony no longer applies, with traffic being routed dynamically
according to the best available path and often according to a prioritisation of service type.
Figure 1 below from ITU-T Recommendation Y-1542 (06/2010) shows an end-to-end
network with three network suppliers and five separate networks. In the future, with the
introduction of the Australian National Broadband Network (NBN), the access networks (or
network segments) will be provided by NBN Co and the transit networks A1 and C1 could be
provided by two different suppliers i.e. there could be four different suppliers of the five
different networks.
Figure 1: End-to-End Multi-Network Supplier Example
Network suppliers will be responsible for establishing and meeting the performance standards
for their own networks. They will also be responsible for the performance standards of the
full range of services carried across their networks. Further, they will be responsible for
delivering the traffic for those services to the interfaces to other networks in a form suitable to
enable them to be carried at an appropriate level of performance across those other networks.
Quality of service management is consequently much more complex. For all services in
digital networks QoS can be characterised by the same set of measurable primary parameters
of delay, packet loss and jitter; however depending on the service type some characteristics
are more important than others. Comparing voice and data services for example, telephone
calls are more sensitive to jitter (or variation in packet delay) than packet loss, whereas data
file transfer is critically sensitive to packet loss.
This new environment presents major challenges in the allocation of the end-to-end budget
across different components of the end-to-end network for each of the key QoS parameters in
a modern, IP-based, packet switched, multi-services, multi-operator network. In this regard
the community is entitled to expect standards that clearly specify the performance required
from each network in a multiple-operator service connection, and which will collectively
meet the end-to-end performance standard required by customers for all services carried.
The International Telecommunication Union (ITU) is the United Nations telecommunications
industry agency. Within the ITU the Telecommunication Standardization Sector (ITU-T) is
responsible for studying technical, operating and tariff questions and issuing
Recommendations on them with a view to standardising telecommunications on a worldwide
basis. Individual countries have national regulatory authorities and voluntary standardisation
bodies responsible for determining their own national standards, and almost universally those
national standards are consistent with ITU-T standards.
In addition to the ITU-T there are a number of other international organisations with
responsibility for related technical standards that apply to telecommunications networks or
components of those networks. These organisations include, but are not necessarily restricted
to, the:
Broadband Forum (BBF)
Metro Ethernet Forum (MEF)
Institute of Electronic and Electrical Engineers (IEEE)
Internet Engineering Task Force (IETF)
3rd Generation Partnership Project (3GPP and 3GPP2)
International Organisation for Standardization (ISO)
Each of these organisations has a key role to play in their areas of interest and expertise, and
provides guidelines, recommendations and specifications as appropriate in those areas. The
ITU-T recognises their roles and where appropriate references their publications, both in
relation to the application of IP-based packet switching techniques in telecommunications
networks and more generally in relation to the telecommunications industry.
Within Australia the two major organisations responsible for voluntary and mandatory
telecommunications standards are the Communications Alliance (CA) and the Australian
Communications and Media Authority (ACMA).
The ITU Telecommunication Standardization Sector (ITU-T) is “responsible for studying
technical Questions and issuing Recommendations on them with a view to standardising
telecommunications on a worldwide basis.”
The ITU-T’s “Series Y: Global Information Infrastructure, Internet Protocol Aspects and Next
Generation Networks” Recommendations provide, among other things, coverage of QoS
parameters and standards relevant to this paper. ITU-T Recommendation Y.1541 (02/2006)
contains recommendations on end-to-end network performance objectives for IP-based
services, while excluding consideration of contributions to full end-to-end performance made
by, for example, “home networks, LANs, application gateways, terminals, hosts and other
customer devices”. With reference to figure below from Y.1542 (which is a simpler version
of a similar figure in Y.1541), the end-to-end performance covered in this paper is between
the two User Network Interfaces (UNI).
Figure 2: Public Network QoS Reference Path – UNI to UNI
Y.1541 recommends clear QoS performance standards under the direct control of public
network infrastructure providers, while stating that “further study is required to determine
how to achieve those performance objectives when multiple network providers are involved”.
The ITU-T has provided further consideration of various approaches to achieving end-to-end
performance objectives involving multiple providers in Recommendation Y-1542 (06/2010).
This document is primarily a discussion paper, outlining the major challenges in achieving the
end-to-end performance objectives recommended in Y.1541. Those challenges “are present
multiple network suppliers are necessary to complete the path;
the number of networks in the path will vary request by request;
distances between users is generally unknown;
the impairment level of any given network segment is highly variable;
it is desirable to estimate the actual performance levels achieved on a path;
the operator must be able to say if the requested performance can be met or not; and
the process must eventually be automated. “
A number of different solutions are examined, with the advantages and disadvantages of each
also evaluated. The document acknowledges that each solution presents further challenges in
the standards development process. It also summarises the various aspects of the
development and agreement that will be required for the new tools and capabilities to
establish recommended standards.
Y.1542 addresses IP networks in general. Its Appendix IV addresses further considerations
applicable for Next Generation Networks (NGN), with particular attention to the carriage of
IP telephony as a fundamental public network service. In this regard Australia’s proposed
National Broadband Network (NBN) will be the access network component of an end-to-end
national (and international) NGN, with the IP telephony service carried over the NBN (and
national NGN) ultimately replacing the current public switched telephone service (PSTS).
In both documents the ITU document indicates that, for similar reasons, with interconnected
NGNs the appropriate method of guaranteeing end-to-end QoS is not clear. It advances two
major approaches, both of which are considered in the body of Y.1542, noting that they are
not mutually exclusive and can be used in combination. At this stage, no clear solution or
recommendation is provided.
The Communications Alliance (CA) produces guidelines, codes and standards for the
Australian telecommunications industry through industry consultation. Those guidelines,
codes and standards are generally developed to be consistent with ITU-T Recommendations,
adapted if and as necessary to meet Australian conditions.
Responsibility for regulation in the telecommunications industry is shared between the
Australian Competition and Consumer Commission (ACCC) and the ACMA. Technical
regulation is one of the responsibilities of the ACMA.
The ACMA may register industry codes and standards that meet certain criteria laid down in
legislation. Compliance with a code is generally voluntary, although the ACMA has the
authority to direct individual industry participants to comply with a code. Compliance with a
registered standard is mandatory.
As a general rule the ACMA’s preferred approach is to rely on industry self-regulation
through the registration of codes developed by relevant industry bodies and associations, with
the CA being foremost in this regard. Only if it is clear that this approach is not working
satisfactorily will it consider an industry standard; however in the absence of a relevant code
it must be directed by the Minister or the ACCC to establish a standard. At the time of
writing the only standard registered by the ACMA is in relation to the Do Not Call Register.
The only documents published by the Communications Alliance addressing QoS parameters
for IP networks and services are guidelines. The two guidelines relevant to this discussion are
G632:2007: Quality of Service parameters for networks using the Internet Protocol and
G634:2007: Quality of Service parameters for Voice over Internet Protocol (VoIP) services.
Neither is registered as either an industry code or industry standard by the ACMA.
The QoS parameters and end-to-end standards in G632 are fully consistent with those in ITUT.1541. G632 also includes consideration of the methods for allocating QoS budgets between
network segments. In the absence of a preferred approach promulgated by ITU-T it states that
it is inappropriate for G632 to be prescriptive about how the budgets might be allocated. It
further states that there “is also insufficient experience at present to support a
recommendation of particular values for the performance targets to be met by individual
networks.” However it does describe a methodology for budget allocation across multiple
networks based on one of the two major approaches canvassed in ITU-T Recommendation
An example of the application of that methodology is also provided for a
hypothetical network path over two provider networks connected by a single interconnection
G634 canvasses the allocation of end-to-end QoS budgets for voice calls using IP networks in
more detail, and considers the involvement of up to three carrier networks. It is similarly nonprescriptive in allocating specific budget allowances to each network, while also providing a
methodology for doing so.
In the documentation referred to in this paper, both the ITU-T and the CA indicate that further
work is required to provide a comprehensive framework for the allocation of end-to-end
network QoS standards between different IP-based packet switched networks involving
multiple network providers.
ITU-T Study Group 12 has coverage of Recommendations Y.1541 and Y.1542 (among
others). Study Group 12’s Work Programme for 2009-12, as shown on the ITU-T website,
indicates that Question 11/12 – Transmission planning, interworking and traffic management
for networks supporting voice, data and multimedia services and Question 17/12 Performance of packet-based networks and other networking technologies list, among a wide
range of issues for attention, the achievement of end-to-end QoS objectives where more than
one packet-based network participates in provision of telecommunications services. Review
of Recommendation Y.1541 under Question 17/12 is listed as under study commencing in
October 2011, with review of Recommendation Y.1542 under study in 2012. No further
details on the status or activity on these studies are listed on the website, with further
enquiries indicating that there appears to be no other significant activity in this regard.
The “Future Work” sections of both G632 and G634 refer to work proceeding in international
forums on achievement of performance objectives when multiple network operators are
involved. In this regard they specifically refer to work on “dynamic” QoS negotiation on a
session-by-session basis (one of the major approaches canvassed in ITU-T Recommendation
Y.1542). The CA Works Programme 2011 does not list either G632 or G634 for review, and
this status was confirmed by further enquiries.
In this regard it should be noted that the CA guidelines do closely follow the relevant ITU-T
Recommendations. With ITU-T activity on those recommendations listed for activity in late
2011 and in 2012 it is arguable that at least a prima facie case exists for the CA to wait until
the outcomes (or likely outcomes) of the ITU-T are known before determining what future
activities it might undertake.
End-to-end delivery of services incorporating use of the NBN will be IP based and will
involve multiple networks and multiple service providers in most, if not all, cases. At the
wholesale service level it will involve, at a minimum, an access network at each end of the
network connection and a backhaul network link. In a typical end-to-end network connection
NBN Co will provide at least one of those access network segments, the backhaul link
provided by a separate backhaul network infrastructure provider and the other access network
provided by either NBN Co or another infrastructure provider. Other more complex multinetwork configurations are also likely to occur.
As things currently stand, for packet-based multi-service networks QoS performance
standards for each segment are determined by individual network infrastructure providers.
While CA Guideline G632 provides a methodology for (and simple example of) how end-toend QoS performance standards might be allocated statically to individual networks in a
multiple network environment, that approach requires agreement between those providers but
without a clear and consistent framework for doing so. G634 similarly canvasses up to three
different networks for provision of IP voice services.
At this stage the ACMA does not appear to be taking an active role to lead and facilitate
industry-wide agreement on the issue of end-to-end QoS allocation. NBN Co is consulting
widely with the industry on a wide range of issues, including the issue of end-to-end QoS
objectives of retail service providers (RSP). In a response to submissions received to a
consultation paper it issued in December 2009, NBN Co noted that different RSPs had “a
different number and definition of QoS levels through to their end users”. In response, NBN
Co proposed to “provide RSPs with maximum flexibility in the operation of their end-to-end
QoS capability”.
In December 2010 NBN Co released an updated version of its NBN Co Fibre Access Service
Product Technical Specification Version 2.0, which dealt with a number of QoS-related
issues. However the specification is silent on QoS performance standards, either for its
proposed wholesale product offerings or on an end-to-end network basis.
Key concerns arising from these circumstances are that:
In the move of existing telecommunications services (such as telephony) to an
Australian NGN (of which NBN Co’s network will be a fundamental part) there is a
risk that the current consistency of high quality end-to-end service quality of (fixed)
telephony services may be unacceptably reduced. As a consequence there is
significant potential for the quality of telephone calls to vary significantly and to fall
outside the current high standard enjoyed by customers. Conversely, a deliberate
design tolerance to different levels of QoS would be a positive response to the need
for flexible and competitive pricing.
The offering of new services that have a high dependency on QoS (such as widely
available desk top video conferencing) may not be commercially successful due to the
risk that the consistency of end to end service quality of these services is not well
managed, and therefore does not meet reasonable customer expectations. Again,
conversely, a variation to this would be an intended variable quality to suit different
levels of price and acceptability in the market place.
These concerns are particularly an issue in Australia with the move to the NBN. The NBN
will be the access network for great majority of fixed services, including existing services
such as telephony, and is intended to be a modern best practice digital IP based access system.
NBN Co, the industry and the regulators need to decide on the allocation of QoS component
to NBN Co access network so that appropriate amounts are remaining for other network
suppliers/service providers for end-to-end national and international services. It also
represents a major opportunity for Australia to take an active role in influencing the ITU
approach to allocation of end-to-end QoS. Flexibility and adequacy for the user application
and actual market needs should guide QoS allocations. Unilateral allocation of QoS for endto-end connection segments by individual carriers and service is not a recipe for success.
For Australian network suppliers the allocation of performance budgets would provide a
sound basis for back-to-back Service Level Agreements between network suppliers, in turn
providing greater certainty for the design, construction and operation of their respective
In our view achieving appropriate end-to-end performance for all services that are connected
via the NBN is essential to the success of the NBN. Failure to act swiftly on performance
standards for individual networks delivering multiple services across a multi-network service
connection carries a high risk of poor service delivery to customers and subsequent customer
discontent. Loss of confidence in the NBN is likely to significantly impact on community
support for it.
The process of determining national and international standards for the telecommunications
industry is a long one. In an environment where the NBN Co will shortly commence a
commercial rollout a stable, agreed process for allocation of end-to-end QoS performance
standards across multiple networks (including international networks) is rapidly becoming
critical. Otherwise reasonable customer expectations will not be met for services that will
become IP based and at least in part be carried on the NBN.
The issue is much wider than what NBN Co can address on its own. While Australia’s NBN
will be an important component of an end-to-end service, it will be only one component. This
is thus a national issue, which is also reflected in global networks.
The ITU-T Recommendations and CA Guidelines (among others) provide a sound framework
of end-to-end QoS standards. What is required (and is currently lacking) is a framework for
allocation of the end-to-end QoS budget, both within Australia and internationally, that takes
due account of the needs and expectations of NBN Co and other network infrastructure and
network service providers, and most importantly of end customers.
In this latter regard, particularly given the planned transition of many existing services to the
NBN, a sound case also exists for data collection and reporting of customer perception of
service quality for at least fixed and mobile services (both voice and data) that are susceptible
to QoS issues. It is acknowledged that this is a complex matter with a number of challenges.
For example, it is difficult for customers to recognise QoS related performance issues in a
structured way. Generally the service quality has to be very poor and occur often before
customers are frustrated enough to report this as a concern. By that stage the overall technical
status of end-to-end services may be very poor and possibly be very difficult to redeem.
Given the complexities of an IP-based multi-services environment involving multiple network
providers a systematic process of information collection, sampling and measurement may be
The good work done to date by the CA and the ITU-T provides a solid foundation for future
activity. A framework for that future activity should address, at a minimum, the:
Mechanisms (voluntary codes or mandatory standards); and
Key issues.
The current processes for establishing national and international standards, codes, guidelines,
recommendations etc. are well established and have proven to be successful in obtaining
widespread agreement and compliance. Those processes are, however, time-consuming and
require extensive contribution of resources from the telecommunications community.
As indicated earlier, there is currently a low level of activity in both international and
Australian forums in determining the allocation of network performance standards across
multiple networks in a multi-service IP-packet based environment. There is a consequent
high risk of unsatisfactory performance for end-to-end services using those networks. Given
the rollout timetable of the NBN and the planned transfer of Telstra services to the NBN a
strong, if not compelling, case exists for Australia to establish the required standards in
advance of international standards from the ITU-T.
In this regard, well-established processes for establishing national standards already exist
through the ACMA and recognised national bodies such as the CA. However the ACMA
currently uses a “light touch” approach, preferring to largely rely on the CA to manage those
processes under ACMA supervision. Given the current low level of activity, the risks to
achieving satisfactory end-to-end performance and the complex processes involved, the time
has come for the ACMA to use its authority to initiate and actively manage those processes to
ensure a timely outcome on these critical standards. If the ACMA requires additional powers
and resources to do so they should be made available as a matter of priority.
The major key mechanisms in use under Australian legislation are registered voluntary codes
and mandatory standards.
A key advantage of registered codes is that they are developed with extensive industry
consultation and therefore are likely to have a high level of ownership of, and compliance by,
industry participants. A disadvantage is the exposure to network suppliers who take voluntary
to be discretionary and only comply where it suits. While the ACMA has the authority to
direct a participant to comply, the delay can be lengthy, and any remediation of the network
also potentially lengthy. The impact could be an extended period of poor performance for
network connections involving such a supplier.
On the other hand mandatory standards provide much greater authority to the ACMA in
managing compliance in a timely way (assuming appropriate means of enforcing compliance
accompany that authority). A further advantage is that, if established in a timely fashion,
network suppliers are better positioned to design and build complying networks. A
disadvantage is the potential for less ownership of the standards by suppliers.
Given the critical importance of realising end-to-end performance standards across multiple
IP networks, combined with a more active role by the ACMA the mandatory standards
approach is likely to achieve a satisfactory outcome within a shorter timeframe than would
otherwise occur. This in turn would provide network suppliers with a greater opportunity to
build complying networks in a timely fashion.
Principles for allocations and budgeting of performance should consider the different service
types and solutions for these types, taking into account at least the following:
A requirement for equitable allocation at each end for the access component;
Notwithstanding the above, an asymmetric and dynamically flexible accommodation
of satellite, wireless (e.g. WiMax), and mobile (e.g. LTE) access methods may be
necessary, and an appropriate budget and QoS assumption and degradation tolerable
for this type of access;
For the remaining networks, the number of network suppliers for any one connection
is variable;
Traffic can be routed dynamically according to the best available path and often
according to a prioritisation of service type;
An agreed allocation for carriage between access points (e.g. PoIs); and
A budget allowance for terminal devices (e.g. video devices) and access
configurations (e.g. LANs).
The focus of this paper to this point has been on the performance of an IP-based packet NGN
involving multiple carriers once an end-to-end service connection has been established.
Arguably of equal importance is the capacity to establish and maintain that end-to-end
connection for the time it is required. This performance characteristic is variously known as
network reliability, availability and/or resilience. Causes of failure can be due to faults within
one or more of the supplier networks or through an external denial-of-service (DoS) attack.
While not discussed further here, the issues and status of performance standards for
establishing and maintaining that end-to-end connection for IP-based packet NGNs involving
multiple supplier networks is similar. That is, there is a lack of any clear framework for
determining how end-to-end network reliability is established and managed across multiple
supplier networks. There also appears to be a similar lack of action among international and
national standards forums to address this fundamental issue.
The performance of both way interactive real time services such as telephony and videoconferencing (to name just two) is fundamental to the successful operation of
telecommunications networks and the support of the social and economic functioning of
nations. Meeting the end-to-end QoS and network reliability standards is essential in meeting
customer expectations of the performance of all telecommunications services. Failure to do
so carries a high risk of poor quality services, high levels of customer dissatisfaction and, in
the case of Australia impact on community support for NBN.
The ACMA and the CA have an inherited national responsibility to lead a process for
allocation of end to end QoS, along with allocation of network reliability responsibilities, in
NGN connections involving multiple supplier networks, both within Australia and
internationally that takes due account of the needs and expectations of NBN Co and other
network infrastructure and network service providers and, most importantly, of end
Given the long lead times typically involved in establishing national and international
standards the timing is of this activity becoming critical. It is imperative that the industry,
industry regulators and the Federal Government recognise the importance of having a sound
basis for network suppliers to design, build and operate networks that will be used as part of
end-to-end network connections delivering multiple services to customers. If necessary this
should be done in anticipation of the work of the ITU-T. The responsible organisations
(most notably the ACMA) need both the resources and the full authority to effectively initiate
and execute these tasks.
Australian Communications Industry Forum. 1998. G502: (Version 1.0): Australian Network
Performance Plan
Communications Alliance Ltd. 2007a. G634:2007: Quality of Service parameters for Voice
over Internet Protocol (VoIP) services
Communications Alliance Ltd. 2007b. G632. Quality of Service parameters for networks
using the Internet Protocol
Communications Alliance Works Program. 2011, Updated 19 January 2011. Accessed 10
February 2011. Available from
ITU-T. 2006. Recommendation Y.1541 Network performance objectives for IP-based
ITU-T. 2009. Work Programme 2009-2012. Accessed 19 February 2011. Available from
ITU-T. 2010 Recommendation Y.1542 Framework for achieving end-to-end IP performance
NBN Co Limited. 2009. ‘NBN Co consultation paper: proposed wholesale fibre bitstream
products’ December 2009
NBN Co Limited. 2010a. NBN Co Fibre Access Service Product Technical Specification
Version 2.0 December 2010
NBN Co Limited. 2010b. ‘NBN Co response to industry submissions — proposed wholesale
fibre bitstream products’ March 2010
Cite this article as: Rocke, Mike; Wignall, Kit. 2011. ‘Gaps in telecommunications public policy:
end to end service delivery in the NBN world’. Telecommunications Journal of Australia. 61 (2):
pp. 18.1 to 18.10.
Simon Hackett
Deploying a ‘superfast’ national tail circuit network (i.e. the National Broadband Network)
will highlight other bottlenecks in information flow that currently exist between voice and
data service providers in Australia, unless those bottlenecks are also addressed. This paper
highlights the need for appropriately symmetrical peering arrangements to be enforced, for
both voice and data services, between all NBN Service Provider networks.
The National Broadband Network (NBN) represents a huge intervention in the
telecommunications realm in Australia. It is intended to replace the dominance of Telstra with
a new 'good' monopoly that should be limited to operating in the wholesale realm alone.
While such a tail circuit network will address a critical part of the future communications
needs of Australians, there are other bottlenecks that exist between consumers and the
information sources they wish to access. Raising the tail circuit speed may simply highlight
those other bottlenecks to information flow unless they are also addressed.
I will note two specific bottleneck points that seem to have escaped consideration thus far,
and explain why some attention to these details within NBN policy would be of benefit to
A consistent issue in Australian telecommunications has been around the notion of 'peering'.
In the telecommunications context, this refers to a scenario where two or more industry
members support the smooth and efficient passage of information between their respective
networks without adding artificial cost constraints; in other words, without one party
imposing an asymmetric cost upon the other party in order for information to be exchanged
between those parties.
The generally accepted charging model for such interactions is ‘sender keeps all’ (SKA)
peering – in other words, each party to such a peering connection pays its own costs to the
point of interconnect and retains all income related to the flow of information across the
link(s) concerned.
There are two key 'peering gaps' in Australia today, with one related to voice and the other
related to Internet data.
In the voice realm, Telstra (as the dominant fixed line voice carrier) has long imposed
onerous, outdated, and expensive constraints (both technical and financial) upon other carriers
wishing to achieve financially and technically efficient bilateral 'local number portability'
(LNP) and the bilateral exchange of phone calls with the Telstra voice network.
The importance of this ‘voice peering’ in the context of the NBN is that the NBN will
physically remove the existing distance based costs related to originating and terminating
voice calls, and will replace that with the carriage of all calls to NBN customers via Voice
over IP. Whether the customer end is implemented through the ATA (analog voice) port on
the customers optical termination unit, or the call is delivered via the customers Ethernet port
to VoIP equipment in their home, the marginal cost to deliver the call from the NBN Point of
Interconnect to the customer falls to zero in this environment.
As such, it is logical to expect the replacement of the existing CCS7, distance based, circuit
switched PSTN mechanisms (call origination, call termination, and local number portability)
with the simple peering of each service provider voice network using Voice over IP.
This makes the use of SKA peering an obvious and appropriate mechanism in the voice realm
for NBN based providers.
To date, industry requests to engage in this form of VoIP based, SKA voice peering and to
implement LNP over the same framework with Telstra (as the dominant voice platform
provider today) have been rejected, and it is therefore clear that some form of policy
requirement for such voice interaction is necessary when the NBN is deployed.
In the data realm, Telstra and others have historically formed the 'Gang of Four', a subset of
Internet Service Providers who have refused to offer SKA IP network peering on a neutral
basis and instead have imposed asymmetric costs on the connection and exchange of IP data
between Telstra and parties not within the 'gang'.
In particular, while other IP backbone providers in Australia peer extensively (via both
bilateral and multilateral peering points around the county), the members of the “Gang of
Four” (and most critically, Telstra and Optus) require other providers to purchase connectivity
to and from their networks at commercial (transit) IP carriage rates.
These connections are expensive, and as such they are frequently not provisioned with
sufficient ‘burst’ capacity to accommodate transient high demand for data flow. By contrast,
SKA based peering links are generally provisioned with high capacity (and proactively
upgraded) as there is no reason to do otherwise.
These peering links encourage efficient transfer of data between IP backbones, and ensure
there is no artificial bottleneck created in the flow of Internet data between a customer on one
network within the Gang of Four and a server attached to another network not inside the Gang
of Four (or vice versa).
It is important to note that for some time now, the paid transit links between the Internode
national IP backbone and the Telstra and Optus networks is such that we deliver more data to
those backbones than we import. In effect we are paying to deliver data to those networks that
is then on-sold to its customers.
Historically, the ACCC recognised this problem in 1998 and took enforcement action to
require peering between IP networks. However, the determination made at the time was
fatally flawed. The ACCC decided (incorrectly) at the time that the (then) dominant four
players had to peer – but no requirement was placed upon those four to peer with anyone else,
ever. All subsequent requests and attempts to peer with Telstra and Optus since then have
been rejected by those network providers.
In 2011, only two of those players (Telstra and Optus) remain in a market dominant position,
and both steadfastly refuse to engage in sender-keeps-all neutral IP network peering, despite
the entire rest of the industry having engaged in extensive bilateral and multilateral peering
arrangements for many years. This situation leads to higher costs and reduced network
efficiency for consumers.
In the ultra high speed NBN environment it will become vital that both issues are resolved
and that peering of voice and data occurs efficiently between all providers offering customer
services across the National Broadband Network.
At 100 megabit customer port rates, a lack of sufficient peering capacity (and a lack of
economically rational paths through which to expand that capacity in accordance with
technical requirements) will rapidly impede commerce and consumer utility for high
bandwidth applications.
Similar issues will exist with respect to fixed line voice services unless action is taken to
ensure that voice networks are peered and that efficient number portability is made available
to consumers ‘on demand’ across the NBN.
Indeed the mobile number portability regime in Australia only exists today due to such an
intervention to force it to happen. A similar intervention is clearly necessary in the NBN voice
services realm. It will not happen by itself.
Having indicated the existence of these problems, the question becomes one of how to ensure
that efficient neutral peering in both voice and data do occur between all retail service
providers that operate on the NBN. Where could a policy be defined and made to operate, in
order to achieve this outcome?
A number of points exist at which such a policy could be defined and required of NBN
service providers. These include:
Amendments to the laws applicable to the NBN to require technically efficient SKA
peering of voice, voice local number portability and SKA peering of data service
networks between NBN service providers.
Appropriate contractual requirements within the NBN Co wholesale access contract
that all NBN service providers must sign
ACCC intervention, potentially via requirements for the approval of the forthcoming
NBN Co Special Access Undertaking (SAU) for the network
A requirement for peering being included within the Telstra/NBNCo ‘side deal’ under
which Telstra will be paid to shut down the copper network as the NBN fibre network
is commissioned
However it is achieved, it is clear that technically and financially neutral peering of NBN
service provider networks (voice and data, including local number portability) are essential
parts of ensuring that the NBN delivers the full benefits to Australians that we all expect of it.
Cite this article as: Hackett, Simon. 2011. ‘Peering policy gaps with the National Broadband
Network’. Telecommunications Journal of Australia. 61 (2): pp. 19.1 to 19.3.
Ros Eason
Communications, Electrical and Plumbing Union (CEPU)
The liberalisation of Australian telecommunications in 1997 was accompanied by changes
which saw responsibility for competition policy, and especially access issues, transferred from
the industry specific regulator to the ACCC. Ros Eason considers how well the current
dispersal of regulatory responsibilities and energies has served the industry and asks whether
it is time for a re-think of our institutional arrangements.
The decision by the Australian Competition and Consumer Commission (ACCC) last year to
recommend rejection of the National Broadband Network Company’s preferred network
design was a critical moment in telecommunications policy making in this country. Not only
did it throw the hugely expensive and time-sensitive NBN project significantly off-schedule
but it also highlighted the peculiarity of Australia’s current regulatory arrangements.
Where else in the world does the competition regulator – one which self-confessedly has
minimal internal expertise in matters of telecommunications network engineering –
effectively determine the topology of complex and critical national communications
How is it that, given its unparalleled role in this area, the ACCC’s views were not signalled to
NBN Co at an earlier point in the design process? What coordination, if any, on this question
was there between the competition regulator, the company charged with delivering the
government’s programme and the Department responsible for oversighting the project and
advising the Minister?
And where, in the formal process, was the technical regulator, ACMA, whose views on the
practical ramifications of the proposed network architecture for the delivery of multiple
services, some more latency-sensitive than others, may have been worth hearing?
No doubt the ACCC decision reflected not only problems of coordination between the
different bodies responsible for our national telecommunications policy but also ambiguities
at the heart of the NBN project itself. Uncertainties as to the scope of the NBN “mission”themselves related to the requirements that the network further both competition and social
policy goals while generating sufficient returns to keep its costs off budget –have bedevilled
the project from its inception.
The highly centralised network model proposed by NBN Co, which allowed for only 14
Points of Interconnection (POIs), would have maximised the company’s revenues (especially
in the absence of volume discounts) while lowering unit costs, thus best positioning it to fund
the substantial internal cross subsidies which the government’s uniform pricing policy
implied. (No alternative funding mechanism was proposed by government.)
At the same time, however, it would have stranded a large portion of existing fibre assets and
effectively foreclosed all but inter-capital city markets to new competitive entry by fixed
network operators. Such a scenario was acceptable neither to major industry players nor to the
ACCC, given its understanding of its pro-competitive charter.
The final model endorsed by the Commission now provides for 121 points of interconnection
(POIs), but it is not clear how long this number will withstand the conflicting claims of
industry participants and the demands of policy. Indeed, at the time of writing, proposed
government amendments to the Telecommunications Legislation Amendment (National
Broadband Network Measures- Access Arrangements) Bill 2011 would appear to allow the
winding back of this number if such arrangements proved incompatible with NBN Co’s
uniform pricing mandate.
At the same time, to put the matter beyond doubt – and to hobble the economically orthodox –
the amendments specifically authorise cross-subsidisation as a means of achieving such
pricing outcomes, effectively prioritising this goal over the provision of multiple access
The amendments thus deal head-on with one of the key areas of conflict – access
arrangements and their relation to social policy – that has so vitiated telecommunications
policy in Australia in recent years. Unfortunately, however, they do not essentially disturb
the division of regulatory labour which has institutionalised these conflicts since 1997.
At the time of the introduction of the Telecommunications Act 1997, support for the transfer
of some regulatory functions from the then AUSTEL to the ACCC was largely based on the
expectation that the move would lead to a more industry-neutral and hence less intrusive
approach to telecommunications competition regulation. These hopes proved profoundly
Far from being confined within the general provisions of the then Trade Practices Act 1974,
the ACCC was armed with two new telecommunications-specific sections which were used to
justify and implement an increasingly assertive pro-competitive approach to access and access
pricing issues. Such interventionism thrived in the policy vacuum created by the Coalition
Government’s single-minded pursuit of Telstra privatisation as its overarching policy goal.
Increasingly, however, it produced outcomes which were at odds with other “legacy”
elements of policy, notably uniform retail tariffing and the related issue of universal service
Regulatory anomalies flourished: averaged retail line rental prices and de-averaged access
seeker charges; divergence between pricing methodologies used by the ACCC for access
pricing and ACMA for USO calculations; conflicting and apparently arbitrary pricing
approaches to access services which might reasonably be regarded as substitutes.
In recent times any attempt at policy coherence appears to have been abandoned in favour of
an unabashed pragmatism. How else can the ACCC’s most recent ULLS decision, which in
anticipation of the NBN – but contrary to the Commission’s historic cost-based stance –
introduces averaged access price for Bands 1-3 (but not 4!), be understood?
Such policy zig-zags have undermined confidence in the Commission amongst some of its
most ardent supporters even as it has sought to extend its regulatory reach into questions of
industry structure and, most recently, network design.
Meanwhile, ACMA, where technical expertise relevant to much of the ACCC’s activity
resides (e.g. for the sub-loop unbundling inquiry, determination of non-price terms and
conditions for declared services) has been largely marginalised from the central regulatory
and policy debates. Its function as assessor of USO costs was dealt a death blow by
Communications Minister Alston in 1999 with the pre-emptive capping of the 1997-98 USO
at the politically acceptable level of $253 million. (The then ACA’s subsequent estimate was
$548 million, while Telstra put the figure at $1.8 billion.) Since that time the authority’s
telecommunications functions, at least in relation to wireline services, have been confined
largely to the endorsement and monitoring of technical standards, themselves developed by
industry under the auspices of the Communications Alliance.
It is not clear what role, if any, it will play in the implementation of the new USO
arrangements, including the reassessment of costs, that the NBN project will require. What is
clear, however, is that when government needed an assessment of the scale of Telstra’s
current funding obligations for the purposes of the Heads of Agreement with NBN Co, neither
ACMA nor the Department of Broadband Communications and the Digital Economy
(DBCDE) was evidently deemed to have the internal expertise necessary for the task. The
work was contracted out to McKinsey. Here is another straw in the wind that is blowing
through Australia’s increasingly bleak telecommunications policy landscape.
It is time for a thoroughgoing assessment of our public policy making capacities and related
institutional arrangements. The fragmentation of responsibilities introduced by the
Telecommunications Act 1997 has acted against the development of coherent and technically
informed solutions to the challenges that such a dynamic industry poses.
It has instead encouraged political fixes (the 1999 USO decision is an egregious example)
which diminish the authority of our institutions without providing long-term policy answers.
And it has involved a dispersal of policy expertise – and a related thinning of institutional
memory – which a country as small as Australia can ill afford, especially as we move into the
unchartered territory the NBN project represents.
Cite this article as: Eason, Ros. 2011. ‘Too many cooks – have we got our regulatory structures
right?’. Telecommunications Journal of Australia. 61 (2): pp. 20.1 to 20.3.
John Stanton
Communications Alliance
This article examines the issue of policy gaps in the Australian telecommunications
framework from the prospective and reflective viewpoints.
Looking forward, the article examines the pressing need for an Australian ‘master plan’ for
the development of the Digital Economy and related industry sectors. It also argues for a more
comprehensive approach to ensuring that Australian consumers are equipped to make a
smooth transition to fibre-based telecommunications services and to make informed decisions
that will optimise their communications experience in an NBN world.
The article stresses that it is equally important for Government and regulators to review and
possibly remove the raft of existing provisions that were designed and implemented for an
earlier telecommunications era. It argues that many of these instruments presently serve little
purpose other than to impose costs and obligations on industry players which outweigh any
attendant benefit and reduce the industry’s competitiveness and flexibility.
When addressing policy gaps in the Australian telecommunications landscape it’s practically
impossible to provide a comprehensive view. Given the pace of change and game-changing
events such as the rollout of the National Broadband Network (NBN), there are bound to be
many gaps that industry has not yet recognised, and many more that no-one has yet identified.
For the purposes of this article, I have adopted a somewhat liberal definition of “policy gaps”.
The first series of “gaps” I attempt to describe are provisions that exist in the
telecommunications legislative and regulatory framework today, but which I contend should
be considered for phase-out or termination. So the “gap” is perhaps a weakness in the
regulatory review process which has allowed out-dated elements to survive.
There is little doubt that it is easier to legislate and regulate than to deregulate. I concede that
Gillard Government Ministers will argue, with some justification, that legislating in a
minority Government is no cakewalk, but the general point stands up to scrutiny.
Bureaucrats in DBCDE and related Departments have borne a heavy load over the past 18
months, drafting a host of Bills needed to create the basis for the NBN, along with numerous
other pieces of telecommunications legislation.
The legislative focus has been squarely on the NBN, and particularly on the critical
interconnect and access issues that underpin competitive activity and commercial possibility.
It is not surprising, then, that relatively little attention has apparently been paid to the fact that
the statute books contain a raft of legacy and residual regulation – much of which was framed
to address an environment in which Telecom or Telstra was the dominant and vertically
integrated incumbent.
With the advent of the NBN as a universal non-discriminatory access provider, the
environment changes fundamentally, and much of the existing regulation becomes less
relevant, less effective or anachronistic.
The Federal Government should – with industry’s help – take on the hard, parallel task of
seeking a “clean slate” approach by removing as much of the out-dated regulation as possible
and building up new provisions based on cost/benefit and emerging requirements.
In particular, we need a forward-looking approach to consumer protection regulation. Many
well-intentioned existing instruments are either barely effective in the current environment
and/or impose substantial costs on industry that tend to outweigh the benefits.
The Government’s 2011 Convergence Review is unlikely to achieve a great deal on this front,
as its terms of reference appear to focus away from telco regulation and toward content and
convergence issues.
Following are just a few examples of existing regulation that is approaching its use-by date, or
might already have slid beyond that point.
Many customer service plans today treat local telephone calls as a piece of ‘included value’ in
a product bundle. Many plans include local calls as a ’free’ component. Increasing use of
Voice over IP (VoIP) services dispenses with the concept of a local call altogether. These
trends – combined with ongoing fixed-to-mobile substitution – will continue until, soon,
telephony is just another application on the information super highway – and a relatively lowvalue application at that. It is reasonable to ask, then – why do we continue to enshrine and
impose on industry the cost and complexity of maintaining an untimed local call billing and
charging structure that is derived from Telstra’s network structure and design of the 1960s?
The peculiar maintenance of untimed local calls in Australia has its roots in the federal byelection in the seat of Adelaide in February 1988. The Hawke Government lost the seat to the
Liberal Party via an adverse swing of more than 8%. Public anger against the plans of the then
Telecom Australia to introduce timed local calls appeared to play a decisive part in the
election result. A political taboo emerged overnight around the timed local calls issue.
In early 1988, Telecom had undertaken a wide-ranging public consultation process in an
attempt to convince the populace that the move made sense (which it probably did). The then
Minister for Transport and Communications, Senator Gareth Evans, summed up the situation
in the wake of the by-election when he told the Senate: “I readily acknowledge that that was
not one of the more successful community consultation processes of all time, unless one
adopts as one's measuring stick the achievement of an early decisive result.“
So decisive a result, in fact, that 23 years later, untimed local calls are still a mandatory
feature of the Australian telecommunications landscape – long after technologies, products,
customer usage and preferences have all moved on.
The Customer Service Guarantee Standard was created in the year 2000, but already looks
like an anachronistic instrument. It applies only to standard telephone services (in an era
where mobile services outsell fixed services by a ratio of 2 to 1 and Internet/data services are
driving overall growth). The Standard has been based around Telstra’s historical network
topography and connection capabilities, yet it also applies to all Carriage Service Providers.
How does the CSG play in an NBN world, where infrastructure delivery times are primarily
the responsibility of NBN Co? The risk is that there will be a temptation to further expand the
CSG, when the sensible course would be to phase it out.
The Australian regulatory regime continues to be based around regulating a “standard
telephone service”. In many instances it assumes a one-to-one relationship between
infrastructure and service delivery. This is a thing of the past. A new nexus needs to be
Pre-selection dates back to the introduction of fixed-service competition in the early 1990’s. It
allows customers with a standard telephone service to choose a different service provider to
supply their national long-distance calls, international calls and calls to mobile numbers. It
was designed to overcome the bottleneck control of Telstra over local access and to give a
‘leg-up’ to new entrants.
In future, NBN Co will be responsible for providing network access on a non-discriminatory
basis, thus removing at a stroke the main rationale for pre-selection. Furthermore, consumers
connected to the NBN will have the luxury of multiple ethernet ports on their network
termination unit (NTU) in-home to connect to numerous service providers if they so choose.
In these circumstances it seems pointless and inefficient to mandate continued pre-selection
A regulatory spring-clean is well overdue in the area of mandated customer information.
Carriers and CSPs carry obligations to inform customers of many things that may have been
important 15 years ago, but which should by now have faded away.
Quite apart from regular items such as the Standard Form of Agreement, premium services
information and information about special assistance complaint handling customer service
guarantees, emergency services etc, there are additional and separate information
requirements arising from at least five pieces of legislation, five regulatory determinations
and fifteen industry Codes.
This load is soon to be increased by new information requirements in the Communications
Alliance Telecommunications Consumer Protections (TCP) Code (the present revision of the
Code is expected to be complete by mid-2011). Finally, the migration of customers onto
NBN-based services will bring with it a raft of extra customer information tasks for the
A related potential policy gap is the lack of a national approach to disseminating the relevant
information to customers. In an increasingly on-line world, the tendency is to say ‘it is on our
web site’, but policy makers – and service providers – need to address accessibility issues in a
more structured and considered manner, which should in turn generate improved discipline
about what information is actually required.
There are other elements of the telecommunications framework that are worthy in principle
and made sense in the past, but which are rapidly being overtaken by advances in technology
and changes in usage patterns. The National Relay Service (NRS), for example, is an
expensive network, supported by levies on industry, which enshrines the old technology of
teletype. IP-based communications technologies for customers with special needs will soon
overtake the usefulness of the NRS. The question is, how quickly will Australia respond to
this and make the shift to a better tool?
Another example is the National Numbering Plan, which should be a flexible technical
document focused on network addressing and call routing. Industry manages small pieces of
the Plan, e.g. the INMS and associated freephone and local rate numbers, and this
arrangement seems to work well. The rest of the Plan is administered by the ACMA and the
process for change is lengthy, complex and relatively inflexible.
Minister Conroy has foreshadowed his intention to address one of the more obvious policy
gaps relevant to the telecommunications industry. This is the creation of a national Digital
Economy Strategy.
Details are scarce to date, but if it is to be effective, the strategy should bear at least some of
the characteristics of the information technology ‘master plans’ that have been used so
effectively in countries such as Singapore and the Republic of Korea to coordinate policy
settings across all arms of government and drive national initiatives to bring the benefits of
high-speed connectivity and applications to business and consumers alike.
Australia’s strategy must be calibrated to foster an environment in which applications
development can thrive and e-government services can become pervasive and deliver
productivities and efficiencies to help make our nation globally competitive.
One element that Australia needs badly is a national initiative to accelerate the digitisation of
Australian content. Korea began a concerted campaign back in 1987 – yes, 1987! – to digitise
all Government documents. Rapid achievement of this task laid the foundation for the Korean
e-government revolution, which is a key contributor to that nation’s economic rise over the
past decade. More than 80% of Korean tax returns are completed online and more than 1500
Government services are available via digital platforms.
The Executive Chairman of Open Text Corporation, Tom Jenkins, visited Australia in March
2011 and recounted how the lack of digitised Canadian content had generated unintended
consequences after Canada had upgraded its national broadband capability. The advent of
‘fast pipes’ for consumers meant that the youth of Canada were flooded by digitised
American content, with the result that Jenkins believed that young Canadians had effectively
ceased to exist – they were now young Americans.
Jenkins warned that the NBN rollout could have similar effects in Australia unless we move
quickly to digitise more of our local content. At present, he claimed, only about 3% of
Australian content had been digitised.
I had first-hand exposure to the problem recently, when peripherally involved in a Federal
Government initiative to create a personal identification platform for a particular service,
widely used in Australia, around which there are some valid security and law enforcement
concerns (confidentiality requirements prevent me describing it more precisely). The use of
Passports for identification purposes was a logical option, but could not be used because
Australia has not yet completed the digitisation of passport data.
Communications Alliance has been active since early 2010 on the issues surrounding the need
to ensure that consumers get access to the information they will need to make sensible and
informed decisions when the time comes to migrate their services to the NBN.
Consumers will be confronted with a myriad of new possibilities and questions around such
issues as:
the merits of competing service plans;
whether existing customer-premises equipment will still work or needs to be modified
or replaced;
whether to use existing wiring, wireless devices or new cabling to distribute services
whether existing services can all be replicated exactly on a fibre-based platform;
how to deal with multiple ethernet ports and multiple service providers; and
how to manage faults.
Once migrated, consumers – including businesses – will face new challenges to optimise their
telecommunications experience in a fibre-based world, including which of the vast array of
IP-based applications they should use and how to manage their video services as triple-play
options become prevalent and intelligent IPTV offers totally new video opportunities.
The consequences of widespread consumer confusion and/or poor initial decision-making by
consumers can be readily imagined. This could generate a public-relations ‘perfect storm’,
prove damaging to the health of the industry, and impede the delivery to consumers of the
many benefits that fibre-based services and applications can offer.
The Government has mandated that NBN Co undertake a wide-ranging Public Information
Campaign, including on service issues that lie beyond the NBN Co network boundary.
Communications Alliance has established an industry Working Group to assist NBN Co in
this task.
It is doubtful whether these arrangements will be sufficient for the task. The Government
allocated funds in the region of $60 million to publicise and provide consumer information
around the television Digital Switchover campaign – in which consumers need to make
comparatively simple decisions about how to be ready for the switch from analogue to digital
The lack to date of a similar commitment to ensuring Australians have the information they
need to take full advantage of the nation’s significant investment in the NBN stands out as a
potentially dangerous policy gap.
Today’s telecommunications legislators face the unenviable task of trying to make a
traditional and unwieldy law-making and regulatory process keep pace with accelerating
advances in technology, product development and consumer usage patterns.
Policy gaps will inevitably occur, either through a combination of procedural time-lags and
unforeseen events, or because regulation is made too prescriptive to cope with changing
To a degree we must accept this as a symptom of rapid progress – provided there is an
ongoing commitment to repair those gaps that do appear.
Equally, however, we must ensure that the out-dated elements of regulation - the provisions
that once made sense but have now become less useful and/or simply act to impose
unnecessary obligations and costs – are cleaned away to promote efficiency and the ability to
meet new challenges.
Cite this article as: Stanton, John. 2011. ‘Addressing Policy Gaps in Australian
Telecommunications’. Telecommunications Journal of Australia. 61 (2): pp. 21.1 to 21.5.
Rosemary Sinclair
Australian Telecommunications Users Group
With the implementation of the National Broadband Network, Australians within a few years
will be provided with arguably the best broadband infrastructure in the world. The challenge
is to ensure that the end users reap the benefits of that infrastructure in the context of a broadly
based digital economy. Several important questions are posed that require further policy
elaboration, in order to meet the long-term best interests of end users.
The Australian Telecommunications Users Group (ATUG) is pleased to contribute to TJA's
issue on 'Addressing Policy Gaps'. In 2011, ATUG celebrates 30 years of working to improve
communications services and prices on behalf of end users who rely on communications to
efficiently deliver their services, to effectively connect with customers and to innovate for
growth and productivity.
The recent communications sector policy debate in Australia has been focused on
fundamental reform of a framework that has not delivered on its 1997 promise of open and
effective competition in the fixed local access market.
A change of Government in 2007 led to renewed focus on telco sector outcomes and
broadband was the case in point – slow speeds, high prices, under served regional markets,
switching processes that discouraged customer choice, a patchy platform that did not support
In April 2009 the Government outlined a comprehensive and complex framework for the
communications sector. It stated it would:
Commence an implementation study to determine the operating arrangements,
detailed network design, ways to attract private sector investment
Fast-track negotiations with the Tasmanian Government, to build on its NBN
proposal to begin rollout of FTTP network and next generation wireless.
Address 'black spots' through the timely rollout of fibre optic transmission links
connecting cities, major regional centres and rural towns.
Progress legislative changes that will govern the national broadband network
Facilitate the rollout of fibre networks, including requiring greenfields developments
to use FTTP technology.
Make an initial investment in the network of $4.7 billion. (In the December 2010
Statement of Expectations, the Government committed to an equity agreement with
NBN Co based on $27.5 billion funding requirement, to be reviewed annually.)
Commence a consultative process on necessary changes to the existing
telecommunications regulatory regime.
Much of this policy agenda is well underway and yet there are gaps – many of which emerge
more clearly during implementation.
For instance, at the time of writing, the NBN Companies Bill and (ATUG's shorthand) the
NBN Access Bill have both passed the House of Representatives and are currently in Senate
Committee with hearings scheduled in early March. The governance structure and
accountability framework for the NBN Co will be properly in place only with the passage of
these Bills through the Senate. ATUG was pleased to see the 'long-term interests of end users'
remain as the key objective for NBN Company and for this to be reinforced by NBN
Company's access arrangements being part of the Competition and Consumer Act (Trade
Practices Act) access provisions.
An important issue which was until recently a 'gap' was the difference in view between NBN
Co and others including ATUG on the number of Points of Interconnection. This problem was
solved using time-tested processes of public consultation and discussion, with the outcomes
being a larger number of Points of Interconnection, which preserved competition in backhaul
markets. The decision leaves further questions for end users in regard to delivering on the
Prime Minister's undertaking about a Uniform National Wholesale Price so that 'regional
areas can pay the same price as people in the city'. For industry there are still questions on the
criteria that will only be agreed between the ACCC and NBN Co after NBN Co lodges its
Special Access Undertaking. And Telstra has advised that some of the identified POIs are not
yet suitable for use and would require additional investment and extensive work to refit or
expand so they would be suitable. The same issue may arise for other parts of Telstra
infrastructure that will be part of the $9billion access arrangement between NBN Co and
In general, the objective of preserving infrastructure competition where possible in an NBN
policy world raises a series of questions about the new emerging wholesale markets – both
NBN Co markets and backhaul markets. The legislation preserves an opportunity for others to
build local access fibre provided it meets NBN technical and access standards. Questions will
which arise which will need policy responses if commercial market outcomes are not
For ATUG this is an area of 'wait and see' as the outcome depends on service providers at
Layer 3 developing an effective wholesale market while they still have retail market interests.
What visibility is needed for this market? How can users be sure prices are competitive? Who
will respond if barriers to entry emerge such as balance sheet strength, customer numbers or
technical parameters? Again ATUG is pleased that a risk mitigation strategy is part and parcel
of the legislation – if the market doesn't develop, the Minister and/or the ACCC can respond.
Assuming these new markets develop effectively there are a series of practical questions end
users have about quality of service, end to end performance quality through network assets
owned by a number of companies, fault handling processes and billing processes. All of
which require significant intra-industry work to achieve what end users enjoy now – any to
any connectivity and end-to-end service performance. In this context, the first and second
release sites are not just 'construction trials' for the NBN Co; they are competition and
consumer trial sites for the NBN Policy Framework.
The NBN policy promise is not only about speed it is also about much improved competition
– multiple services from multiple service providers over the NBN Co local access link with a
consistent customer experience from one end of the NBN to the other end. In this new world,
the focus for end users will be on practical outcomes – How much will services cost? When
will they be available? How much disruption will there be? Who do I call if something goes
wrong? But these outcomes will depend on good policy responses to emerging issues.
Part of the risk mitigation is the Joint House NBN Committee, which has been agreed to. This
will provide a six-monthly review by both Houses of progress with the NBN, including
importantly network rollout performance including service levels and faults and NBN Co's
strategy for engaging with consumers and handling complaints. The wide-ranging terms of
reference for this Committee provide an important protection for end users and an important
protection against unforeseen policy gaps.
Universal Service Obligation is a very significant policy area where there are still many
questions. A new model has been proposed as part of the Telstra/NBN/Government
arrangement needed to support the cost effective deployment of the NBN (with consequent
benefits for end users in terms of prices). The new model leads to a new organisation, USO
Co, and new processes where Telstra becomes a sub-contractor to USO Co with NBN taking
responsibility for infrastructure in fibre-served areas but being required to maintain copper
services in non-fibre served areas. The objectives of the updated USO arrangements are to
ensure that a basic voice service remains available across Australia, to provide clarity and
certainty to consumers and industry, and to ensure consumer safeguard regulations are
effective. A series of Ministerial Determinations will be needed to give effect to these
objectives and until these are clear, an important policy gap remains.
So far in the policy development the focus has been on residential market outcomes – perhaps
because revenue volumes are here, perhaps because of a belief that businesses will benefit
from competitive infrastructure. Business grade offerings from NBN Co will be important in
driving residential take-up because it will be business applications (including entertainment)
and government services that will drive take-up of consumer connections. Encouraging new
'business-focused' entrants to the communications market will be an important KPI for the
government's NBN Policy. These new entrants need to be supported with pro-competition
implementation plans because they will drive innovation outcomes for the NBN.
Beyond the NBN build and connect phase issues, ATUG sees policy work emerging in the
transition to a Digital Economy – the benefits side of the NBN project.
ATUG has been discussing the shift to a Digital Economy and a number of questions have
emerged in these discussions:
Innovation and Applications – How can we encourage the new businesses? How
can we support the transformation of existing business and government service
delivery models? How can we encourage and support new ways of working such as
teleworking? How can we use Cloud Computing services?
Integrity and Assurance – How do deal with community concerns about privacy?
How do we improve digital confidence? How do we empower consumers with esecurity strategies? How do we improve community skills to encourage wide
participation in the Digital Economy?
There are a series of seemingly independent initiatives that need to be brought together in a
comprehensive Strategy for Australia's Transition to a Digital Economy. COAG is the vehicle
to coordinate Federal and State Government efforts. Industry should be an equal partner given
the commitment to investment, training and change that is going to be needed.
Ubiquitous, affordable, high-speed broadband connectivity will enable much higher
levels of participation and interactive engagement – much more user-generated
Innovation needs more than speed. Open Source working and a Creative Commons
approach will be innovation drivers in a Digital Economy. What is the role for
Copyright? What do Digital Economy Business Models look like? How will price
structures change? Might applications charges include access charges?
Business innovations will depend on Digital Confidence as much as Digital
Connectivity – telecommuting; manufacturing on demand; shopping online with
telepresence; business intelligence services; financial services 'Gone Green'; Software
as a Service – the role of Cloud Services. Business software providers will embed
collaboration tools to add 'Social Networking' community power to business
Visual Services are seen to be a key use of the new networks. Whether it is visual
interaction in the delivery of Education or Health services over distance, video
conferencing services as an alternative to long distance travel, or television services,
(free to air or subscription) the opportunity offered for High Definition visual services
is substantial. The implication is Symmetric Service Capability.
There may be many 'new' Service Providers. The concept of a 'government port' on
the termination unit had strong support in ATUG's discussions as many people
considered that the delivery of government services via the new broadband networks
has the potential for better service to the community and reduced costs of delivery.
Such a concept may require the establishment of a 'Government ISP' to bring together
the online services of government in a coordinated and user-friendly style.
End User Trust and Confidence in the Digital Economy and in the services delivered
over the new broadband networks is a key 'Success Factor'. Community concern
about the perceived absence of adequate security of online payment arrangements has
slowed the take up of electronic commerce
Service Availability and Service Integrity are critical for all users in a fully Digital
Business needs education on better methods of verification/authentication.
'Bandwidth is not enough in dealing with security issues.' Governance tools are just as
important as technology tools. What is 'Best Practice' for online transactions in a
Digital Economy?
Developing skills to enable small and medium businesses and consumers to
effectively participate in the e-commerce world is just as important as the
development of professional and practitioner skills through University, TAFE and
private provider courses.
Consumers need education on 'best practice' for information online – being confident
about how personal information will be accessed and used, and how it will be
protected. The EU's eYouGuide to consumer rights in a Digital Economy substitutes
concrete rights for 'best endeavours' but there are no absolute cures, only control
measures to reduce risk and increase confidence.
Digital Media Literacy is important to ensure the benefits of a Digital Economy are
available to all; to give end users the confidence, knowledge and understanding
needed to participate in digital media and communications environments.
The introduction of an open access, wholesale only NBN is a key underpinning of the
move to a Digital Economy. It is essential that 100% of premises have access to NBN
standard services as quickly as possible.
Regulatory structures need to be reviewed in light of the move to a Digital Economy.
This work has started in the Telco Sector with the emergence of the NBN but it needs
to go further by looking at Consumer Policies in an NBN based Digital Economy and
the issues flowing from the service innovation and convergence enabled by a Digital
Economy. The 2011-2012 Convergence Review is an important step.
Issues are different in different sectors - Australia's Retail Sector has no tradition of
catalogue shopping and so has not developed the logistics systems needed to support
retail distribution in a Digital Economy. In the Health Sector a key issue is who owns
the Health Record? How best to secure and store the record? How to protect personal
Australia's National Broadband Network policy is an important policy framework that
delivers an upgrade of the copper network on a national basis to fibre to 93% of Australian
premises. NBN Co is charged with building the network by 2021 and operating it on an openaccess, wholesale only basis with uniform national wholesale prices and an architecture which
promotes competition. The next decade will see the implementation of a policy designed to
deliver much better outcomes for end users.
This phase will need continued attention by policy makers, end users and NBN Co to
outcomes that are in practice in the 'long-term interests of end users.' This paper contains
several recommendations to enable Australia to make a satisfactory transition to a Digital
Economy that meets the needs of end users.
Cite this article as: Sinclair, Rosemary. 2011. ‘Addressing the telecommunications policy gaps’.
Telecommunications Journal of Australia. 61 (2): pp. 22.1 to 22.5.
Wayne Hawkins
Australian Communications Consumer Action Network (ACCAN)
Where is the Australian Government’s procurement policy for accessible information and
communications technology? This paper investigates the current Australian Government
procurement policy, the policies being introduced to dismantle barriers that Australians living
with disability encounter and the international procurement policy environment for accessible
information and communications technology (ICT). The paper argues that in order for
Australians with disability to be able to have more access to employment, public services and
a greater market of accessible ICT products and services Australia will need to adopt a
comprehensive whole-of-government procurement policy for accessible ICT.
In recent years Australia has introduced a range of progressive public policies to address the
participation barriers faced by its citizens who live with disability. The Government has
become a signatory to the United Nations Convention on the Rights of Persons with
Disabilities, implemented a raft of reviews, inquiries and public consultations on how best to
dismantle the barriers that Australian citizens with disability encounter every day in all areas
of economic, social and cultural participation. However, despite this progress in disability
public policy and a growing awareness and discourse on how societal barriers create
disability, the question remains: where is the Australian Government’s public procurement
commitment to accessible information and communications technology?
This paper highlights the need for an accessible information and communications (ICT)
Australian Government public procurement policy by investigating the current Australian
model of access and inclusion in public policy as it relates to the ICT environment; the policy
changes that have been implemented in this sector to disassemble some of the barriers that
people living with disability encounter in accessing our growing digital economy; and through
comparisons with the international accessibility public policy landscape.
Public procurement is the process that governments follow when purchasing goods and
services from the private sector. In Australia all levels of government – Federal, State and
Territory as well as local – have procurement policies in place to monitor and prescribe the
way in which goods and services are purchased. The Commonwealth, for example, has
adopted the Commonwealth Procurement Policy Framework to guide departments and
agencies in the acquisition of goods and services. The Framework ensures that the following
principles are encompassed as part of any government procurement: “value for money;
efficient, effective and ethical use of resources; and accountability” (AGIMO 2009).
Public procurement policies are not unique to the area of ICT and are used widely by national,
state and local governments to promote and protect a raft of initiatives.
As Cynthia Waddell asserts, these initiatives include such policy goals as:
to stimulate national economic activity;
to protect against foreign competition;
to improve competition in certain economic sectors;
to drive innovation in a particular area of technology;
to remedy regional disparities; and
to achieve specific social policy goals. (Waddell 2009, McCrudden 2007)
An accessible ICT public procurement policy is a whole-of-government commitment to the
purchase, lease and funding of information and communications technology products and
services which include built-in Universal Design or access-for-all functionality.
All public procurement policy is dependent on procedures and criteria in order to be effective.
An Australian accessible ICT procurement policy will require specific procedures and steps in
order that it achieves the following strategic goals:
improving accessibility in the public service workplace;
increasing accessibility to all public services delivered via ICT platforms, and most
importantly; and
fostering Universal Design in the mainstreaming of ICT products and services for the
entire Australian ICT marketplace.
Public procurement in the context of this paper relates to the expenditure of government funds
in the purchase of all ICT products, services and contracts across all levels of government,
and public expenditure limited to the purchase, lease and development of hardware, software,
and the development of public services. It does not include any public expenditure associated
with human resources in the operation of these ICT products and services.
According to the most recently reported data on Government ICT expenditure collected by
the Australian Bureau of Statistics, the total Australian Government expenditure on ICT in
2003 was over $5 billion (ABS 2004). With an annual ICT budget of this magnitude, the
Government has the power to drive the marketplace for ICT products and services. It is in the
public interest that the Government use this market influence to encourage innovation, growth
and availability of accessible computer equipment, software, telecommunications and public
services. There is a strong argument supporting the link that demand creates innovation.
Therefore, it follows that market demand created through public procurement policy can have
the power to both foster and grow innovation in accessible ICT products and services. When
increased competition is created through the desire to feed public procurement demand for
ICT products and services – products and services which incorporate access-for-all
functionality – the cost of equipment for people with disability across the marketplace should
It is not only people with disability who benefit from the principles of access-to-all
functionality in an ICT marketplace. The development of electronic reading devices for the
blind or vision-impaired have been co-opted as the preferred model for reading by many fully
sighted people and consequently a bourgeoning market for e-books is threatening traditional
publishing models.
Having a competitive marketplace of available, accessible and affordable ICT will be
fundamental if the Government’s Social Inclusion agenda is to include people with disability
in Australia’s growing digital economy.
Several of the world’s leading economic markets have already adopted access-for-all ICT
public procurement policies. Perhaps the most influential of these in leveraging increased eaccess and e-inclusion is Section 508 of the United States’ Rehabilitation Act of 1973, (FCC
2008), which stipulates that all Federal Government departments or agencies must purchase,
develop, maintain or use information and communications technology that is accessible to
people living with disability. For all U.S. Government employees or consumers living with
disability who use government services, all information must be accessible. In order for
government agencies to purchase ICT products and services, these products and services need
to be Section 508 compliant.
The market driver that Section 508 wields in the United States ICT economy ensures that
developers and manufacturers of ICT goods and services address accessibility in order to sell
to the U.S. Government. The roll-on effect of this is that the wider ICT marketplace has more
ICT products with access-for-all functionality built in, removing the barriers of availability
and affordability of accessible products for many of the U.S.’s approximately 60 million
citizens living with disability (U.S Census 2010). In support of the Federal Government’s
commitment to Section 508, the Federal Communications Commission Access Board adopted
a standard for procurement developed by the Telecommunications and Electronic and
Information Technology Advisory Committee in 2008 (TEITAC 2008). Additionally, the
General Services Administration provides federal agencies with Section 508 procurement
guidance and information. (GSA 2011)
The European Union has adopted an access-for-all ICT public procurement policy, Mandate
376 (M-376) (EC 2005). The main objectives of the M-376 mandate are to harmonise and
facilitate the public procurement of accessible ICT products and services and to provide a
mechanism through which public procurers have access to an electronic toolkit that enables
them to make use of harmonised requirements in the procurement process (G3 ICT 2007).
There is a range of EU States' initiatives developed under the auspice of Mandate 376, which
provide national and harmonised intra-EU States access-for-all ICT public procurement
Both national and international studies of e-access and e-inclusion have highlighted a digital
divide between people with disability and their non-disabled family members, friends and
colleagues when participating in the growing digital economy. Addressing this digital divide
needs to be one of the Government’s top priorities as Australia’s digital society increasingly
transforms all aspects of economic, social and cultural life. The power of the public purse can
leverage the wider ICT market to adopt the access-for-all principles of universal design,
principles that can help bridge this digital divide and provide greater participation for all
Australians in our rapidly advancing digital society.
These international procurement policies, such as the European Union’s Mandate M-376,
include consultation with people with disability, experts in ICT development, standards
bodies and manufacturers to ensure that the steps for procurement realise the goals of the
policy. These stakeholders are included in the:
1. request for tender assessment of vendors & tenders;
2. product development or customisation;
3. implementation and evaluation; and
4. ongoing maintenance.
The inclusion and consultation of people living with disability in the development of public
policy is essential if these policies are to be effective. In the case of an accessible ICT
procurement policy where people with disability are the end-users, there needs to be a
thorough understanding of the barriers in access to ICT products and services.
This range of international public procurement policies developed to ensure that accessible
ICT products and services are available for government markets can provide best-practice
guidelines for the development of an Australian accessible ICT public procurement policy.
Unlike comparable first-world countries, Australia has yet to adopt an ICT procurement
policy which includes promotion of access-to-all and universal design protections for our
already disadvantaged citizens living with disability. While the Federal Government has
adopted ICT procurement guidelines, guidelines informed by the Review of the Australian
Government’s Use of Information and Communications Technology Report 2008, these
guidelines do not include any reference to the need to address e-access or e-inclusion for
people living with disability. (AGIMO 2011)
Given the rapidly changing digital environment which has been embraced and championed by
the current Government, the lack of a comprehensive ICT procurement policy that drives
innovation, economic growth and social participation will only continue to disenfranchise and
exclude the very people that a new digital society is hailed as benefitting.
This blind spot in Australian public policy can only be interpreted as the proverbial elephant
in our public square, particularly given that in recent years the Australian public awareness of
the disadvantage that many of our family, friends and neighbours living with disability face as
they engage with the wider world has increased. Leading this growing awareness is a
paradigm shift in the way we view disability. Increasingly policy makers and civil society are
adopting the social model of disability – that is, disability as a result of societal barriers and
attitudes – rather than the outdated medical/welfare model of disability which viewed
disability as intrinsically being an individual’s deficit. Over the past three years the Australian
Federal Government has developed a number of policies designed to help ameliorate the
barriers that inadvertently create many of the access issues that people living with disability
face in everyday life. Most significant is the 2008 ratification of the United Nations
Convention on the Rights of Persons with Disabilities (UNCRPD) (UN 2006). Underpinning
the presupposition of this paper are several of the Articles of the UNCRPD which explicitly
address the need of states parties to improve accessibility in the areas of information and
communications technologies while also calling on signatory states to improve access to those
technologies which allow full participation in the digital economy.
General obligations
1. States Parties undertake to ensure and promote the full realization of all human
rights and fundamental freedoms for all persons with disabilities without
discrimination of any kind on the basis of disability. To this end, States Parties
(g) To undertake or promote research and development of, and to promote the
availability and use of new technologies, including information and
communications technologies, mobility aids, devices and assistive technologies,
suitable for persons with disabilities, giving priority to technologies at an
affordable cost;
Australia has reinforced its commitment to the UNCRPD by ratifying the Optional Protocol
which enables disability discrimination complaints to be taken to the United Nations if they
have failed to be resolved using all domestic remedies within the States Parties.
Another of the recent public policies developed by the Government is its Social Inclusion
agenda, which has been adopted as a whole-of-government commitment to ensure that all
Australians “have the opportunity to participate fully in the life of our society”. This Social
Inclusion agenda is based on the core principle that “the needs of individuals must be at the
centre of policy development and service delivery”, and as such public services must be
accessible for people living with disability (ASIB 2009).
Ironically, in stark illustration of how inadvertent barriers prevent people living with
disability from social participation, the Government’s Social Inclusion website registration
process was initially developed with an inaccessible authentication captcha box that had no
audio alternative, thereby disabling participation, or social inclusion, for people who were
blind or vision-impaired. Had there been a whole of government ICT procurement policy in
place, the development of an inaccessible government website would have been addressed
before it went live.
This social inclusion agenda aligns with the Government’s guiding policy initiative for
addressing disability; the National Disability Strategy (NDS). The overarching NDS is
intended to implement remedies to participation barriers that have been identified by people
with disability, disability service organisations, peak disability bodies and government
departments and agencies that interact with people living with disability (COAG 2010). The
NDS has recently been adopted with a range of high-level ideals and very little in prescriptive
solutions to the many barriers that prevent people living with disability from being able to
fully and equitably participate in the Australian way of life. While the NDS does address
accessible websites, the lack of inclusion of a whole-of-government procurement policy
requiring built-in access-for-all ICT is the major shortfall of the NDS as it stands. As a
national initiative to be implemented under the auspice of the Council of Australian
Governments (COAG), the NDS would have considerably more relevancy and currency with
the inclusion of an accessible ICT procurement policy.
While the Government has not yet undertaken to address this significant gap in public policy,
there have been some recent government initiatives designed to improve access, specifically
in the area of ICT, for people living with disability.
These new policy initiatives include the December 2010 release of the Access to Electronic
Media for the Hearing and Vision Impaired Report which made 22 recommendations to
improve access to broadcast services such as television for those Australians who are Deaf,
hearing-impaired, blind or vision-impaired (DBCDE 2010). The report recommends that
closed captioning on free-to-air television be increased from its current 6pm to 10:30pm
primary channel requirement to 6am to midnight on all free-to-air broadcasters’ primary
channels and all news and current affairs programming. Another of the report’s
recommendations is for the Government to conduct a trial of Audio Description (AD) on the
ABC television network for a period of 13 weeks. Audio Description is a verbal commentary
of the visual content of video that is not available to viewers who are blind or visionimpaired. In order to provide a closed AD trial, one that can have the audio description
content turned on or off depending on a viewer’s need. As the trial will need to be run on one
of the ABC’s digital multi channels, this will require that the digital television or digital settop box has audio-enabled on-screen menu navigation functionality.
Unfortunately, for Australian television viewers who are blind or vision-impaired, there are
currently no audio-enabled set-top boxes available in the Australian marketplace – boxes
which provide an alternative to visual navigation of the on-screen menu. Without an
accessible set-top box, a closed trial of audio description will exclude the very people it is
intended to assist.
Highlighting how public procurement can influence and drive the market, the Government’s
Digital Television Switchover Taskforce is currently running a trial of fully accessible set-top
boxes for its Household Assistance Scheme (HAS). Prior to the Taskforce’s announcement of
the trial, consumer and blindness organisations lobbied government and manufacturers to
promote the development of an audio-enabled digital set-top box for the Australian
marketplace. In the meetings these groups held with industry the discussions ultimately
focused on the market size for disability specific products and the return on investment for
manufacturers producing these products. Discussions on the benefits of Universal Design and
the economies of scale that could be achieved from an access-for-all market approach were
not fully appreciated by manufacturers and consequently they would not commit to
developing fully accessible set-top boxes.
However, in order to secure contracts through future HAS Requests for Tender which will
most likely require full accessibility features in set-top boxes; the manufacturers have since
developed audio-enabled boxes and will soon produce these fully accessible boxes for the
wider Australian market. These set-top boxes will not only enable blind consumers to
navigate digital television but will provide assistance to the growing numbers of aging
Australians with vision loss, consumers with low English-literacy skills and consumers with
cognitive impairments. Through the power of the public purse, accessible set-top boxes in the
Australian marketplace will ensure that the increased choice and participation that digital
television offers as our most ubiquitous medium for entertainment will be available for all
Similarly, the Government’s policy to adopt the World Wide Web Consortium’s (W3C) Web
Content Accessibility Guidelines (WCAG 2.0) will be significant in increasing e-access and
e-inclusion for all Australians, not only those with disability. This policy commits all
government websites to be “A” rated by 2012 and “AA” compliant by 2014 (AGIMO 2010).
This will make access to online government information and services that are delivered via
the web accessible and easier to use for many people living with disability. Unfortunately it
will have limited impact on the under-representation of people living with disability in public
sector employment and even less impact on the wider ICT marketplace
If Australia is fair dinkum about including all citizens in the increasingly ubiquitous digital
society, the lead needs to come through government commitment and policy. An accessible
ICT public procurement policy will:
promote the principles enshrined in the United Nations Convention on the Rights of
Persons with Disabilities (UNCRPD) in which Articles 4, 9, 21 and 30 specifically
address access to ICT and the role that access plays in encouraging economic and
social participation;
create greater employment opportunities for people with disability; and
increase access to the growing number of government services being promoted
through online platforms for people living with disability.
Adoption of a policy requiring accessible ICT equipment and software in all government
departments, and public-funded organisations would largely increase the opportunities of
employment for many Australians living with disability. The roll-on effect of this increased
employment would produce a range of benefits for the whole community. With more people
with disability in public service employment, the cost of providing financial assistance will
decrease. With more people with disability in public service employment society’s attitudes
will change seeing people with disability as fully participating members of the community.
With more people living with disability in public sector employment there will be greater
awareness and employment opportunities within the private sector for people living with
As of June 2010 the percentage of people living with disability employed by the Australian
Public Service was a low 3.2 percent (APS 2010), while at the same time the ABS was
reporting that more than 19 percent of the Australian population identified as living with a
disability (ABS 2010). While we do not know all the reasons that the number of people with
disability is so underrepresented in the public sector, it is likely that with an accessible ICT
public procurement policy in place, the employment opportunities in the public sector for
people with disability would increase. The ABS reports that while Australia is facing a labour
shortage there has been no increase in the percentage of employment of people with disability
over the last financial year, yet the number of Australians in receipt of the Disability Support
Pension has risen.
Current statistics on the numbers of Australians living with disability who are employed are
very disheartening. Vision Australia’s 2007 Employment Report showed that 63 percent of
Australians who are blind or vision-impaired are either unemployed or under-employed, and
of those who are employed, only 30 percent have a weekly salary over $1000. (VA 2007)
As the term implies, access-for-all provides usability and functionality of products and
services to the greatest number of people. Through the adoption of a robust and relevant
whole of government accessible ICT public procurement policy, all Australian public service
workplaces and ICT public services could become accessible to people living with disability.
While Australian Commonwealth departments and agencies are required by the Disability
Discrimination Act 1992 to ensure that online information and services are accessible by
people with disabilities, there remain many strong arguments as to why Australia needs to
adopt a comprehensive accessible ICT public procurement policy, ranging from the rightsbased principle that all Australian citizens need to have full and equitable access to
government services; the power of the public procurement economy in influencing the
broader marketplace; and to ensure that Australia does not become the dumping ground for
inaccessible ICT goods that are unsellable overseas where policies protect markets from
inaccessible products and services, in particular the larger economies of the United States and
the European Union.
Australian Bureau of Statistics (ABS). 2004. Government Technology, Australia, 2002-03
Accessed 14 February 2011, available from:
Australian Bureau of Statistics. (2010). Disability, Aging and Carers, Australia Summary of
Findings 2009, accessed 13 February 2011, available from:
Australian Government Information Management Office (AGIMO) Department of Finance
and Deregulation. 2009. Commonwealth Procurement Guidelines, accessed 14 February
2011, available from:
Australian Government Information Management Office (AGIMO) Department of Finance
and Deregulation. 2011. Commonwealth Procurement policy FMG1, accessed on 13
February 2011, available from:
Australian Government Information Management Office (AGIMO). 2010. Web Accessibility
National Transition Strategy, accessed on 23 February 2011, available from:
Australian Public Service Commission (APS). 2010. State of the Service Report, accessed on
28 February 2011, available from:
Australian Social Inclusion Board (ASIB). 2009. Welcome to Social Inclusion, accessed on 13
February, available from:
Council of Australian Governments (COAG). 2010. National Disability Strategy, accessed 24
February 2011, available from: - 751k
Department for Broadband, Communications and the Digital Economy (DBCDE). 2010.
Access to Electronic Media for the Hearing and Vision-Impaired, accessed on 24
February 2011, available from:
European Commission (EC). 2005. Mandate 376, accessed 24 February 2011, available from: interest/Documents/mandates/m376en.pdf
European Commission. 2006. E-accessibility Toolkit, accessed 13 February 2011, available
G3 ICT. 2007. The Accessibility Imperative: Implications of the Convention on the Rights of
Persons with Disabilities for Information and Communications Technologies, pp139,
Wireless Internet Institute and World Times. Accessed 13 February 2011, available
General Services Administration (GSA). 2011. Section 508 Technology Strategy, accessed 24
February 2011, available from:
McCrudden, Christopher. 2007. Buying Social Justice, Oxford University Press: New York,
p. 25.
Telecommunications and Electronic and Information Technology Advisory Committee
(TEITAC). 2008. Report to the Access Board: Refreshed Accessibility Standards and
Guidelines in Telecommunications and Electronic and Information Technology, April
2008, accessed 24 February 2011, available from:
U.S Census. 2010. United States-Disability-America-Factfinder, accessed 24 February 2011,
available from:
United Nations. 2006. Convention on the Rights of Persons with Disabilities, accessed on 13
February 2011, available from:
United States Federal Communications Commission Access Board (FCC). 2008. Section 508
of the Rehabilitation Act of 1974, accessed 14 February 2011, available from:
Vision Australia (VA). 2007. Employment Report, accessed 14 February 2011, available
Waddell, C. 2009. Public Procurement of Accessible ICTs, Asia Pacific Regional Forum on
Mainstreaming ICT Accessibility, 25-27 August 2009 Bangkok, Thailand Accessed 14
February 2011, available from
Cite this article as: Hawkins, Wayne. 2011. ‘Australia’s missing accessible information and
communications technology procurement policy’. Telecommunications Journal of Australia. 61
(2): pp. 23.1 to 23.9.
Dr Andrew Pesce
Australian Medical Association
An e-health system that connects patient information across health care settings – and to
which treating doctors and other health workers have access, and to which they can contribute
– will improve the safety and quality of medical care in Australia.
A well-designed e-health system makes the best use of existing health care services and avoids
errors, duplication and waste. Although Australia has made significant progress in developing
technical specifications and standards for e-health systems, the time has come to build the
overarching infrastructure to make e-health a reality.
In June last year, the AMA looked forward to an acceleration of e-health programs in
Australia after the passing of the Healthcare Identifiers Act by the Federal Parliament.
Healthcare identifiers are an important building block for electronic health records. They will
facilitate the timely and accurate sharing of electronic patient information.
However, a Department of Health spokeswoman recently conceded that the Healthcare
Identifiers Act does not provide for a system of shared electronic records. Instead, the
National E-Health Transition Authority has selected IBM to design and build the National
Authentication Service for Health to improve the security of electronic health
This is a welcome move and another step towards implementing personally-controlled
electronic health records as part of the Government’s 2010-11 Federal Budget commitment of
$466.7 million to develop a system that supports personally-controlled electronic health
But this funding falls well short of the $1.1-$1.8 billion that the National Health and Hospitals
Reform Commission had estimated was needed to deliver the national core infrastructure,
governance standards and the tools to ensure the system will be available to all Australians
who choose to participate.
It is clear that significant investment is still needed in e-health.
The push now is for a commercial approach that will rely on private investment and private
engagement. However, it is hard to see e-health becoming a reality without a solid
commitment from the Government to build the overarching infrastructure that is necessary to
connect patient information across the health care sector.
A report by Booz and Co last year into e-health investment found:
e-health in primary care drives most of the health system benefits, however these
benefits are not realised in the primary care setting but flow on to the acute setting;
the investment must be made at the primary care level, but the financial benefits of
that investment accrue elsewhere;
those who are required to make the significant investments reap only a small
proportion of the benefits;
those with the most to gain incur fewer costs; and
governments are best positioned to intervene in this distorted market.
Personally-controlled electronic health records can empower and encourage individuals to
take responsibility for their own health, but for medical practitioners, their use may be
severely limited because of problems with the accuracy and comprehensiveness of the
information they contain.
If e-health is to deliver safe and quality patient care, and avoid medication errors and
duplication, we must have a shared electronic medical record in addition to any personallycontrolled health record.
A shared electronic medical record that links reliable and relevant medical information across
health care settings would provide treating doctors with the information required to inform
clinical decisions.
The AMA Federal Budget Submission 2011-12 called on the Government to concentrate all
its efforts on getting pathology results, diagnostic imaging results, hospital discharge
summaries, and medications dispensed information onto an electronic medical record.
This is basic information, yet critical to patient care. It is currently available in electronic
format, but it is not easily or instantly accessible to doctors in all situations when they are
providing care for patients.
If it were possible for doctors to electronically access this patient information in ‘real time’,
while protecting patient privacy, a significant amount of the e-health ambition would be
The Government must fund and implement a shared medical record that:
is supported by a personally-controlled electronic health record;
contains reliable and relevant medical information about individuals;
aligns with clinical workflows and integrates with existing medical practice software;
has appropriate security measures in place to protect patient privacy;
is governed by a single national entity; and
is fully funded by governments and supported by appropriate incentives, education
and training.
Of course, there will need to be appropriate safeguards for patient privacy. Every doctor is
concerned about the clinical risks if patients are reluctant to share information with them
because they thought – somewhere, sometime – that information might be accessed
inappropriately. These concerns will need to be dealt with when there is legislation that
covers the arrangements for electronic health records.
Making e-health a reality is a complex process that requires a sound and realistic
implementation plan. Medical practitioners will play their part in bringing about the benefits
of e-health by investing within their own practices. But the Government will need to take
strong leadership to invest in and build the overarching infrastructure that is needed to
connect patient information and assist doctors to obtain the capability to make e-health a
routine part of medical practice.
The AMA Position Statement on shared electronic medical records can be viewed at
Cite this article as: Pesce, Andrew. 2011. ‘Infrastructure gaps must be filled to make e-health a
reality’. Telecommunications Journal of Australia. 61 (2): pp. 24.1 to 24.2.
Dave Lee
NSW Farmers' Association
The following article was written in February 2011 and therefore
may not take into account subsequent policy announcements.
The impending roll-out of the NBN provides an opportunity to address the inequitable access
to high-speed broadband, and to empower citizens to effectively use new technologies as they
become available. This paper seeks to briefly highlight the technological inequality in
Australia, outline Australian Government policies and programs aimed to address the digital
divide, and discuss potential gaps that require attention.
Focus is concentrated on Australian Government facilitated educational and informational
policies designed to reduce the digital knowledge divide. Given the massive investment of
taxpayer funds in the NBN, it is argued that further educational measures are required to
ensure citizens have the ability to make use of available technology, and thus gain the
maximum benefit from the NBN.
The NSW Farmers’ Association is the key state representative body for both intensive and
extensive industries ranging from broadacre, meat, wool and grain producers, to producers in
the horticulture, dairy, poultry meat, egg, pork, oyster and goat industries. Through its
commercial, policy and apolitical lobbying activities it provides a powerful and positive link
between farmers, the Government and the general public.
The Association’s telecommunications policy has been developed over many years,
continually evolving with changes in technology, social policy and regulatory framework.
Regardless of change, there have always been two underlying principles: parity of service and
parity of price. The Association believes these principles should apply to all
telecommunications customers – regardless of their geographic location. This philosophy
drives the Association’s objectives in the area of telecommunications, with broadband
Internet and the development of the National Broadband Network (NBN) being no exception.
Whilst the Association’s primary policy focus is equality of access and price, the issue of a
digital divide exacerbated by the inability to optimally utilise available technology is also of
concern to our Members, and requires further action from Government.
The NBN is Australia's largest infrastructure project. It has been widely lauded as a landmark
investment that will bring broadband access to all Australians, whilst simultaneously being
criticised for not having undergone an independent cost-benefit analysis. As the NBN is rolled
out, and better broadband resources become available, investments in empowering citizens to
embrace the opportunities it brings are necessary. Furthermore, as expectations rise from
business, society and government to participate in the digital world, the coming years are
shaping up as a watershed period in addressing the digital divide.
Whilst there are many definitions of the digital divide, it is defined in this paper as 'the gap in
access to technology'. Digital divide is caused by a number of factors including income,
education, age, location, disability, opinion, gender and culture (ACT Government 2003;
Curtin 2001; Curtin 2003; Lloyd & Hellwig 2000). The Australian Government has made a
significant investment in the NBN to reduce this gap. A key element of the NBN is the
guarantee that all Australians will be able to access high speed broadband of a minimum 12
Megabits per second (Mbps) peak speed. Whilst increased physical access will contribute
significantly to reducing the digital divide, it's just one piece of the puzzle.
In one study access was divided into three components: access, ability and affordability (ACT
Government 2003). 'Access' is described as technical access from home, community or public
access points. 'Ability' is explained as the provision of training and support, including
culturally appropriate training, and 'affordability' is referred to as the cost of access to
appropriate technologies. In this article, the term 'access' will refer to technical and physical
access, not to be confused with ability or affordability.
The purpose of this paper is not to comment on the necessity, price, or technical elements of
the NBN. This paper focuses on the policies and programs in place aimed to address the
contribution of ability to the digital divide. This is not to say that access and affordability
aren't important, or have been resolved. Clearly they haven't, and these issues will be briefly
visited to provide context.
Gibson (2003) identified eight factors that contribute to a digital divide: income, education,
age, location, disability, opinion and gender. Whilst all eights factors can affect the ability to
utilise the Internet effectively, this paper focuses on location. This is due to the historical
geographic divide in Australia, and the Government's responses aimed to address this issue.
Internet and broadband services have expanded outside of cities as a result of increases in
technology, geographical extension of access, and Government assistance targeting
underserved citizens and regions. Government programs such as the Higher Bandwidth
Scheme, the Broadband Connect and the Australian Broadband Guarantee were somewhat
successful in responding to the issue of lower availability of broadband Internet in rural
Australia. Their overall success is of less certainty, with a detailed analysis having been
provided by the Australian National Audit Office, released on 15 February 2011.
This history of the need for Government intervention to improve access in rural Australia
relates to ability in two ways. Firstly, it shows that there is a market failure for
telecommunications services in rural Australia, which shows no signs of abating. Secondly, it
shows that rural Australians are newer to broadband technology in general, and thus may
require further information on how they can benefit from the Government's massive
investment in new technology.
Figure 1 below shows the continuing digital divide and constant improvement in the
percentage of households with Internet access. It must be stressed that merely having access
to the Internet is only one element of digital participation. Quality and affordability are
equally important, and both are affected by location.
Figure 1 - Percentage of Households with Internet Access
(Source: Australian Bureau of Statistics. '8146.0 - Household Use of Information Technology, Australia, (2009))
Government Policy objectives aimed at reducing the digital divide can be divided into two
those aimed at increasing access and affordability, and
II) those aimed at encouraging efficient use by those who already have access.
These two policy aims are closely linked and often overlapping.
The NBN proclaims to provide all Australians with access to a minimum peak speed of 12
Mbps. 93% of Australians will have access to fibre to the home which will allow for speeds of
100 Mbps and more. Of the remaining 7%, 4% will have access to fixed wireless, and 3% to
satellite services which will allow peak speeds of up to 12 Mbps (as opposed to minimum
peak speeds originally promised by NBN Co), an obvious disadvantage. The millions of
Australians who make up this 7% are often forgotten in discussions touting the benefits of
fibre. The digital divide remains a significant issue, with no solution proposed.
NBN Co. has indicated that they will charge the same wholesale prices Australia wide.
However retail prices are far from certain, and could well vary between geographical
The quality of service provided by satellite and fixed wireless will also be inferior. The
Wireless Access Service and the Satellite Access Service will not initially have access to
interactive streaming, real-time video or the Transactional Business Virtual Private Network
Access service.
As outlined earlier, closing the digital divide depends on ensuring that people have the ability
to use services, should they be able to access and afford them. Williams (2011, p54) said:
'Rollout' is necessary but not sufficient without 'roll up'! 'Rollout' suggests that
success in implementing a 'national broadband network' is a purely technical matter,
with access achieved when inputs are committed. 'Roll up' speaks to the need to
understand that success is achieved when the passive notion of 'enabling access' is
replaced by an active reaching out to people to actually use this new tool.
As the NBN rolls out, and more advanced technology is available, there is a risk that people
will be intimidated, and feel like they have 'missed the boat'. Figure 2 shows that Australians
would like to have a greater knowledge on how to use the Internet. It is interesting to see how
many people in their thirties who want to use the internet, but do not understand how.
Figure 2 - Internet non-users responses to the statement 'I would like to use the Internet but feel intimidated by the
complexity of it all', by age.
14–19 year
20–29 year
30–39 year
40–49 year
50–59 year
60–69 year 70 and over
Note: excludes respondent category 'cannot say'.
(Source: Roy Morgan Single Source Australia Database, Internet non-users aged 14+, Jan 08–Jun 08, (n= 2049).)
Government's policy goals and programs designed to address the ability of Australians to
maximise the potential benefits that the NBN facilitates are outlined below. The evidence
suggests that policy is unclear, and programs are inadequate given the scale of the provision
of broadband infrastructure.
When looking at the Government's stated policy goals, it is not clear what role they aim to
play in addressing the lack of ability of Australians to participate digitally. Page 3 of
Australia's Digital Economy: Future Directions defines the key focus in creating a successful
digital economy:
for Government, to:
Lay the foundations for the nation's digital infrastructure
Facilitate innovation
Set conducive regulatory frameworks
for Industry, to:
Demonstrate digital confidence and build digital skills;
Adopt smart technology;
Develop sustainable online content models
For Community, to:
Enjoy digital confidence and digital media literacy skills;
Experience inclusive digital participation; and
Benefit through online engagement. (Commonwealth of Australia 2009: 3)
This clearly states that the Government does not have a role or responsibility to facilitate
digital participation. This is contradicted later in the same document when outlining the
Government's digital media literacy policy and program skillset aims:
The technical ability to engage at a basic level with a computer and the Internet, for
example creating documents and emails;
The ability to understand and critically evaluate digital media and to understand and
critically evaluate digital media content; and
The ability to create content and communications. (Commonwealth of Australia
2009: 44)
Whilst this appears to provide clarity of policy goals, the introductory sentence under
'Government measures' provides further ambiguity:
The Government has a number of initiatives in place that are designed to increase
access to online services by all Australians. (Commonwealth of Australia 2009,
This statement oversimplifies the issue the Government is trying to resolve. Whilst they are
stating that they are seeking to 'increase access', the underlying problem they are really trying
to address is an increase in ability.
Does the Government have a role in facilitating use, promoting knowledge or educating the
public about the benefits their massive investment in the NBN will bring? Surely it should be
a key area of focus to ensure communities achieve digital confidence and digital media
literacy skills. Promotion and education of benefits will encourage greater participation and
uptake, thus providing a greater return for the Government's investment. Further clarity in this
area from the Government is required.
Whilst NBN Co has been tasked with the roll-out of the NBN, it is not intended that they
educate Australians about the potential benefits it will bring. This is highlighted in the
Government's Statement of Expectations with NBN Co; no mention is made of education or
encouragement of use. The communication, education and empowerment of citizens to use
the NBN is the responsibility of the Department of Broadband, Communications and the
Digital Economy. The National Broadband Network: Progress update December 2010 does
not specifically mention how it plans to educate and empower citizens to get the most out of
the broadband network.
Despite the policy confusion outlined above, the Government has put in place programs to
promote participation in the digital economy, and inform citizens of the potential benefits the
NBN will facilitate, with further programs planned. An outline of key programs is provided
below with commentary on their relevance and adequacy.
The digital business website ( was set up by the
Department of Broadband, Communications and the Digital Economy (DBCDE) to assist
small businesses and community organisations to make the move online. This does not fall
under the category of empowerment of basic Internet use, but it is a step in the right direction
to assist businesses and groups to move online.
DBCDE commissioned the following research projects to help analyse the benefits of a digital
Household e-commerce activity and trends in Australia;
Impacts of teleworking under the NBN;
Financial and externality impacts of high-speed broadband for telehealth; and
Telemedecine in the context of the National Broadband Network.
The findings of these reports are very useful in identifying the potential benefits of the NBN,
and will no doubt be communicated to citizens. The method by which they are communicated
remains a key challenge.
DBCDE is implementing a number of programs to improve online safety and security. These
are of great importance, as those who are new or inexperienced at using the Internet need
reassurance that they will be safe online. It is important that very simple, clear information is
communicated to Australians, through a variety of traditional channels, to alleviate such fears.
The Government has committed $2 billion over five years to the Digital Education
Revolution program. This program aims to contribute sustainable and meaningful change to
teaching and learning in Australian schools that will prepare students for life in the digital
economy. Longer term strategies such as these are important, to ensure that no children are
left behind.
The four-year Digital Regions Initiative program co-funds digital enablement projects with
state, territory and local governments. It takes a collaborative approach to improve the
delivery of education, health and/or emergency services in regional, rural and remote
communities. Programs that have received funding include:
Ambulance Mobile Connect SA;
North East Victoria Bushfire; and
South Australian Digital Telehealth Network.
Broadband for Seniors is Government funded program aimed to:
provide older Australians with access, confidence and skills in new technology;
address issues of technological isolation; and
build community participation and social inclusion.
The program provides basic Internet training to seniors, given by volunteers. If this training
provision were to be extended, volunteers should be utilised where possible. However, if
demand exceeds that which the volunteers can provide, Government will need to step in to
provide this service. Quite often those who need the training the most can least afford it, and
thus it would not be appropriate to leave this up to the private sector to provide.
The success of Broadband for Seniors is currently being assessed by the Department of
Families, Housing, Community Services and Indigenous Affairs. Anecdotal evidence states
that this has been extremely successful in teaching older Australians basic computer and
internet skills, with participant improvement far exceeding expectations. This provides a
fantastic example of a program increasing the ability of a group to participate in the digital
economy, effectively addressing a market failure. A similar approach is taken in the
Indigenous Communications Program. Delivery of computer training is to be provided over
the next four years in up to 120 remote Indigenous communities.
Regional Broadband Coordinators raise awareness of broadband and the opportunities of
competitive backhaul services, promote broadband take-up and use and improve community
understanding of the opportunities of broadband and engagement in the digital economy.
Currently, there are eight broadband coordinators in Australia, covering the priority backbone
blackspot regions. This means that there is limited coverage in rural Australia to communicate
the importance of engagement in the digital economy.
In late 2010 the Australian Government ran Community Forums to provide information on
the benefits of high speed broadband. Information provided by DBCDE stated:
The number of attendees averaged over 25. The audiences were diverse and included
both the general community and business representatives.
Generally, attendees were very grateful for the forums and the opportunity to ask
questions. In all locations in which the forums were held there was a very positive
sentiment for the Government's NBN initiative.
The information provided at the forums centred around the benefits of broadband as
well as the specific detail around the initiative and the physical rollout.
Representatives from both the Department and NBN Co were in attendance to answer
There are no notes or minutes of the forums, and no further information can be
provided at this point in time.
It is difficult to assess the success of this initiative, given the limited public available
As at February 2011, DBCDE was working with a communications agency to develop a four
year communication plan aimed at educating all Australians about the benefits of an NBNenabled digital economy. This information is not yet publicly available.
Whilst the focus of this paper has been on the policies and programs of the Australian
Government due to their decision to invest in the NBN, it is important to recognise that all
initiatives must be accommodated and incorporated in planning. These include initiatives by
State Government, Local Government, Private Companies, Internet Service Providers and
Public Libraries.
As the NBN is rolled out it is essential that the issue of 'ability' is addressed in a timely,
adequate manner. As discussed above, a detailed communications plan will be implemented
by the Government to compliment the technical communication that will be done by NBN
Co. This communications plan needs to go beyond advertising roll-out details and raising
awareness of the project. It should address the policy gaps that exist in relation to ensuring
that all Australians have the basic skills to be able to utilise the NBN.
Programs that educate and empower people who will have access to the technology to use
services such as online forms, video conferencing and discussion forums are essential. These
programs must be free, offered in physical locations with actual instructors, and be well
advertised to maximise participation. It is crucial that education methods range from those
that rely on no prior knowledge of computers and the Internet, through to more intermediate
The timing of this information is critical. Citizens need to have had an ability to increase their
ability to utilise the NBN before they make the decision to opt in. If this does not occur, too
many could decide not to opt in, due to the perception that they would never be able to utilise
the technology available. Another key point is that Government must be able to learn lessons
as the educational communications strategy is rolled out around Australia. Demand for
programs can be gauged, and tailored to make efficient use of Government resources.
In reviewing the Australian Government's policies and programs aimed at the ability
(meaning competence and confidence) of Australians to use the Internet, it is clear that
change is required before the NBN is rolled out. The Government has indicated that a detailed
four year communications plan will be released by June 2011. It is essential that it clearly sets
out how the Government plans to ensure that all Australians are aware that assistance is
available that will allow them to improve their Internet skills.
The current lack of information from Government on addressing the digital knowledge divide,
whilst worrying, can be addressed in this communications plan. It is essential that the roll-out
of the NBN is not restricted to technical information on infrastructure provision, connection
details and pricing strategies. The risk that citizens will not embrace the possibilities of the
NBN, or opt out completely, is very real. This could result in a larger issue if people feel that
the NBN facilitated digital world has passed them by. Too much taxpayer money has been
invested for the key issue of ability to be neglected.
Whilst this paper has focussed on ability, it is stressed that differences in affordability and
quality access will continue to be the primary causes of the geographic digital divide even
after the NBN has been rolled out.
ACT Government. (2003). Community IT Access Plan, viewed 14 February 2011. Accessible
Australian Bureau of Statistics. (2009). 8146.0 - Household Use of Information Technology,
Australia, 2008-09. Australian Government, Canberra. Available at:
Black, M & Atkinson, J. (2007). Addressing the Digital Divide in Rural Australia. Accessible
Curtin, J (2001). A Digital Divide in Rural and Regional Australia. Department of
Parliamentary Library, Canberra.
Curtin, J (2003). Annual Report of the Networking the Nation Board. Australian Government,
Commonwealth of Australia. (2009). Australia's Digital Economy: Future Directions.
Australian Government, Canberra. Accessible at
Gibson, C. (2003). Digital Divides in NSW: a research note on socio-spatial inequality using
2001 Census data on computer and Internet technology. Australian Geographer 34 (2)L
Lloyd, R & Hellwig, O. (2000). Barriers to the take-up of new technology. University of
Canberra, Canberra.
Williams, T. (2011). Connecting Communities – The Impact of broadband on communities in
the UK and its implications for Australia. Huawei, Australia. Accessible at
Cite this article as: Lee, David. 2011. ‘The digital divide: the Australian Government's role in
addressing 'ability'’. Telecommunications Journal of Australia. 61 (2): pp. 25.1 to 25.8.
Mandy Salomon
Smart Services Cooperative Research Centre, Swinburne University of Technology
As debate ensues over the nation’s priority to build ‘a gold-standard Internet network’ as
Communications Minister, Senator Stephen Conroy describes it, his government’s broadband
initiative, the NBN, has many Australians asking what the business case for a super-fast
broadband service might be.
With educationalists alert to the fact that the 21st century classroom leaves the closed, teachercentric, facts-based model of learning behind, the curriculum is being redesigned, teacher
practice is changing, and technology tools that cater for an extensible, customised approach to
learning are being developed.
Amongst the most compelling technology services for consideration are multi-user virtual
environments (MUVEs); these are emerging technology platforms which can be hosted on
servers or sold as software that enable 3D rendering of real or composed scenarios, events,
people and places, which may be shared in real time with multiple other users, stream rich
media and which can integrate learning management systems, such as ‘moodle’.
The aim of this paper is, firstly, to outline the important role MUVEs could play in our virtual
classrooms, and, secondly, to assess whether policy and curriculum development are mindful
of the advantages of implementing MUVEs, as there is evidence that MUVEs are being
overlooked by ICT strategists and in the setting of Australia’s first national curriculum. This
discursive paper shows where the omissions are, and suggests that, as far as the
implementation of 3D virtual environments in the education sector goes, there may be a
disconnection between those who ‘do’ (the teachers) and those who ‘plan’ (the policy
As debate ensues over the nation’s priority to build ‘a gold-standard Internet network’, as
Communications Minister, Senator Stephen Conroy (2010) describes his government’s
broadband initiative, the NBN1, many Australians are asking what the benefits of a super-fast
broadband service might be.
In December 2010, Minister Conroy’s Department 2 released its ‘Progress Update’, flagging
the new education services that the NBN would facilitate. The planned new superfast
technology infrastructure, promising speeds of up to 100 megabits per second (Mbps) to 93%
of all premises, would create ‘virtual classrooms’, ‘addressing the distance and isolation
barrier…providing access to the best specialist teachers…and enabling collaborative learning
between education institutions, both domestically and internationally…’ (DBCDE 2010).
The NBN is of course, a means to an end, not a solution in itself, and, concomitantly the
complex job of scoping the ‘virtual classroom’, understanding how to learn and teach within
it, and determining which services need to be developed for achieving the aims must, must
also be undertaken.
The conundrum is being energetically discussed in forums across the nation and indeed
internationally. Outlining the nature of the shift, at the education and technology conference
‘Questnet’, Nick Cross, Education Outreach Manager at the Australian Academic Research
Network (AARNet), surmised:
‘Formal education no longer comprises the majority of our learning. Learning now
occurs in a variety of ways – through communities of practice, personal networks,
and in the participation of targeted learning’ (Cross 2009).
Similarly, in its ‘Teaching and Learning with Web 2.0 Technologies’ report, the Victorian
Department of Education and Early Childhood Development referred to ‘the need for more
collaborative learning, with student connections formed with experts, parents and peers’
(DEECD 2010, 5).
With educationalists alert to the advantages of the 21st century classroom over the the closed,
teacher-centric, facts-based model of learning, the curriculum is being redesigned 3, teacher
practice is changing, and technology tools that cater for an extensible, customised approach to
learning are being developed.
Amongst the most compelling technology services for consideration are multi-user virtual
environments (MUVEs). These are emerging technology platforms which can be hosted on
servers or sold as software that enable 3D rendering of real or composed scenarios, events,
people and places, which may be shared in real time with multiple other users, can stream rich
media, and can integrate learning management systems (Gardner et al 2008), such as
‘moodle’ (Sloodle 2010).
The aim of this paper is, firstly, to outline the important role MUVEs could play in our virtual
classrooms, and, secondly, to assess whether policy and curriculum development are
sufficiently cognisant mindful of the advantages of implementing MUVEs, as there is
evidence that MUVEs are being overlooked by ICT strategists, and those charged with
constructing Australia’s first national curriculum (ACARA 2010).
This discursive paper shows where the omissions are, and suggests that, as far as the
implementation of 3D virtual environments in the education sector goes, there may be a
disconnect between those who ‘do’ (the teachers) and those who ‘plan’ (the policy makers).
The research entailed:
1. Observing the use of MUVEs at Melbourne Grammar School.
2. An environmental scan of government support and initiatives.
3. Collecting and annotating perceptions about the ‘immersive Internet’. 4
It was then considered whether such perceptions constitute the view amongst policy makers
that MUVEs are not yet ready for deployment in classrooms – or indeed if they are
sufficiently cognisant with them.
The paper does not delve into the machinations of departmental jurisdictions, in particular, the
Department of Education, Enterprise and Workplace Relations (DEEWR) and the many
committees across the education sector which report to it. Such detail is beyond the scope of
this paper, although following this thread would further illuminate the blockages.
In terms of the promise of the NBN and the educational opportunities envisioned, this enquiry
is, hopefully, timely.
Reports about trends in online learning (Allen et al. 2008; Johnstone et al. 2009) indicate that
a range of factors constitute today’s virtual classroom, but that the range itself is predicated on
a network-enabled computer as the baseline requirement, after which all or some of the
following features may become involved:
web-derived content including rich media
remote access with limited or no face-to face contact with teachers and students
synchronous and asynchronous access to content
self determined learning pathways and time frames
online collaboration tools such as wikis and blogs for knowledge acquisition
The relationship between the learning community (including teachers), the curricular, and
ICT tools and skills are further components for consideration (U.S. Department of Education
2010, 14-22).
Immersive tools are a part of this new paradigm; they are extensible environments for
creating, sharing, and building knowledge. Multiple users gravitate or enter the simulated
environments because of a common interest or purpose, such as collaboration, education and
training, co-design, entertainment, industry and community events, and social interaction. A
graphical representation, an avatar, denotes a user’s presence. Numerous users may share the
same digital space; they see the same objects and avatars as one another, and can interact with
all. Interaction is via multiple channels (chat, voice, gestures, and movements) and many such
platforms enable users to share common content synchronously. A computer keyboard is used
to navigate and manipulate viewpoints, although new modalities such as gesture, which
Xbox’s Kinect brought to market in 2010, are being introduced. MUVEs’ variable elements
include graphics, interaction, media input, documentation and presentation tools, scalability
and bandwidth.
In his book, ‘Getting Over The Slump: innovation strategies to promote children’s learning’,
James Paul Gee describes how new digital environments assist in problem solving, in that
they enable educators to ‘build worlds full of the sorts of content we have associated with
books’, allowing ‘young people to enter these worlds and experience directly the connections
between words and other symbols and the world.’ (Gee 2008,16). MUVEs open up an
enormous range of imaginary tasks, with content which can mimic a historical setting, but
which equally, can simulate real world scenarios that allowing students to role-play and
problem solve.
The Northern Beaches Christian School (NBCS) in outer Sydney has made a major
commitment to 3D learning environments. Teacher, Steve Collis (2009), reports that NBCS
students are practised in their use of 3D interactive tools, and that they have created clothing
designs and started a business for selling them using an ‘in-world’ 5 currency. There is
bookstore for student writing, a welcome centre, an auditorium, an art gallery showing
monthly exhibitions of student work, and an in world radio station streaming student-made
programs. Governance, in NBCS’ virtual environment is handled by its ‘land council’ there is
a content regulatory body for programmers. Directed learning might take place at the Maths
Maze, whilst group work has students beaming up into pods that hover above the terrain. Text
chat is part of the assessment and is emailed directly to the teacher. A dance club enables
students to socialise with their French counterparts, developing language skills and cultural
insights at the same time. Importantly, Collis, who has a language teaching background,
believes that the students are learning ‘high order skills’ that ‘would impress any employer’
(video narration in Collis 2009). He also emphasises that implementation of MUVEs in to the
curriculum would not have occurred without support at the highest level of the school.
MUVEs have many properties that lend themselves to remote and distance learning (O’Neill
2010, Salmon 2009) but if they were merely a substitute for a physical classroom, there would
be no need to use it when students were co-located. Multi-user virtual environments are being
used in situations where students are both in the same room as well as connected to each other
in a virtual world. This so-called ‘mixed-reality’ learning’ (Gardner et al. 2008, 8) involves
class sessions structured around the integration of virtual worlds and traditional face-to-face
group work, building on the ideology that knowledge becomes valuable when it is created and
devised through the collaborative processes. 6
The following case study, a three-day workshop entitled ‘Make Poverty history in Second
Life’ (MGS 2008) which was conducted at Melbourne Grammar School (MGS) in July 2008,
demonstrates this. The multi-media project, which used the 3D virtual environment platform
Second Life, could not have been achieved using more traditional collaborative tools, such as
web conferencing or document sharing.
Facilitated by the school’s director of eLearning, Alberto Rizzo, 22 students decided to build
on the theme ‘Make Poverty History’ by creating 3D objects and posters in an exhibition
space to draw attention to the poor living conditions for communities in developing countries.
The location for the activity was Skoolaborate, a schools site within the ‘Teen Grid’, a region
purposed for 13-17 year olds in the virtual world, Second Life. 7 The project was ambitious in
terms of the short time frame, however a project blog was used to help students navigate, two
experienced MUVE facilitators, or ‘para-teachers’, as well as MGS staff were on hand to
The awareness campaign culminated in a mixed-reality concert featuring local bands
performing in the school’s hall while simultaneously, a virtual version, consisting of the live
audio feed and an avatar band (students were controlling the avatar movements) streamed into
the ‘Make Poverty History’ virtual space. At the same time, the in-world version (the
simulation), comprising a virtual stage, and avatar representations of the band members and
their instruments, was streamed into the school hall on a large screen. Skoolaborate member
schools from around the world logged in to the region and were able to view the virtual
concert in real time, as well as view the creative content designed by the MGS students.
Those for whom conflicting time zones were a problem were able to visit the exhibits after the
event and watch the real-world concert as an archived machinima 8 (Rizzo 2008).
Figure 1 - Students from Debney Park Secondary College mentor Melbourne Grammar students In ‘The Make
Poverty History in Second Life’ project. July, 2008
The Second Life component amounted to around $6k, a cost which MGS reasoned would be
an investment in terms of future projects such as digital storytelling and machinima
production (Rizzo 2008). The funds were allocated to employ technical personnel, including
para-teachers with Second Life expertise, extra equipment and bandwidth, (though the
school’s existing bandwidth proved to be sufficient).
Alberto Rizzo believes the cost was justified, given the steep learning curve for the School
and the need for experienced hands on the day. Following the event, a school Second Life
group was formed involving MGS staff and students, and weekly workshops. The group
continues to collaborate locally with Debney Park Secondary College and further afield with
Skoolaborate’s global cohort. Activities include 3D modelling, content creation and
storytelling. Some MGS students are proving to be so competent that they are employed as
content builders in the wider education and training sector, (informal discussion with
facilitator, Dale Linegar, in 2010).
Figure 2 - The project blog; students were given series of activities, rather than a ‘how to’ manual. This activity
focuses on creating avatars to represent the real world band members. Prompts to action include ‘using the
appearance editing tool’, and ‘take some snapshots’
A deconstruction of the event shows that:
1. Group work occurred simultaneously, in the real and virtual environment (‘mixed
2. Learning to navigate and build content in the virtual world was a hands-on
experience. No textbook was used.
3. Students created and constructed visual metaphors for their ideas about poverty in
developing countries using in-world tools; no physical resources were required to do
4. Students worked in teams, and designated one another roles.
5. A para-teacher with Second Life skills oversaw the event, as no teacher within the
school had sufficient training to handle the event.
6. Students were in a position to demonstrate their newly found skills to their regular
teacher – a reversal of the usual paradigm where the teacher provides information for
students to consume.
7. The students had a critical time frame in which to achieve their goal, and were
working with people from other schools whom they had not met before.
8. The project leveraged the mission, motivation and achievement characteristics of
multi-player video games with which many young people are familiar and which is
played recreationally, outside of school hours.
MUVEs are emerging technology, thus users commonly experience bugs such as lag and
instability. Muves’ plug-and-play potential can be hindered by schools’ IT policies and
configurations. Lack of customer support, setup and registration time were identified as major
problems by a Victoria University team who opted to use the Second Life ‘Teen Grid’ for
their ‘Avatar Project’ (Schutt et al. 2009).
Virtual worlds can present some perplexing issues around governance, as regulatory elements
are largely in the hands of developers. Real-world authorities are always in catch-up mode as
virtual world practices evolve, and are uncertain about how to regulate public virtual worlds,
especially where money laundering, tax avoidance, scams, harassment, and theft have been
known to have occurred. These are some of the reasons why educators might seek to use
platforms that sit behind their institutional firewall.
Subscribers have limited rights over the environments in which they have invested, and are
subject to end user licence agreements (EULA) over which they have little or no input.
If a virtual world platform should close, users have little to no recompense for their digital
assets. However, interoperability and content transfer between platforms is well underway,
with the Boston-based Immersive Education Initiative (IEI 2010) able to transfer content
across five platforms. 9 This mitigates any losses, as users could transfer their work to an
alternative product.
MUVEs become bandwidth hungry the higher their levels of ‘immersion’ 10; even lightweight
platforms11 are impacted if user-groups are simultaneously looking at multiple, embedded,
rich media, such as streaming video, streaming audio and presentations. 12 In terms of the
NBN, other factors with a potential to impact of performance (Given 2010) will be periods of
peak demand on the network, and the fact that many users will chose to opt in at the ‘entry
level’, delivering a likely 12 Mbps, not the high end 100 mbps, which is applicable to the
needs of large-scale-enterprise.
Whilst research for this paper did not uncover a definitive range of bandwidth required for
optimum usage - variables include the configuration of the client, the number of plug-ins
associated with the platform, its graphical density, the number of simultaneous users, the
demands of the project at hand – anecdotally, service providers and developers interviewed 13
all support the idea that increased bandwidth builds new services and extends existing ones,
and that, ipso facto, demand by the public for these services will increase. This same view is
expressed by Minister Conroy’s Department, which foresees that the NBN will ‘support a
new wave of digital innovation that will change and improve the way Australians live their
lives, receive services and connect with the world.’ (DBCDE 2010).
It is hardly surprising that exponents of the ‘immersive Internet’ are enthusiastic advocates of
the Federal Government’s NBN strategy, if for no other reason than their own creative
enterprises stand to benefit. But beyond this, MUVE providers cited (comprising a value
chain of content developers, designers, technical staff and para-teachers), share Minister
Conroy’s belief that the proposed fibre-to-the-premises infrastructure will ‘drive innovation
and opportunity’ (NBN 2010).
In spite of current bandwidth constraints, experimentation in MUVEs within the education
and training sector is well underway. Institutional advocates include the Department of
Education and Training, NSW’s Curriculum and Learning Innovation Centre (CLIC) and the
Distance Education Hub (DEhub) which includes a Virtual Worlds Working Group
comprising representatives of over 30 higher-education institutions with some three hundred
scholarly works attributed to them (DEhub 2011). Over 100 projects have been identified in
the higher education sector (Salomon, 2010 pp.12-13), and this is by no means an exhaustive
In contrast, there is a notable lack of recognition in the Federal Government’s Digital
Education Revolution (DER), which has committed $2.4b over the seven years, 2009-16, to
make the most of the ‘opportunities presented by the National Broadband Network’ (Gillard
2010). Of this, $40 m has been allocated to professional development programs for teachers
and school leaders. Within this parcel, a $16m ICT Innovation fund has selected four largescale programs designed to equip teachers with digital readiness (DEEWR 2010b ).
Significantly, none of these programs make any clear reference to virtual worlds or multi-user
virtual environments. As an example, in the $5.4m program ‘Anywhere, Anytime Teacher
Professional Learning’, designed to update teacher’s ICT skills, a program ideally suited to
assisting teachers to become cognisant with MUVE technology. One outcome has been the
establishment of ‘Pathways for Learning Anytime Anywhere ; a Network for Educators’
(PLANE) by the NSW government to create ‘a 21st century immersive learning environmenta "digital virtual world" for experiential learning, problem based simulation learning,
collaborationand communication’ (PLANE 2011). However the bulk of the program focuses
on Adobe Connect and Microsoft Sharepoint (DEEWR 2010a), which are cloud-based
services designed for the business and enterprise sector; as such, their design is skewed
towards project management rather than ‘experiential learning’, a central tenet identified by
the Australian Curriculum Assessment and Reporting Authority (ACARA) in its vision for
21st century schools (ACARA 2010, 5-19).
MUVEs are also omitted from DEEWR’s ‘Virtual Learning Environments’ report (2008, 25),
in favour of blogs, wikis, and interactive white boards. A word search for MUVEs on the
DER website in February 2011 produced no result other than to suggest it might be a
misspelling of ‘MOVES’. The search term ‘virtual world’ produced only one result; it was
used by the minister responsible – now the Prime Minister, Julia Gillard. In her 2008 address
to the Australian Computers in Education Conference, Gillard used ‘virtual world’
generically, describing it as a place where students ‘spend hours…downloading information,
playing games and socialising’ (Gillard 2008). Similarly, the term ‘immersive Internet’ and
words associated with it. Such as ‘virtual worlds’ are omitted from the Federal Government’s
landmark emerging technologies-for-open-government roadmap, ‘Engage: Getting on with
Government 2.0’ (DFD 2009).
That said, the funding and research landscape is abundant. Entities at the forefront of
developments include Smart Services CRC industry partners: the NSW Department of
Education and Training’s Curriculum and Learning Innovation Centre (DET CLIC) and the
Australian Academic Research Network (AARnet). Both are assessing virtual platforms for
near-future implementation in the K12 and higher education sectors.
AARnet, as the national provider of high speed broadband to the education and higher
education sectors sees the need for a timely and strategic approach, given academic
communities’ evolving interest in immersive technologies (Sankar 2010).
The 2008 University of Essex (UK) trials in which Open Wonderland was used as a
demonstrator for mixed and simulated reality learning environments (Gardner et al. 2008),
have helped to shape DET CLIC’s view that virtual environments do indeed extend learning
possibilities, and can be used to create ‘a robust, safe, learning platform where’ ‘natural’
collaboration is possible’ (Wood C 2009). DET CLIC’s plans to integrate immersive
technologies into its slate of education products such as the popular interactive online science
game ‘Murder Under the Microscope’ and continues to lobby its uptake in education policy
The Australian Learning and Teaching Council (ALTC) has funded a number of virtual
worlds research projects driven by UniSA’s Dr Denise Wood, including two disability access
projects worth upwards of $500k (Wood D 2009).
The Flexible Learning Network has a national allocation of $2.65m for 2011 innovative –elearning projects in the TAFE/Vocational training sectors, and it has a track record for
funding virtual environment projects (Flexible Learning Network 2010)
The Victorian Health Promotion Foundation (VicHealth) has funded two 3-year projects,
being the ‘Avatar Project’ (2009)) and ‘Connected Lives’ (Schutt 2009). The latter involved
children with disabilities, including autism, from Melbourne and Gippsland regions. Other
funding bodies supporting immersive service development include ARC, the Australian
Teachers Learning Council, Centre for Creative Industries (CCI) and NICTA. The Smart
Services Cooperative Research Centre has a dedicated Immersive Services stream, with the
iSee platform, its cornerstone as well as a QUT team under Dr Ross Brown, researching the
way virtual worlds can be used as workflow management systems, and a social research team
based at Swinburne University of Technology (SSCRC 2010).
At a state level, government agencies are looking to build broadband enabled services, and the
construction of its ICT project funds reflects this. In Victoria, for example, the Institute for a
Broadband Enabled Society (IBES) is developing a number of immersive and 3D projects,
particularly in the health domain (IBES 2010), and Multimedia Victoria (MMV), is
embarking on Round 2 of its ‘Collaborative Internet Innovation Fund’ (cIIF). Whereas Round
1 was designed to develop Web2.0 enabled projects, Round 2, announced in October 2010,
has a broader brief: to assist with the development of projects ‘dependant on characteristics of
the National Broadband Network such as its ubiquitous nature and high bandwidth’ (MMV
2010). A sum of $5m has been allocated. Further project funding may be available within the
context of the State Government of Victoria’s 2010 $110m dollar ‘ICT Action Plan’.
On the creative side, the Australia Council has funded a number of Second Life digital arts
projects, including $20k for ‘Babelswarm’ (Australia Council 2007), 30k for ‘MMuve IT’
(Australia Council 2010) and ongoing support for the Australian Centre of Virtual Art
(ACVA) which grew out of the Babelswarm project. The Council has also instituted a ‘Geek
in residence’ program, to service the digital component within creative practice. Screen
Australia, along with state film agencies jointly funds the Laboratory for Advanced Media
Production (LAMP) convened by AFTRS.
Screen Australia and Film Victoria have shown leadership with their joint ‘Serious Games
Initiative’ in recognition of the emerging market. This program attracted 53 applicants, a
significantly higher number than expected. Two projects were ultimately selected for
development (Financial Review, 2009). Given the interest and potential, the funds allocation
of $375k for 2009-10 is small, and suffers in comparison to the investment made by the
French Ministry for the Digital Economy program in which EU20m has been earmarked for
developing ‘serious games' ( 2009).
Looking at the wider services sector, support for the industry is adhoc. Virtual world
developers such as Keren Flavell (2009) and Bob Quodling of Simmersion (2008) point out
that their projects tend to fall between funding camps. This suggests that if Australia’s home
grown innovation is to flourish, there may be a case for recognising the immersive Internet as
an enterprise entity in its own right.
This paper is a response to the call by the Australian public, and an eager parliamentary
opposition, for a clear indication as to how the bandwidth supplied by the National Broadband
Network might be applied. The Government needs strong cases, clearly put. The muchvaunted ‘virtual classroom’ is an ideal case for arguing for super fast connection speeds as
taxpayers need little encouragement to approve policies that advantage their own.
MUVEs are contextualised with this broader agenda in mind. As flexible, editable,
interactive, shared online tools, they are part of our broadband future in which students will
extend their own learning by collaborating within shared networks.
Well over 100 Australian education institutions are now trialling virtual worlds, and among
members of education’s innovation circles, such as the Distance Education Hub (DEhub),
MUVEs’ attributes are well known. But, whilst individual projects are being supported, the
immersive Internet industry (services such as content makers, designers, consultants and
marketers) is not recognised as an ICT niche in its own right. This lack of identity may be
contributing to the immersive Internet industry’s failure to register on some strategic radars, 14
resulting in piecemeal rather than systematised take up. Further evidence to this case is the
apparent low level of government ICT purchases of in this bracket: MUVEs have only very
recently been directly mentioned (PLANE 2011) in DER projects, whereas, for example,
Microsoft’s and Adobe’s collaborative tools have been procured, and teacher training in their
use is underway. Although these tools currently have no interactive 3D component, they may
have found favour because of the way they integrate with existing government ICT, and for
the attractive procurement and service conditions on offer.
If MUVEs are being overlooked because their marketing and support teams cannot compete
with their big-tech counterparts, virtual classrooms run the risk of not reaching their potential;
users needs and the technology need to be built together. MUVEs cannot be replaced by other
collaborative tools as they contextualise human input into a computer by orientating it within
an interactive, editable, and graphically satisfying online 3D environment. Document sharing
or video conferencing cannot reproduce this experience. Projects at Melbourne Grammar
School and The Northern Beaches Christian College have been described in order to support
If negative perceptions are indeed an issue, then the fact that MUVE technology is still in its
early stages of development is the likely deterrent; stability, useability, security, integration
into existing IT, and the need to set standards continue to challenge the rate of take-up.
However, barriers to adoption such as maintenance and upgrades are being averted as services
transition to being browser-based and hosted in the data cloud. Already a next wave is
discernable, and whilst SecondLife is the lead platform in the education community, Open
Source platforms such as OpenSim, Open Wonderland and the Australian product VastPark
are well positioned for integrating third party applications, as well as for use behind a schools’
Developments in interoperability and content transfer between platforms are moving well
(IED 2010), as are moves towards an industry standard, known as X3D. This is welcome
news to developers and consumers as it means more flexible arrangements between
institutions, and the ability to share, migrate and re-purpose content.
There are many projects under the auspices of the Digital Education Revolution that could
assist the progress of MUVE product development and usage. the aforementioned PLANE
project appears to be in the early planning and development stage, and is unable to capitiise
onDER’s National Secondary School Computer Fund plans, in which children in upper
secondary levels (years 9-12) are to receive their own laptop computer by the end of 2011
(DEEWR 2010b). These are fitted with video cards and inbuilt web cameras, meaning that
these computers are capable of hosting most lightweight virtual world platforms. 15 Students
have the immersive tools at their fingertips but DEEWR is not optimally using them. This is a
lost opportunity. Even if educators are reticent to experiment, their students are not, for they
are already familiar with the play structure and protocols of MUVEs, due to MUVEs’ shared
attributes with online video games and entertainment virtual worlds, places where young
people like to be.16
So, the hardware is there, the pedagogy getting there, (it is being constructed by innovative
teachers who are conducting their own trials and experiments). What seems to be missing is
an understanding of the immersive Internet at the higher branches of the education tree. Could
it be that, like many of their fellow Australians, education’s decision makers need high
capacity broadband up and running before they will really understand the value in this new
service? MUVEs can run with existing ADSL 2 or cable broadband speeds 17, but where large
numbers are involved, or the MUVE platforms carry extra services such as rich media
streaming or high resolution video and graphics, bandwidth is quickly filled, and the
experience becomes unsatisfactory. This is a pity, because were MUVEs more widely used,
strategists within ACARA (Australia’s national curriculum project), and the offices of the
Digital Education Revolution (even the Prime Minister herself, who stridently engineered
both the DER and the NBN agenda in her previous portfolio) would be assured of some
timely insights, which could then be relayed to a nation looking for arguments in the NBN
debate that extend beyond the bottom line.
MUVEs are a good news story, but even better, is that unlike schoolbooks, it is the
communities of users, not the tools themselves, that give online virtual environments their
purpose and definition. The more virtual worlds are used, the quicker progress is made,
resulting in more robust platforms, an invigorated pedagogy, an industry of third party
services and applications, and a ‘real’ sense of the ‘virtual’ classroom.
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National Broadband Network (NBN)
The Department of Broadband, Communications and the Digital Economy (DBCDE)
A core feature of the Australian Government’s Digital Education Revolution, being
developed by an independent authority, the Australian Curriculum, Assessment and
Reporting Authority (ACARA) <>
The ‘Immersive Internet’ is a generic term for a range of computer-generated
environments, including virtual worlds and immersive learning and collaboration
platforms and virtual event platforms. The term was popularised by technology
consultancy firm ‘Thinkbalm (2008-2010) <>
‘In-world’ is a location term used to differentiate or clarify that a designated place is
not the physical one, but the virtual one.
Thinkers proposing this view include Henry Jenkins (2006) John Seely Brown (2009)
and James Paul Gee (2008)
Most virtual environments have a range of unique features. In the case of the social
online world Second Life, ‘regions’ are connected to each other, giving the
impression that land parcels adjoin one another. The user therefore senses that his or
her avatar is travelling, (by flying or ‘teleporting’) to other locations and
communities. Some locations are locked down and are not publicly accessible; the
Teen Grid, is one of these, and is subject to high-level security protocols so that
unidentified visitors cannot intrude.
Machinima is the term used to describe a video made of activities within the virtual
environment. It might be a constructed narrative that is ‘filmed’ using avatars as
actors, a recording of a live event, such as a conference hosted in a virtual
environment, or a training exercise. Many examples of machinima can be found on
the video sharing website YouTube, <>.
The IEI’s ‘Platform Eco-system’ comprises Open Wonderland, Open Cobalt, Open
Simulator (OpenSim) and realXtend and Sirikata, the latter being developed at
Stanford University
The degree of ‘immersion’ in respect to simulated online environments, equates the
number of services within the platform which heighten the sense of engagement, for
example a spatial audio program, high end graphics program, coupled with the
seamless transition and integration of scenes, situations and users’ input.
Bruce Joy CEO of VastPark reports that the company’s basic platform, without any
add-ons, has ’a footprint smaller than Skype’, (interview with the author, February
10, 2011).
As an example, Sprout Labs (2009), an e-learning platform developer based in
Tasmania, writes, ‘Our experience with the alcohol training simulation was pivotal in
discovering a limitation of the technology over a broadband connection. We
originally planned to create a video-based simulation of a conversation with a
drunken patron in which the learner had to pick up on non-verbal cues to decide how
intoxicated someone is. Video is the perfect medium for this. As the project
developed it became clear that working with video was just not possible with the
current bandwidth available to most learners. The learning experience had to be
reduced to text, which affected the richness of the learner’s experience’
In a number of discussions with the author, conducted 2007-2010, Bruce Joy, CEO of
the virtual collaboration platform VastPark, envisages holographic experiences for
users <>; Keren Flavell, former program director with
virtual worlds video capture company Treet TV, sees collaboratively-generated
entertainment programs on the horizon <>;Gary Hayes,
principal of MUVE design, a company which builds virtual environment content,
scopes a future of augmented reality embedded into social networking applications <
http://www.muvedesign/> .
For example, the ‘Broadband and Beyond’ conference, held in February, 2011, did
not refer to the immersive technology tools. <>
The laptops issued by NSW DET, the Lenovo IdeaPad S10e and the ThinkPad Mini
10 use the Intel Graphics Media Accelerator 950 and the Intel NM10 Express Chipset
200MHz graphics respectively (TALE 2010).
Barbie World, Lego Land, Club Penguin, World Of Warcraft, UltimaII, Everquest , to
name but a few.
In inner city Melbourne, cable broadband connection speeds regularly clock in at 6.9
Cite this article as: Salomon, Mandy. 2011. ‘Introducing multi-user environments into Australia’s
virtual classrooms: a value proposition for Australia’s National Broadband Network.
Telecommunications Journal of Australia. 61 (2): pp. 26.1 to 26.15.
Melissa McCarthy
The Royal Institute for Deaf and Blind Children
The Royal Institute for Deaf and Blind Children (RIDBC) provides specialist support to
children with a sensory disability, e.g., a vision or hearing impairment. Recent developments
in telecommunications technologies have enabled RIDBC to expand their services to better
support families and children living in regional and remote areas of Australia. This paper
outlines the challenges of accessing support in regional and remote areas, the innovative uses
of telecommunications technologies, the specific technologies that have been trialled, the
model of service delivery and the technologies currently in use.
The Royal Institute for Deaf and Blind Children (RIDBC) has been assisting children with a
sensory disability, e.g., a hearing or vision impairment, for over 150 years. Since it was
founded in 1861, RIDBC has been at the forefront of sensory disability, constantly striving to
find new and innovative ways of supporting children and their families. Hearing loss and
vision loss are both considered to be ‘low-incidence’ disabilities, however, these disabilities
are not restricted to densely populated areas. Hearing and vision loss affect the Australian
population indiscriminately, regardless of location. However, additional social and
environmental factors can lead some regional and remote areas such as indigenous
communities to be even more frequently affected by sensory disability (Senate Community
Affairs References Committee 2010).
Prior to the development of modern telecommunication technologies, families in rural and
remote areas of Australia had limited or no access to specialist support for their children with
a sensory disability. Families were often obliged to make long journeys to major metropolitan
centres to attend appointments with their children. The introduction of high speed broadband
and cellular networks has brought the city to the bush. Modern telecommunication
technologies have removed the burden of long journeys and provided families with greater
access to regular, intensive support with experts in the field of sensory disability. Not only
have new technologies provided access to these services locally, but many families now
utilise videoconferencing technology in their homes and access specialist support without
having to leave their lounge rooms.
Three major factors prompted the development of the RIDBC Teleschool program: the
importance of early intervention, the lack of expertise in regional and remote areas and the
vastness of Australia. It has been well documented that children with a sensory disability
require specialised early intervention support (Sass-Lehrer 2002). Research has also shown
that early diagnosis and intervention in children with hearing loss leads to more natural
language development (Yoshinaga-Itano et al 1998). For children with vision impairment or
blindness, early specialised intervention is needed in all areas of development and must offer
the child experiences and opportunities for independent and active learning (White and Telec
1998). Given the importance of early intervention for children with a sensory disability, there
is an urgent need for families to have access to early and intensive support. Due to the low
incidence of sensory disability, however, many families in regional and remote areas of
Australia do not have access to this kind of specialised support.
Recruitment, retention and ongoing professional development are additional issues that raise
significant challenges in regional and remote areas. These challenges exist across most
sectors; however, the impact is felt even more greatly in the area of sensory disability. Given
the highly specialised nature of sensory impairment, professionals require a specific and
unique skill set for supporting children with a sensory impairment. There are a limited
number of programs aimed at training professionals in the area of sensory impairment, and
consequently the number of professionals who are specifically trained to work in the field is
low. This limited supply of qualified professionals cannot meet the demand, which results in
many positions remaining vacant. Retention is also a challenge as professionals in regional
and remote areas are often expected to cover vast geographical distances and support
caseloads that are broad-ranging and encompass wide age ranges and varying levels of
complexity. In addition, specialists have difficulty accessing opportunities for professional
development, material and technical resources, and informational resources on recommended
or proven practices (Rude et al 2005). Professionals in these positions are often the only
professional in the area, and frequently experience a greater sense of isolation and lack of
support. The combination of these factors results in higher staff turnover in regional and
remote areas (Ludlow 2005).
The third key factor in the decision to create RIDBC Teleschool is related to distance. The
‘tyranny of distance’ is a well-known phenomenon in the Australian context. In area,
Australia is the world’s sixth largest nation but in population, Australia is home to just 21
million people (Department of Foreign Affairs and Trade 2008). Two-thirds of the population
live in major cities as defined by the Australian Bureau of Statistics, while the remaining onethird of the population live in regional and remote areas. For this segment of the population,
access to specialist services is severely limited. A Parliamentary Report released by the
Federal Government in 2002 highlighted the limited expertise available in regional and
remote areas of Australia, particularly in the area of sensory disability (Employment,
Workplace Relations and Education Committee 2002). In order to access professionals in the
area of sensory impairment, families have generally been obliged to travel great distances to
attend appointments at specialist centres in the nearest major city. In some cases, families
have even relocated to major cities to avoid the costs and time involved in such frequent
These three factors – importance of early intervention, lack of expertise and distance –
combined to highlight a significant gap in services for regionally and remotely located
families whose children were diagnosed with a sensory impairment.
Historically, families living in regional and remote areas of Australia received limited, if any,
support for their child’s sensory disability. Support was generally provided through
correspondence courses, infrequent outreach visits by specialists or by undertaking long
journeys to major cities. RIDBC sought to improve the equity of access to disability services
through the use of emerging telecommunications technologies. By the late 1990‘s, advances
in mainstream telecommunications technologies provided the means to connect families with
professionals using real-time two-way audio and video transmission. RIDBC initially
developed a program which relied on existing Integrated Services Digital Network (ISDN)
connections to link families in the country with professionals in the city. These ISDN
connections were often found in hospitals and community health centres. Families reported
satisfaction with the support they received via videoconference but reported challenges with
the locations and scheduling. Consequently, RIDBC sought alternatives to the ISDN lines and
explored the use of broadband to provide videoconferencing directly into family homes.
Technologically speaking, videoconferencing is a very demanding task and requires fast
upload and download speeds at both the sending and receiving ends of the connection. For
best results, videoconferencing also requires the upload and download speeds to be equal to
each other. In 2004, Symmetric Digital Subscriber Lines (SDSL) met these requirements and
RIDBC began trialling the use of SDSL in family homes. The SDSL connection was coupled
with dedicated videoconferencing equipment which included a camera, a codec and a
microphone. This equipment was then connected to the family television. The use of SDSL
was successful in terms of speed and quality, but the technology also raised new challenges.
In most cases, it was necessary to install an additional phone line that could be dedicated to
videoconferencing. Installation in rural and remote areas often took three to six months with a
further one to three month waiting period for an Internet service to be assigned to this
dedicated phone line. Once the telecommunications technology was in place, a staff member
from RIDBC would travel to the family home and install the dedicated videoconferencing
equipment. This process was time consuming and costly and meant that families were not
getting immediate access to the support they needed. After trialling this approach with ten
families, RIDBC decided to investigate other options.
In 2007, RIDBC began evaluating the possible use of the Telstra 3G network to transmit
videoconferencing sessions. The introduction of the 3G network in regional and remote areas
offered new potential for RIDBC to connect to families and a small pilot project with three
families was undertaken. Installation times were dramatically decreased as families did not
need to wait for a second phone line to be installed nor did they need to wait for the
subsequent installation of an Internet connection. Instead, a specially-designed modem/router
and a Telstra SIM card were connected directly to the videoconferencing equipment and an
aerial was used to boost the signal. Again, the videoconferencing equipment was connected to
the family television. The availability of 3G connectivity in most regional and remote
locations eliminated the need for an additional phone line, which had been the major barrier to
the immediate installation of in-home videoconferencing equipment. The biggest limitation of
the 3G solution became the availability of equipment and the associated delivery times.
However, even taking this into account, families could now be connected to a specialist in
sensory disability in a matter of weeks instead of months. From the success of this project, the
new RIDBC Teleschool was born and the number of families using in-home
videoconferencing grew exponentially.
Connection type
studios at hospitals
or community
health centres
(sites already
in the family home
Second phone line,
Internet connection,
four to nine
in the family home
Router/modem, 3G
SIM card, aerial,
four to nine
Table 1 - Telecommunications technologies trialled by RIDBC Teleschool between 2002 - 2007
The staff at RIDBC Teleschool is composed of highly qualified and experienced
professionals. They encompass a wide range of expertise, including numerous subspecialty
areas related to sensory disability. These professionals are based in Sydney and connect with
each family via videoconference on a weekly basis to provide one hour of regular, intensive,
specialist support. Families are provided with lesson plans and materials via the post or email
depending on the needs of the child. Weekly videoconferencing sessions are supplemented
with phone and email contact. Local professionals are often involved in weekly sessions.
Benefits for local professionals include an increase in their understanding of sensory
disability, access to professional development, information about recommended practice in
sensory disability and a decreased sense of isolation. Families also benefit from the
participation of local professionals, as this provides a more cohesive and coordinated
approach to supporting the child and family. RIDBC Teleschool is currently supporting 165
families in all states and territories of Australia and videoconferences are now delivered
through three distinct transmission methods: ISDN, 3G/NextG and broadband.
Our early trials with videoconferencing demonstrated that ISDN videoconferencing provides
a reliable connection. ISDN lines are generally located in an existing studio, which means that
families can begin accessing services almost immediately. Additionally, existing sites
typically employ a technical support person who can assist the family and alleviate any
concerns about operating the technology. ISDN is currently the preferred transmission method
for newly enrolled families at RIDBC Teleschool as it is reliable, accessible and supported by
local technical staff. However, ISDN videoconferencing does have some limitations. As we
discovered in our early trials, the existing studios are frequently configured in a boardroom
setting designed to facilitate meetings by videoconference. This is not an ideal configuration
for working with young children and families can feel constrained by the setting. Scheduling
can also be complicated depending on how frequently the site is used. For example, in some
locations the videoconferencing equipment is located in a multi-purpose room that is also
used for meetings and events, thereby limiting the availability of the videoconferencing
equipment. Finally, most sites charge an hourly fee for the use of equipment and room hire.
While fees vary from site to site, the use of ISDN lines is generally the most expensive
transmission method used by RIDBC Teleschool.
The 3G pilot project provided a proof of concept for further implementation.
Videoconferencing equipment, a modem/router, an aerial and set-up instructions are sent via
courier to the family. The equipment is set up by a local installer who contacts RIDBC
Teleschool to confirm the installation. The ease of installation facilitates the rate of
implementation. Once installation is complete, the family can commence weekly
videoconferencing sessions to access the specialist support needed for their child’s sensory
disability. Data is transmitted at a rate of 384 Kilobits per second (Kbps). Although higher
speeds are possible, this rate is sufficient for videoconferencing and often provides a more
stable connection than higher speeds. Families who have had experience with ISDN
videoconferencing quickly develop basic technical skills in operating and troubleshooting the
in-home 3G equipment. More advanced technical issues can often be resolved remotely by
RIDBC staff. This can be achieved by providing phone support to the family or by remotely
accessing the settings on the family’s equipment. Families value the opportunity to work in
their home environment and this is evident in family participation and child engagement.
While the up front costs for equipment and installation can be significant, the equipment can
be re-allocated as families leave the program.
The introduction of high speed broadband has led RIDBC Teleschool to explore yet another
transmission method. Broadband technology is being used in two distinct ways: with
computer-based conferencing and with dedicated videoconferencing systems. Computerbased videoconferencing takes place using programs such as Skype or Sightspeed. Families
use their own Internet connection to download one of these programs onto their computer. If
necessary, RIDBC Teleschool will provide families with a webcam. The effectiveness of this
method relies on the speed of the family’s Internet connection. As with 3G/NextG
technology, the preferred rate of transmission is a symmetric speed of at least 384Kbps. Since
many home Internet services have asymmetric upload and download speeds, it can be difficult
for families in regional and remote areas to attain the necessary speeds. Also, home Internet
plans can be limited by the amount of data that can be downloaded. As videoconferencing
transmits large amounts of data, families can find they quickly reach their monthly download
Alternatively, some families may use a dedicated videoconferencing system with their own
broadband connection. In this setup, the camera is connected to the family’s Internet rather
than a 3G modem/router. The family enters a specified IP address into the camera’s address
book and can then connect directly with RIDBC Teleschool. Although using a dedicated
videoconferencing system with broadband can result in similar issues to computer-based
videoconferencing, there are also some distinct advantages. The picture quality of the
dedicated camera is superior to a webcam. The dedicated camera also has a greater range of
pan/tilt/zoom features, which enhance the videoconference. Furthermore, RIDBC staff can
control the dedicated camera remotely. This functionality alleviates the technical concerns of
many families. Broadband transmission is by far the least expensive option currently available
to RIDBC Teleschool. Unfortunately, broadband access is currently limited in most regional
and remote areas. The implementation of the National Broadband Network will hopefully
result in greater availability of broadband service in these areas and ultimately, an increase in
the use of this transmission method for videoconferencing.
existing studios at
hospitals or
community health
(sites already
in the family
Router/modem, 3G
SIM card, aerial,
four to nine
Broadband with
computer based
e.g., Skype
in the family
Home Internet
connection, computer,
webcam and
Broadband with
in the family
Home Internet
connection, dedicated
one to four
Table 2 - Telecommunications technologies currently in use at RIDBC Teleschool
Since 2002, RIDBC Teleschool has used telecommunications technology to connect more
than 250 families to much-needed support for their child’s sensory disability. Over 100 of
these families have benefited from in-home videoconferencing. Family satisfaction is
evaluated annually through an anonymous survey. In a recent survey, 97 surveys were sent
out to families enrolled in RIDBC Teleschool. 52 of these surveys were returned, with all
families indicating that RIDBC Teleschool has made a difference in their lives and they
would recommend the program to others.
As a direct result of engagement in this program, families demonstrated greater confidence
concerning their child’s sensory impairment, improved their knowledge and understanding of
sensory impairment, developed a sense of empowerment in supporting their child's needs and
strengthened family and child competence through increased communication. 100% of the
families responding expressed the benefit of accessing a service that offers expert knowledge
and specialised resources while reducing the burden of travel on the family.
These families also indicated that RIDBC Teleschool provided guidance, and ongoing,
regular support for their child’s sensory disability, which made them feel less isolated in their
regional and remote communities. Families appreciated the immediacy of feedback resulting
from the real-time transmission of audio and video of both the child and the professional. The
staff at RIDBC Teleschool also value this two-way communication as they are able to make
more timely and responsive therapy recommendations based on their own observations rather
than relying on the reports of others.
The range of benefits reported by families could not have been achieved without the increased
accessibility provided by telecommunication technology. In fact, families have indicated that
their experience with videoconferencing has been so positive that they would value the use of
the telecommunications technology to access specialists in other disciplines.
RIDBC Teleschool has pioneered innovative uses of telecommunications technologies in an
effort to overcome the barriers of distance, geographic isolation and inequity of access. By
reflecting on the challenges that exist for families in regional and remote areas and exploring
possible solutions, RIDBC Teleschool has developed a model of service delivery that
provides regular, intensive specialist support for children with sensory disabilities. The
success of RIDBC Teleschool clearly demonstrates the tangible benefits that
telecommunications technologies can bring to those living in regional and remote areas.
Prior to the mainstream acceptance of telecommunications technologies, families living in
regional and remote areas of Australia were at a distinct disadvantage with regard to accessing
support for their child’s sensory disability. The challenges typically faced by professionals in
remote communities, e.g., vast distances, large caseloads and diverse client needs, made it
difficult for those communities to provide the range and quality of services needed by
children with sensory impairment. In addition, staff in regional and remote areas often felt
isolated and lacked opportunities for ongoing professional development resulting in higher
staff turnover in those areas (Ludlow 2008). These circumstances meant that families
frequently had to access support in alternative ways, such as correspondence courses or
travelling great distances to the nearest major city.
The availability of telecommunications technologies means that families can now access
experts in the field of sensory disability regardless of their location. Families are able to
receive greater continuity and consistency of services as staff based in metropolitan areas
have lower rates of turnover than regional and remote communities (Ludlow 2008). Families
no longer face restricted choices for supporting their child’s sensory impairment. Families can
now access professionals who have the experience, specialist qualifications and knowledge of
specific subspecialty areas that were not previously available to them.
RIDBC Teleschool is constantly striving to find new and innovative ways of supporting
children with sensory disability and their families. For the last ten years, RIDBC has focused
on the innovative use of telecommunications technologies to address the needs of families in
regional and remote locations. Investigation and evaluation of various transmission methods
has led to quicker and easier installations for families as well as more reliable connections.
With further advancements in telecommunications technology, such as high-definition
capability and the National Broadband Network, an increasing number of families in regional
and remote areas will be able to access specialist disability support without leaving their
homes. In the future, a model similar to that of RIDBC Teleschool could be applied to many
other areas of disability, health care and education thereby eliminating the barriers of distance
and inequity so frequently faced by families living in regional and remote locations.
Australian Bureau of Statistics. 2009. ‘Australian Social Trends, 2008.’ Accessed 13 January
2011. Available at
Department of Foreign Affairs and Trade. 2008. ‘Australia in brief’. [Internet] Accessed 13
January 2011. Available at /aib/island_continent.html
Employment, Workplace Relations and Education References Committee. 2002.
‘Parliamentary Report on Education of Students with Disabilities. [Internet] Accessed on
12 January 2011. Available from:
Ludlow, BL; Conner, D.; Schechter, J. 2005. ‘Low Incidence Disabilities and Personnel
Preparation for Rural Areas: Current Status and Future Trends’. Rural Special Education
Quarterly. Accessed online 12 January 2011. Available at:;col1
Rude, H; Jackson, L; Correa, S; Luckner, J. 2005. ‘Perceived needs of students with lowincidence disabilities in rural areas’. Rural Special Education Quarterly, 24 (3): 3-14.
Sass-Lehrer, M. 2002. ‘Early beginnings for families with deaf and hard of hearing children:
myths and facts or early intervention and guidelines for effective services’. [Internet]
Accessed on 12 January 2011. Available from:
Senate Community Affairs References Committee. 2010 ‘Hear us: Inquiry into Hearing
Health in Australia’. Parliamentary Report, 121-127. Senate Printing Unit, Parliament
House; Canberra.
White, G; Telec, F. 1998. “Birth to school.” In Towards excellence: Effective education for
students with vision impairments; edited by Pat Kelley and Gillian Gale, 103-117. North
Rocks, Sydney: North Rocks Press.
Yoshinaga-Itano, C; Sedey, A; Coulter, DK; Mehl, AL. 1998. ‘The language of early – and
later – identified children with hearing loss’. Pediatrics, 102:1161 – 1171.
Cite this article as: McCarthy, Melissa. 2011. ‘Using technology to support children with sensory
disability in remote areas: the RIDBC Teleschool Model’. Telecommunications Journal of
Australia. 61 (2): pp. 27.1 to 27.7.
Robert Morsillo
Swinburne University of Technology and Telstra Corporation Limited
“What may be gained from thinking about disability and technology differently is potentially a
great deal more than commonly thought” (Goggin & Newell 2004, 419). Almost all the policy
and politics surrounding the NBN to date have been concerned with supply-side issues
pertinent to building the network to ensure the universal availability of broadband services.
However, there has not been any specific affordability or accessibility policy considerations to
address the needs of people with disability as a particularly interested user group. People with
disability can showcase and lead consumer demand for the high capacity broadband
capabilities of the NBN given their desire and need for immersive multi-media based
communications. This paper suggests some options to address these issues utilising current
policy levers available to the Australian Government, including the Universal Service
Obligation and the National Disability Strategy.
…what has yet to be addressed is the economics of denying or constraining
accessibility for people with disabilities, or, the converse, of designing technology
for a wide diversity of users – and what this means for national policy (Goggin &
Newell 2004, p. 418).
The National Broadband Network (NBN) is a new Australia-wide high capacity broadband
infrastructure project initiated by the Rudd Labor Government in 2009, which is intended to
bring 100Mbps capable fibre-to-the-premise (FTTP) connectivity to nearly all Australian
households, small businesses and schools. Those not receiving fibre connections (about 7%,
mainly in regional and remote areas) will be served by 12Mbps terrestrial wireless or satellite
connections (Conroy 2009).
There has been considerable contention about the project, including about its cost, its benefits,
whether Australians need such a “gold-plated” solution, the new regulated industry structure
that comes with the NBN, and the role of the incumbent telecommunications service provider,
Telstra Corporation Limited (Telstra).
There has also been a great deal of discussion about the wisdom of mandating a particular
type of delivery technology at this time. For example, the rising popularity of wireless
broadband and smart-phones, and the potential of 4G wireless technologies such as LTE
(Long Term Evolution) to offer high capacity data connections, provide much fuel to heat the
debates (see for example Given 2010b).
This paper does not intend to enter into these supply-side economic and technology debates
about whether the NBN is a good idea or not. Rather, its starting point is the very likely and
imminent implementation of the proposed FTTP technology, despite some significant hurdles
still to be overcome (cf. Telstra Corporation Ltd 2010b).
Back in 2005 Goggin and Milne claimed:
…there is little consideration of consumer or social issues in the formal evaluation
of telecommunications policy, especially in relation to structural adjustment. There
is a need for greater research and analysis of these issues, particularly using social
science and public policy approaches (Goggin & Milne 2005, 29).
There is no doubt that the NBN is a major “structural adjustment”. In fact, “It’s a total rejig of
a nation’s communications infrastructure, top to bottom” (Kohler 2010). There is, therefore, a
need to consider and evaluate issues for people with disability as expected consumers of NBN
delivered services, and to then decide whether telecommunications policy needs to be
adjusted accordingly. In the current context, this is a positive undertaking, since it seeks to
understand the key factors that will help make the NBN technology successful, including for
people with disability.
While previous discussions in the Telecommunications Journal of Australia (TJA) about
broadband services and people with disability point to the considerable opportunities that high
capacity connections can bring (see in particular Slater et al 2010; Wood 2010), in recognition
of Christopher Newell we cannot allow disability and the NBN to be “conceptualised as a
specialised, technical issue” (Newell 2005). This paper, then, examines key factors that may
hinder the success of the NBN for people with disability and proposes some enablers through
incremental improvements to current public policy considerations, in particular the Universal
Service Obligation (USO) and the proposed National Disability Insurance Scheme (NDIS).
A summary of the paper and its argument is as follows:
Telecommunications networks create significant social and economic externalities,
which may justify government supply-side infrastructure investments. However, these
benefits can only be realised if there is significant take-up of the technology, the
network effect, which could also justify government demand-side social inclusion
People with disability are significantly under-represented in the access to and use of
the Internet, and there is a lack of government policy discussion on affordability and
accessibility that particularly impacts this group. However, people with disability can
showcase and lead consumer demand for the high capacity broadband capabilities of
the NBN given their desire and need for immersive multi-media based
USO policy and the role of USO Co needs to be incrementally bolstered and the
NDIS needs to be fully utilised to enable people with disability to gain access to the
benefits of NBN connectivity.
A distinguishing characteristic of telecommunications technology is the presence of
significant network externalities. For this reason, investment in telecommunications
infrastructure might be expected to yield relatively high social returns. This also
provides the case for government investment (Williams 2010, 176).
The recent return of government proposals to invest heavily in new telecommunications
networks has already been described in some detail (Given 2010a). This changing politicaleconomic context results in “complex forms of ‘public private interplay’” that demonstrate
three trends:
First, they represent shifts away from the liberalisation and privatisation policy
consensus that dominated the last two decades. Second, they show a shared
conviction about the anticipated size of fast broadband’s economic and social
benefits … Third, they reveal the unlikely impact of the global financial and
economic crisis in stimulating investment in particular infrastructures seen as
critical to the national economies that will emerge from it (Given 2010a, p. 541
emphasis added).
It is not the intention of this paper to further argue this general consensus on the economic
and social surplus produced by telecommunications networks (cf. Birke 2009; Endres 2010).
However, it is important to note that such benefits only arise when the network is fully
extended in a number of ways. For example, Williams goes on to note in regard to economic
growth, “high rates of return occurred only when there was close to universal coverage”
(Williams 2010, 176). While the NBN will eventually achieve universal availability, this does
not guarantee the required levels of take-up and usage by consumers to realise its benefits.
Allen’s analysis of “new telecommunications services” seems particularly pertinent here, “…
when network ‘newness’ is fullblown and network externalities and critical mass play their
largest role. Full motion videoconferencing is a case in point; so would be an interactive
broadband service to the home” (Allen 1988, 258). At issue is the “perceived value” of the
new network by consumers, when it is small and/or has very few people connected. Allen
notes that such externalities place the emphasis on supplier incentives, such as introductory
pricing, to ensure success in reaching critical mass. As we shall see, affordability is a critical
issue for people with disability.
Early indications of interest from the NBN pilot sites give a mixed picture, even at the initial
physical connection stage. In Tasmania, the low rate of connection requests (“only half”)
prompted the State Government there to consider switching to an “opt-in” default for
properties passed by the new optical fibre infrastructure (Neales 2010). Initial results from
Brunswick, Victoria, are similar (compared, however, to an average of 70% across five pilot
sites). This may be due to the high incidence of renters in such an inner-city area (Gannon
2011). Initial evidence from overseas shows lower than hoped for take-up rates for fibrebased broadband networks, though with only “phase 1” type services available (KPN 2009,
20; Morgan 2010, 3).
In some cases it may not be the overall network size that matters but take-up within a person’s
local and/or social network that may be more important. This is relevant to people with
disability, such as the (capital D) Deaf community who use Auslan (Australian Sign
Language) as a preferred mode of communications. Overall critical mass for a network can be
achieved through aggregating a number of specific networks of users that are successful in
reaching their own suitable usage thresholds. There is then an argument for the “targeting of
specific niches as a viable marketing strategy to overcome the disadvantage of smaller
network size” (Birke 2009, 788).
Finally, there is the important role of complementary devices, applications and services, and
markets that will utilise the NBN technology in specific user environments, such as health and
education. “It is impossible to precisely measure the costs and benefits of the NBN. Many of
the benefits will depend on complementary investments by the government or private
companies” (Gans & King 2010, 183).
In conclusion, while the NBN will eventually provide universal availability of high capacity
broadband, there remains the challenge of gaining the critical mass of users that will generate
the network effects that maximise the economic and social benefits of this new technology.
As we shall see, people with disability who have strong local and/or social networks, and who
value rich multi-media modes of communications and engagement, may be able to play an
important leading role in giving effect to the new network, especially since “One-in-five
Australians report a disability” (Australian Bureau of Statistics 2003).
The NBN has the potential to greatly improve the communications options available to people
with disability and on that basis to greatly improve life-style choices relating to family and
community engagement, employment, education, health care and entertainment. For example,
evidence provided to the Federal Communications Commission in the USA cites
opportunities for telecommuting, running a business from home, telerehabilitation, online
education and digital books, Video Relay Services (VRS) and even “the development of an
independent autistic community and culture” (Lyle 2010, 4-5). Goggin also notes the potential
for innovation in “expression and communication” by people with disability using the
Indeed, the new media has meant that many groups who found it difficult to find the
means, and cultural backing, to express their ideas, have found innovative ways
using the Internet especially to do so. There is a great tradition, for instance, of
Blind people devising their own media forms, from Braille to Radio for the Print
Handicapped. Or Deaf people developing a rich cultural tradition based on visual
communication and sign language. The multimedia potential of the Internet extends
the potential for new, far-reaching forms of expression and communication (Goggin
More specifically, innovative communications solutions such as audio-description, signing,
sub-titling, spoken sub-titles, vide-calling and relay services could be made possible with the
convergence of high capacity broadband and the television set (Slater et al. 2010). There is
the potential (if accessibility is addressed) for people with disability to participate in an
immersive way in online communities of interest, such as Second Life, with their own
preferred representations of themselves (Wood 2010).
People with disability often represent distinct user environments with distinctive
communications needs and opportunities. The Deaf may particularly utilise text but also seek
video-based services that allow communication in Auslan. The Blind may particularly utilise
voice and audio-based services, such as downloading talking books, and listening to (Internet)
radio stations such as Radio for the Print Handicapped (RPH). People with hearing loss may
seek a combination of text, or captioning, together with audio for their media and
communications. People with disability who are isolated for long periods of time at home, and
their carers, may choose online communities of support, including immersive experiences
through video and/or 3D facilities such as Second Life.
It is these types of rich, interactive, multi-media, instantly on services that showcase the
benefits of high capacity broadband. It is these types of needs and opportunities that can drive
demand for the NBN, particularly in its early stages. However, it appears these benefits are
not easily achieved for people with disability given the results with first generation
[I like] to have the Internet and a mobile phone and a house phone, that's a big bill
right there. I pay about $90 a fortnight just to keep my computer and the phones
running (Merrett 2010, 128).
Information about broadband Internet take-up by people with disability in Australia is limited.
For example, 2003 is the most recent Australian Bureau of Statistics (ABS) survey of
Household Use of Information Technologies, which reported that 39% of people aged 15
years or over with a disability had accessed the internet (Australian Bureau of Statistics
2004). This compares to 58% of the general population at that time (National Office for the
Information Economy 2003, 4).
Benchmark research undertaken at the end of 2002 for Telstra’s Low Income Measures
Assessment Committee (LIMAC) found that 23% of people with disability had internet access
at home compared to 37% for the general population, with cost being cited as the major factor
(Telstra Corporation Ltd 2002).
By the beginning of 2006 the LIMAC research found that take-up of the Internet at home by
people with disability had increased only marginally to 27% compared to 67% for the general
population (see Chart 1). Cost was still seen as the main barrier: “Disabled respondents [sic]
experienced the lowest ratings on Internet affordability” and “Perceived affordability of
Internet is lowest of all services” (fixed, mobile, Internet). Significantly, this was in contrast
to other low income groups such as older people, people who are unemployed and low
income families, where take-up of the internet had increased much more significantly (Telstra
Corporation Ltd 2006).
Chart 1 - Differential increases in home Internet take-up 2002-2006 for Australians on a low income
H o m e in t e r n e t t a k e -u p 2 0 0 2 a n d 2 0 0 6
Low-income families
Older people
Source (Telstra Corporation Ltd 2002 and Telstra Corporation Ltd 2006)
This Australian data is consistent with more recent findings from Britain, obtained as part of
the World Internet Project:
Disability, such as a health-related problem, remained a key source of digital
exclusion. The use of the internet by people with a health problem or disability
increased, but only marginally, between 2007 and 2009 (Dutton et al 2009, 17).
While not conclusive, this take-up data suggests that people with disability access the internet
at significantly lower rates than the general population and that usage over time has been
increasing at a much lower rate than for the general population and even for other low-income
groups. This may indicate that price-income-affordability is not the only significant barrier to
take-up for this group.
Of course, some people with disability have been early adopters of technology. In the USA,
surveys have found that “Seventy-two per cent of people with disabilities are likely to
upgrade to a product’s latest model” (Hannah 2008). This might even be glimpsed in the takeup statistics that we do have in Australia, where “The majority of Disability Respondents who
have access to the Internet are connected to a broadband service” (Telstra Corporation Ltd
“While the NBN’s fibre, wireless and satellite networks may provide universal availability of
broadband in a technological sense, this does not automatically mean universal affordability
and accessibility of a service” (Australian Communications Consumer Action Network
2010a, 4).
Almost all the policy work surrounding the NBN to date has been concerned with supply-side
issues pertinent to building the network. While this will ensure the universal availability of a
basic entry-level broadband service, there has not been any specific affordability or
accessibility policy considerations that might address the needs of people with disability as a
particularly interested user group. What is at stake is a repeat of the situation that dogged the
previous universal network, the copper based Public Switched Telephone Network (PSTN),
where accessibility policies didn’t come till the mid-1990s and affordability policies until
2002, many decades after telephones had become widespread in Australian homes.
Affordability has featured from the very beginning in the Australian Government’s general
announcements about the NBN: “…every house, school and business in Australia will get
access to affordable fast broadband (Conroy 2009, emphasis added); and most recently, the
NBN will “deliver significant improvements in broadband services for all Australians at
affordable prices” (Australian Government 2010, emphasis added).
The NBN Implementation Study specifically commented on the relationship between
affordability and take-up, recommending that “Wholesale prices for NBN services should be
set to meet the goals of affordability and take-up” (McKinsey & Company & KPMG 2010,
32). The suggestion was that this could be achieved through the provision of an entry-level
plan. The recent Government Statement of Expectations for the NBN explicitly mentions the
need for “maintaining affordability to drive take-up rates” (Wong & Conroy 2010, 10) and,
indeed, the NBN Co Business Plan makes provision for a basic 12Mbps/ 1Mbps “entry-level”
service across all delivery platforms (fibre, terrestrial wireless and satellite).
However, the actual retail price of this entry-level plan, as offered by a Retail Service
Provider (RSP), will depend on a range of factors. NBN Co modelling indicates that $56 per
month is a median benchmark figure (NBN Co Limited 2010, 105). The significant issue for
people with disability (and other people on a low income) is that this may significantly raise
the bar on the minimum price of any service delivered over the NBN, even just a Plain Old
Telephone Service (POTS).
Current market offerings for entry-level broadband plans begin at $9.95 per month (albeit in
conjunction with other bundled services) and the majority of subscribers are on low-end,
cheaper, plans (Australian Bureau of Statistics 2010). The current entry-level telephone
service (Telstra’s HomeLine™ Budget) is priced at $20.95 per month. The major reason for
the availability of these lower entry-level prices is the greater potential for marginal cost
pricing on the established networks because they are a sunk (depreciated) investment and are
relatively fully utilised. This will not be the case for the NBN for many years.
Once the NBN is constructed, marginal cost pricing will maximise economic
benefits. However, as the NBN is likely to have average costs well above marginal
costs, at least until it reaches capacity, marginal cost pricing for wholesale access to
the NBN will not cover capital costs or lead to a commercial return (Gans & King
2010, 182).
Also, affordability has a number of dimensions, not just the monthly price. There is the cost
of acquiring and maintaining relevant access equipment such as a desktop computer, or a WiFi router with a laptop or tablet device (such as an Apple iPad). Then there is the cost of
acquiring and maintaining the required software applications that may provide useful
accessibility features for people with disability, such as screen-reading software (e.g., JAWS
1989) or specialised Augmentative and Alternative Communication (AAC) software based on
visual symbols (e.g., Proloquo2go 2009).
Further, even NBN based entry-level plans for broadband may not be adequate for the
reasonable requirements of people with disability, for example, who participate daily in
immersive online communities such as Second Life, which might require 50GB or more per
month. This raises the question of when do the perceived costs of disability become an issue
of discrimination, rather than of affordability.
Australia was one of the initial signatories to the United Nations Convention on the rights of
persons with disabilities (the Convention) on 30 March 2007. Article 9 Accessibility includes
specific obligations:
(g) To promote access for persons with disabilities to new information and
communications technologies and systems, including the Internet;
(h) To promote the design, development, production and distribution of accessible
information and communications technologies and systems at an early stage, so that
these technologies and systems become accessible at minimum cost.
Given the significance of the NBN and associated ICTs to all Australians, the applicability of
the Convention is very clear. Yet there is little indication that public policy will seriously
address the accessibility issues of this new technology for people with disability. For
example, the only reference to “disability” at relates to the accessibility
of their website.
The one exception (which proves the rule?) arises in transitioning the USO to the NBN
framework. Specifically, reference is made to the disability requirements of the Standard
Telephone Service (STS) where a voice service is not practical for a particular end-user with a
disability; to Telstra’s Disability Equipment Program (DEP) that supplies the equipment to
fulfil that requirement; and to the Disability Discrimination Act 1992 that places
responsibilities on service providers in general (Department of Broadband Communications
and the Digital Economy 2010).
At the very least, there is an opportunity to make explicit these accessibility requirements for
telephone services supplied over the NBN by any RSP, not just Telstra as the USO provider.
This issue arises because of a current loophole whereby service providers who are not the
USO provider can refuse supply to a person with a disability and take their chances under the
DDA, which places a significant onus and liability on the customer to fight their case (cf.
Newell 2003).
If it is worth considering integrated and comprehensive national responses to
technology, such efforts must genuinely incorporate people with disabilities, their
needs, desires, and expectations. Incorporation of disability into universal service
policy is an obvious place to start … disability can be fruitfully inserted into
national policy on innovation systems, technology, and economy (Goggin & Newell
2004, 419).
The NBN will, in and of itself, provide universal availability, in a geographic sense, of a basic
broadband data service: “Access to fast broadband … will put distant towns on an equal
footing with people in major cities” (Gillard 2010). This will, in effect, extend the current
USO to such a data service, which is a higher level of capability than currently provided
under USO or Digital Data Service Obligation (DDSO) requirements.
Of course, the geographical equity focus of USO policy has been documented as far back as
1993 (Consumers' Telecommunications Network 1993) and so the perceived divide between
the city and the bush continues to impress itself on Australian telecommunications policy. Has
the NBN, then, effectively subsumed the USO? Given argues that the NBN heralds the
“eclipse” of USO policy in Australia.
As the political imperative shifted beyond voice telephony and basic digital data
capability to higher speed broadband, it was impossible merely to tweak the
architecture of universal service and asymmetric obligations on the former
monopolist. The cost was simply too large (Given 2008, 98).
However, Given does not consider the adjunct and related issues of universal service
accessibility for people with disability and affordability for people on a low income.
Accessibility was addressed after the 1995 disability discrimination complaint ("Geoffrey
Scott v Telstra Corporation Limited" 1995) by uplifting the requirements of the DDA into the
Telecommunications (Consumer Protection and Service Standards) Act 1999 to ensure that
the USO-STS (Universal Service Obligation for the Standard Telephone Service)was an
accessible service. This included the funding, by way of an industry levy (similar to the USO
levy), of the National Relay Service to provide relay services between voice and text
communications users (National Relay Service 1999).
Affordability of the USO-STS was addressed in part by the introduction of the Telstra
Carrier Charges–Price Control Arrangements, from 1995, and more specifically by a
Carrier Licence Condition (Telstra Corporation Limited), clause 22 Low-income measures,
from 2002. Telstra's Access for Everyone package incudes such programs as a pensioner
discount, which is applicable to many people with disability, and safety-net services for
people experiencing financial hardship.
The USO therefore was extended, if in a piecemeal way, to cover aspects of accessibility and
affordability of the STS. Since Telstra was the only nominated USO-STS provider, it has
borne most of the regulated responsibility.
With the advent of a new universally available minimum standard broadband service,
courtesy of the NBN, history would indicate that much better consideration should be given to
the role of USO policy in maximising take-up through affordability and accessibility
initiatives. While current USO discourse is dominated by cost calculations and therefore
restricted to residual availability issues, there is an opportunity to reframe it as supporting
critical take-up thresholds to ensure the success of the NBN, which presumes a different
discourse about affordability and accessibility, and so economic and social benefits.
In regard to affordability, discussions need to take place regarding safety-net services that
allow people to remain connected in a basic way when the NBN entry-level service is simply
seen as unaffordable. USO Co could consider whether some form of InContact ® (a Telstra
basic phone service) is required, for example, in situations of financial hardship, and whether
this could be extended to a basic Internet service that still allows access to government
services such as job seeking.
In regard to accessibility, discussions need to take place to ensure that standard telephone
services supplied over the NBN, by any RSP, have suitable accessibility options. Required
equipment to meet this requirement could be delivered by an Independent Disability
Equipment Program, something that has already been the subject of a feasibility study
(Department of Broadband Communications and the Digital Economy 2009). Further, now
with a new and different entry-level service (a broadband service) supplied everywhere over
the NBN, accessibility of end-user equipment might also be usefully considered in this same
context. This could include suitable access software and applications.
This second policy lever available to the Australian Government falls under its National
Disability Strategy. It is a far-reaching social policy initiative intended to better address the
long-term care and support needs of people with disability. In short, it is based on an
insurance model that would provide early intervention and resources to improve quality of life
and increase social and economic participation to people with disability (Sherry 2010). The
Productivity Commission is currently inquiring into the feasibility and form of such a scheme
and is due to report to the Government by 30 June 2011 (Productivity Commission 2010). A
small number of submissions to the inquiry have mentioned the importance of including
communications services in any such scheme, including:
I think there will be a lot of improvements through the Internet and the national
broadband network will open up other opportunities, including, for example,
interpreting and real-time captioning over the Internet (Lawder 2010, 353).
…access to information, including information and communication technologies, is
an essential part of a scheme that giving those – an eligibility regime must take this
into account (Salthouse 2010, 359).
A national scheme must provide equipment that will allow all consumers with
disability access to voice, voice-equivalent or text-to-speech telephony services, the
internet and any future broadband network (Australian Communications Consumer
Action Network 2010b, 6).
Such a scheme should enable a comprehensive response to issues of availability,
accessibility and affordability of essential services, including communications
services (Telstra Corporation Ltd 2010a, 3).
There are two distinct advantages to using a NDIS type scheme to address affordability and
accessibility issues surrounding the NBN. Firstly, it could provide a comprehensive solution
to these issues combined with the flexibility of addressing individual needs. Secondly, as a
driver of demand for suitable ICTs, it can support innovation and the entry of new products
and services into the market.
The Australian Government currently provides a Government Telephone Allowance to a
range of eligible pension recipients and others, including those who receive the Disability
Support Pension. Telstra also provides a Pensioner Discount under its own Access for
Everyone package. Given the new wholesale pricing threshold set by the NBN, consideration
needs to be given as to whether the current Government Telephone Allowance is adequate to
ensure basic affordability of entry-level services at the retail level, for both information and
communications access.
We as a society must believe … [for people with disability] that having access to
broadband is a big deal. We must embrace the cause… (Lyle 2010, 19)
There is a sound economic case, based on the considerable positive externalities of a new
communications network, for Government to invest in extending that network in a range of
ways. To date, with the NBN, the locus of that investment is restricted almost exclusively to
the availability of the infrastructure itself and to allow geographically averaged (wholesale)
While some small demonstration projects involving specific applications and user
environments have been announced (Conroy 2010), there is another important locus required
for such complementary investments to ensure the rapid take-up of NBN connections and
services so that the network effects are realised as soon as possible.
This will involve adjustments to the USO policy and incomes policy to ensure a reasonable
safety-net of accessibility for all Australians, as well as committing to including
communications access and equity in the implementation of a National Disability Insurance
Scheme for people with disability. This will stimulate innovation and showcase new and
interesting applications made possible by the NBN. Such public investment in the
affordability and accessibility of NBN based services will bring forward the beneficial takeup and use of this important infrastructure, given the many high-bandwidth services that will
be particularly useful for people with disability.
Five years ago, Gerard Goggin and Christopher Newell sought to imagine “Disability in
2010”, where and when it was hoped that instead of being viewed as deficit and cost it is
viewed as contributory and valuable (Goggin & Newell 2005, p. 70). As a technology, a
network infrastructure, an institution, with particular public policies surrounding it, we do not
want the NBN to be “shaping, creating and perpetuating disability” (Newell 2005). Rather,
with the right attendant policies of affordability and accessibility, people with disability can
offer “contributory and valuable” support to the success of the NBN as a new network, and in
turn allow people with disability to take up the new opportunities that this technology affords,
thus making for true universal service.
While Christopher Newell made great use of communications technologies in support of his
research and advocacy on behalf of people with disability, and was highly involved in the
telecommunications industry with all the right contacts, it was rather ironic that he was unable
to obtain a fixed broadband service at his home for “technology” reasons. And yet, he
depended on these technologies. At one point, when in hospital for an extended period of time
and subject to intensive medical care, he confided to the author that it was his Internet
connection – which allowed him to remain connected to his work, his colleagues and family,
right from his hospital bed – that had “saved his life”. The need to resolve NBN affordability
and accessibility issues for people with disability doesn’t get any more poignant than that.
The views expressed by the author in this research paper are not necessarily those of Telstra
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Cite this article as: Morsillo, Robert. 2011. ‘One down, two to go: public policy in service of an
available, affordable and accessible National Broadband Network for people with disability’.
Telecommunications Journal of Australia. 61 (2): pp. 28.1 to 28.13.
Quoc V. Vy
Ryerson University, Canada
Deborah I. Fels
Ryerson University, Canada
The enhanced captioning system was developed using a participatory design methodology to
improve speaker identification using avatars. These avatars consisted of the speaker's name
and image surrounded by a coloured border matching their clothing. An evaluation was
conducted using eye-tracking with viewers who are deaf and hard-or-hearing. The major
findings indicate that using an avatar image as a method for identifying who is speaking is not
only feasible but may require the least attention from viewers to process. Further, differences
between hard-of-hearing and deaf participants are reported.
Since being commercially available in the late 1930s, broadcasted television (TV) has quickly
become an 'everyday' medium for consuming content (CRTC 2009). As such, film and TV
have played a significant role in the cultural development and distribution of many modern
societies. However, people who are deaf (D) or hard-of-hearing (HOH) are unable to fully
access and benefit from this experience, due to their condition. A majority of these individuals
rely on captioning as the primarily method for consuming and participating in this cultural
activity. Captioning is a text-based transcription of sound, using text descriptions and symbols
for representing dialogue and non-speech information (NSI) such as speech prosody, emotion,
speaker identification, sound effects, and music.
The most popular form of captioning is found on TV and is called closed captioning (CC) in
North America, or subtitles (for the hard of hearing) in Europe and other parts of the world.
When either captioning system is enabled, a captioning 'window' may be displayed on-screen
that contains textual information regarding the current content. These windows may appear in
various shapes (multi-line) or sizes, either consecutively or simultaneously, and possibility at
different locations on-screen. The information contained in each window may be printed
using different styles: typewriter (word-by-word), vertical scrolling (line-by-line), or pop-on
captioning (block of words). Despite these similar features, both captioning systems were
developed separately using different technologies and are not technically compatible with one
Although practical and beneficial, a common misconception is that captioning is complete
and no further development is required. The ideal goal has been to provide an experience that
is equivalent (or as close) to consuming content as intended, with access to the audio. This
ability to effectively convey sound information is crucial for obtaining a complete and
accurate 'picture' of the content. This is especially the case with viewers who are D or HOH,
as this sound information would otherwise be inaccessible to them. This ideal goal has yet to
be met by the existing captioning systems (e.g. CC and subtitles), which were developed in
the early 1970s. In fact, these captioning systems pushed the limits of technology at the time,
even though they are text-based. The lettering for captioning was initially all-uppercase due to
difficulties of early decoders in rendering lowercase letters that had descenders (e.g., g, j, p,
and q). As a result, the use of all-uppercase lettering was the de facto standard initially and
still is for some captioning practices (CAB 2008). However, technology has advanced so
much over the past 30 years, that this is no longer a limiting factor, and that new opportunities
for better solutions are now possible.
In particular, the use of text descriptions and symbols is not adequate for conveying NSI
effectively to these viewers who may be D or HOH. This inability to represent NSI is a
critical issue of captioning because important information and content is either missing or
incomplete which may affect their comprehension. Not only will users be missing out or
perhaps misinterpreting the content, but will also be less able to enjoy or participate in this
cultural activity. As such, providing an equivalent experience as envisioned by accessibility
pundits and enshrined legislative mandates has not been realised and further developed for
captioning is, and in fact, necessary.
In this paper, a solution to this issue of speaker identification is presented, which uses text and
graphical-based identifiers as a potential for being more effective. The results of evaluating
this EC system with participants who are D or HOH are also presented.
Captioning did not appear on TV until the early 1970s, nearly 30 years after TV was
commercially available. The term 'closed' as in CC, but also applies to subtitles, is used to
indicate that the captioning may be turned on/off by the user. Otherwise, if the captioning is
embedded or 'burned' in the video, it is considered as being 'open' since it cannot be removed
and is always visible. This 'open' captioning is commonly used for translating languages
which may be different from the remaining content, or entirely as in foreign films. However,
'closed' captioning is commonly used for broadcasted TV as it allows viewers the choice of
displaying them as required.
The process of providing 'closed' captioning for broadcasted TV has more or less remained
the same in the past 40 years. The captioning data is encoded into the video signal for
transmission and is decoded before being displayed on-screen. This data is encoded on Line
21 of the Vertical Blanking Interval (CEA-608) of analogue TV and in the picture user data
of the MPEG-2 stream (CEA-708) for DTV. For subtitles, this data is transmitted using an
information retrieval service called teletext, and on a particular page which varies depending
on the country (e.g., Page 888 using Ceefax in the UK). Finally, if the user has enabled this
feature, the captioning data is decoded and shown on-screen.
The current standards for CC are the CEA-608 (CEA 2008) for NTSC (analogue) and CEA708 (CEA 2008) for ATSC (digital) broadcasted TV. These standards were originally
developed in 1994 and 1997, by the Consumer Electronics Association (CEA) - which was
known as the Electronic Industries Alliance (EIA) before 1999.
The current standards for teletext, which is used for transmitting and displaying subtitles, are
the 'Enhanced Teletext specification' (ETSI 2003a) for analogue broadcasting and the
'Specification for conveying ITU-R System B Teletext in DVB bitstreams' (ETSI 2003b) for
Digital Video Broadcasting (DVB). These standards were originally developed in 1994 and
1996, respectively by the European Telecommunications Standards Institute (ETSI). Another
standard is the 'Teletext Subtitles and VBI Data for HD Television' (SMPTE 2008) by the
Society of Motion Picture and Television Engineers (SMPTE).
The first standard for teletext is called 'World System Teletext' (WST 1989), which is the
successor to CEPT1 (1981) created by the European Conference of Postal and
Telecommunications Administrations (CEPT), and earlier the 'Broadcast Teletext
Specification' (IBA 1976), which was originally created in 1974 jointly by the Independent
Broadcasting Authority (IBA), British Broadcasting Corporation (BBC), and British Radio
Equipment Manufacturers' Association.
In response to the significance of broadcasted TV, laws and regulations have been passed to
ensure that accessing this content is more accessible to everyone, especially those with
disabilities (e.g. deaf and hard-of-hearing). These laws and regulations are mandated by
governmental organisations, such as the Australian Communications and Media Authority
(ACMA) in Australia, the Federal Communication Commission (FCC) in the United States
(US), the Office of Communications (Ofcom) in the United Kingdom (UK), and the Canadian
Radio-television and Telecommunications Commission (CRTC) in Canada.
The first of these regulations was the Television Decoder Circuitry Act of 1990 which was
passed in the US. Effective July 1993, this act required decoder circuitry which is used for
displaying closed captioning to be built into TV sets that were 13 inches or larger. As a result,
users were able to access this captioning service without the need for purchasing a separate or
external decoding device.
In addition, other regulations have been passed to reflect this essential service, specifically to
increase the quantity (availability) and quality of captioned content. Such examples of these
regulations are the Broadcast Services Act 1992 in Australia, the Telecommunications Act of
1996 in the US, the Audiovisual Media Services Directive 2009 in Europe, and the
Broadcasting and Telecom Regulatory Policy CRTC 2009-430 in Canada. The latest of these
regulations which was passed is the Twenty-First Century Communications and Video
Accessibility Act of 2010 in the US.
There is also the Convention of the Rights of Persons with Disabilities (2006) of the United
Nations (UN), which is an international treaty and the standard for most regulations of
countries today.
Over the years, protocols and guidelines for captioning have been developed by organisations
all over the world. For example, the Canadian Association of Broadcasters (CAB) in Canada,
National Center for Accessible Media (NCAM) @ WGBH in the US, the Office of
Communications (Ofcom) in the UK, and Media Access Australia (MAA) in Australia.
Although these are different organisations, there are few differences in their
recommendations. The only noteworthy difference in these standards is how they represent
NSI. In general, NSI is represented using only text descriptions and symbols for CC, while
different colours for speaker identification and indicating sound effects for subtitles.
Speaker Identification
The current method for identifying a speaker is one of the limitations of a text-based
captioning system for representing NSI and is the focus of this paper. Currently, the
placement of the captioning near the character is the foremost indicator for identifying the
speaker. However, this is often ambiguous or insufficient, as there may be multiple characters
or off-screen speakers. In these cases, text descriptions and/or symbols (e.g., >>, :) may also
be used to reduce this ambiguity. The text description is usually of the speaker's name or if
that is unknown, a short description which describes their gender or role (CAB 2008).
For example, a typical captioning with a name for speaker identification is: >>ANNE: Good
evening everyone. The chevrons >> are used to visually indicate a change in the speaker,
while a colon : separates the speaker's name with the dialogue. However, the problem with
using text-based identifiers is that viewers (including those who may be D or HOH) are
required and assumed to be able to associate either the name or description of the speaker to
the correct character.
Furthermore, this practice of using the speaker's name is often omitted due to the additional
character space that is required. Instead, only chevrons >> are used whenever possible (not
ambiguous). The practice of using different colours (e.g., white, yellow, cyan, and green) is
used in subtitles for speaker identification. However, this only indicates a different speaker,
and not necessarily who is speaking at that given time. As such, the use of different colours or
a text-based identifier (e.g. name) is not sufficient for speaker identification. This is especially
the case with viewers who are D and HOH.
The enhanced captioning (EC) system was developed using a participatory design (PD)
methodology to include people who are deaf and hard-of-hearing – intended users (Vy & Fels
2009). This was to help ensure that the EC system would be more usable by involving users
throughout the entire design and meeting their needs by including them in the decisionmaking process. The researcher together with some users (participants) were involved in a
mapping technique (Bødker 2004) in which to better understand their needs and explore
technological options that are available. This also enabled a mutual learning (Beguin 2003)
process between both parties, which further promoted this co-operative design for creating a
more effective system. The mapping technique was chosen as it best suited this situation and
is one of many tools from the MUST method - a Danish acronym for theories of and methods
for design activities (Kensing 1998).
The needs of users were investigated using an activity and interview to obtain their opinion on
watching TV with closed captioning (CC) – the current system. This information was then
analysed using the mapping technique to establish an overview and understanding of the
situations that were problematic (Bødker 2004). From these discussions with participants, a
diagnostic mapping was created to analyse the problematic situations that were identified,
while a virtual mapping was created to evaluate ideas for their solutions. As expected, the
investigation indicated that in some situations, captioning is either inadequate or ineffective
for addressing the needs of users. The specific issues that were identified by participants
related to non-verbatim captioning, speaker identification, non-speech information, sound and
music, and other technical issues.
The solution that was developed to address these problems and needs was using a captioning
panel and avatars for speaker identification (Vy & Fels 2009). In particular, there are three
identifying components for indicating a speaker:
1. Image. Ideally, this is a screenshot of the character when they are facing the camera
(head shot or portrait). This image should be updated throughout each scene to match
changes in the lighting, clothing, etc.
2. Coloured Border. This border surrounds the image and the colour usually matches the
character's wardrobe. Another purpose for using colour was suggested for displaying
their emotion.
3. Label. This is usually the name of the speaker, or if that is unknown their role (e.g.
mail carrier) or at the very least a description of their voice (e.g., gender).
The following research questions will be explored in this paper:
What is the impact of closed captioning and enhanced captioning on user’s stated
preferences and eye gaze activity of closed captioning and enhanced captioning?
What are the differences in user’s preferences and eye gaze activity between closed
captioning and enhanced captioning?
There were a total of 19 participants (twelve deaf and seven hard-of-hearing) who were
recruited and conducted this user study. The participants were between the ages of 20 and 89
years old (M = 40.68, SD = 17.54) and watched an average of 9.55 hours of television per
week (SD = 4.61). While watching television, sixteen of these participants always used
captioning, while the remaining three (HOH) participants have never used captioning.
Deaf Group
The Deaf group consisted of nine females and three males. Their age ranged between 20 and
59 years old (M = 34.92, SD = 10.70). The highest levels of education completed in this
group consisted of: two people who completed high schools, seven who completed college,
and three who completed graduate school. This group watched an average of 9.33 hours of
television per week (SD = 5.19).
Hard-of-Hearing Group
The HOH group consisted of three females and four males. Their age ranged between 20 and
89 years old (M = 50.57, SD = 21.99). The highest levels of education completed in this
group consisted of: one person who completed high school, one who completed college, three
who completed university and two completed graduate school. This group watched an
average of 9.93 hours of television per week (SD = 3.33).
Participants watched a total of 16 video clips, which consisted of a combination of four
captioning styles and four video clips taken from a film (Transformers 2007). The different
captioning styles consisted of the existing CC and three different configurations of EC: the
speaker's name (SN), the avatar (AV), and both components together (AV+SN) (see Table 1).
The video clips were selected so that there was a variety of settings, number of speakers, and
words per minute (WPM) of the dialogues as outlined in Table 2. The viewing order of each
video clip and captioning style was randomised for each participant, minimising any potential
learning effects that may be encountered.
Captioning Style
Speaker's Name
Table 1 - Captioning Styles and Components
Number of
Rate of Speech
1m 13s
104 WPM
173 WPM
1m 36s
184 WPM
1m 24s
124 WPM
Table 2 - Properties of Video Clips
For this study, qualitative and quantitative data were collected from study participants, using
questionnaires and an eye-tracking device (Tobii x50). The questionnaire data has been
presented in a previously published manuscript (Vy & Fels 2010).
Gaze Fixation and Scan Path for Eye Tracking Data
The basic information that can be obtained from most eye-tracking devices is gaze fixation
and scan path.
A gaze fixation is determined by a pre-defined size and duration of a gaze point – the x-y coordinates of where the participant is current looking on the screen. The scan path is the
movement between these determined fixations.
A fixation filter of a 30 pixels Velocity Threshold (or radius size) and a 100ms Duration
Threshold was used for analysis. This is the recommended setting for using a stimulus which
contains both images (e.g., video and avatars) and text (speaker's name and dialogue) as
indicated by the analysis software, ClearView 2.7.1 (Tobii 2006).
Areas of Interest
Areas of Interest (AOIs) are defined regions on the screen that are outlined by points and lines
(polygons) which are used for analysis of eye-tracking data.
There were three categories (or types) of AOIs that were defined:
Video: the region containing the video
Captioning: regions of where captioning may appear
SID: speaker identification component (avatar) of EC
Closed Captioning
The following describes the difference of the AOIs for CC (see Figure 1a):
There is a total of two Captioning AOIs: CC.Lower and CC.Upper
There is no AOI defined for SID as the speaker's name is not reliable and does not always
Enhanced Captioning
The following describes the difference of the AOIs for EC (see Figure 1b):
There are a total of four Captioning AOIs: two levels (.Upper and .Lower) for each speaker
(.Left and .Right).
The two SID components for EC (SN) are: Name.Left and Name.Right
The two SID components for EC (AV) and EC (AV+SN) are: Avatar.Left and Avatar.Right
Figure 1 – Areas of Interests (AOIs) as defined for CC (left) and EC (AV+SN) (right)
Because of the large quantity of information collected from eye-tracking, only a subset of this
data was analysed. As such, the data that were analysed was of captioning styles: CC and EC
(AV+SN) for Video D only. Video D was the most ideal choice, because it had the greatest
variety of different situations. For example, Video D had instances of dialogue between
different groups of characters, off-screen speakers, and a rate of speech of 124 WPM which
slightly lowered that of the average of all video clips (146.25 WPM).
As there is a difference in the number of participants in each group, the percentage of these
fixations will be used in a frequency analysis. This will be used for determining a frequency
count within Areas of Interest (AOIs) which is normalised and can be used for comparing
both groups.
A frequency analysis of the fixations of the AOI was carried out to compare any differences
between both groups (see Tables 3 and 4).
The results indicated that HOH group viewed the video more and the captioning less than the
Deaf group. Although the SID component was viewed the least for both groups, HOH
participants viewed the Avatar more, but less of Name than deaf participants.
EC.LowerRight 472
Table 3 - Fixation Count and Percentages of AOIs for EC
Similarly, the same trend for CC with the Video and Captioning AOIs appears as for EC. The
HOH group viewed the Video more and captioning less than the Deaf group.
Table 4 - Fixation Count and Percentages of AOIs for CC
A repeated measures ANOVA (Analysis of Variance) was carried out for fixation duration
using between-subjects factors: AOI_Type (Video, Captioning, SID), Captioning_Style [EC
(SN), EC (AV), EC (AV+SN), CC], and Hearing_Status (deaf or hard-of-hearing).
There was a significant interaction effect for fixation duration between AOI_Type and
Captioning_Style, F(5, 12620) = 3.73, p < 0.05, and between Captioning_Style and
Hearing_Status, F(3, 12622) = 5.58, p < 0.05. There was significant main effects for fixation
duration between AOI_Type, F(2, 12623) = 10.19, p < 0.05, between Captioning_Style, F(3,
12622) = 23.44, p < 0.05, and between Hearing_Status, F(1, 12624) = 49.10, p < 0.05. Posthoc analysis using the Tukey’s HSD test showed significant differences (p < 0.05) between
CC and EC captioning styles (see Table 5).
Captioning Style
Table 5 - Mean and Standard Deviation for Fixation Duration
Figure 2 shows a comparison of Mean Fixation Duration times between the two groups. In
general, the Deaf group spent more time watching each video for all the captioning styles than
the HOH group. For both groups, the shortest amount of time was spent with CC. The Deaf
group spent a similar amount of time for the different EC captioning styles, but longer than
with CC. However, the HOH group spent the longest time with EC (AV+SN), and shorter
times with EC (AV), EC (AV+SN), and CC.
Figure 2 - Average Fixation Duration by HOH and Deaf Groups
The following shows the Estimated Marginal Means for fixation duration for the different
AOI categories: Video, Captioning, and SID components (see Figure 1 for AOI definitions).
Figure 3a shows that both groups spent less time with the Video with CC than with most of
the EC. In general, the Deaf group spent more time looking at all AOIs than the HOH group.
For the EC (SN) and EC (AV) captioning styles, the HOH group spent less time looking at the
Video for CC.
Figure 3a - Average Fixation Duration for AOI Type: Video
Figure 3b shows that both groups spent less time looking at the conventional closed captioned
videos (CC) compared with all of the ECs. Within EC, the Deaf group spent the most time
looking at Captioning of EC (AV) style, while the HOH group spent the least amount of time.
The HOH group spent the most time looking at Captioning with the EC (AV+SN) style, while
the Deaf group spent the least amount of time.
Figure 3b - Average Fixation Duration for AOI Type: Captioning
Figure 3c shows that, in general, the Deaf group spent more time looking at the SID
components than the HOH. The Deaf group spent the most time looking at the speaker’s name
of EC (SN) style, while the HOH group spent the most time with EC (AV+SN) style. Both
groups spent the least amount of time looking at the Avatar in the EC (AV) style.
Figure 3c - Average Fixation Duration for AOI Type: SID
For the captioning styles of EC, deaf participants spent more time looking at the SID
components than HOH participants. When compared to the other EC styles, deaf participants
spent the most time on looking at the speaker’s name with EC (SN), while HOH participants
spent the most time with EC (AV+SN). Both groups spent the least amount of time looking at
the avatar in EC (AV), when compared to the remaining EC styles.
The data show that there are significant differences in the eye tracking data between the
conventional closed captioning style and all of the enhanced captioning styles. There were
significant interactions and main effects for fixation duration for Captioning_Style. In
general, the fixation duration increased for all of the enhanced captioning styles compared
with CC. This was an expected finding because most of the participants were accustomed to
the CC style of captioning, as it has been the convention for the past 40 years. The enhanced
captioning styles were new and probably required more attention to process them, for all
individuals. Longer term exposure to enhanced captioning styles may reduce this novelty
effect. To determine whether eye gaze behaviour would change with practice, longitudinal
studies with different types of content will need to be carried out.
Examining the Area of Interest (AOI) data for the enhanced captioning conditions only
provides more details regarding the differences between the Captioning_Style allowing
inclusion of the EC (AV) captioning style condition as well. As seen from Figure 3, the video
component was watched most for the EC (AV+SN) video condition by both participant
groups and least in the EC (SN) or EC (AV) video conditions for both groups. The enhanced
captioning SID components (either speaker name or the avatar) were looked at most in the EC
(SV+AV) video condition for the HOH participants while the deaf participants watched the
SID components most for the EC (SN) video condition. Finally, HOH and deaf participants
spent the least amount of time looking at the enhanced captions in the EC (AV) video
It seemed that for both groups, it was not necessary to look at the avatar images (SID) for a
long duration to discover who was speaking; there was no reading involved and the visual
association between speaker identification indicator (avatar) and who is speaking may be
simpler. Cognitively, reading may require more time for processing than image processing in
the visual cortex so it is not surprising that both participant groups spent the least amount of
time watching the avatars when their eyes were focused in that AOI. However, the HOH
group spent the most time looking at the avatar and speaker name when they appeared
together but the Deaf group spent the most time in that AOI looking at the text of the videos
(in the SN Captioning_Styles condition). It appears that the cognitive load may be increased
more for HOH participants when text and images appear together, while for deaf people, text
processing by itself may require more cognitive effort than when there is redundancy between
the text and the image. It may also be true that the avatar image was of least interest and was
disregarded immediately when it appeared. A further examination of the cognitive effort
being expended by participant groups for the various enhanced captioning conditions is
required in order to better understand the effects.
Examining the fixation duration for all of the AOIs showed that deaf participants spent more
time in all of the AOIs than did HOH participants. This indicated that deaf participant’s eyes
were fixated on all aspects of the videos, regardless of style or video type, for a longer time.
Because the playing time for each video was constant, it would then seem that the eyes of
HOH participants were looking elsewhere (non-AOIs) for more time than the eyes of deaf
participants or that they were more concentrated on the AOIs. This could indicate that deaf
participants had to spend more perceptual and cognitive effort to process the captioning
information regardless of style, thus requiring additional attention; or that deaf participants
found the video clips (video and captioning) more interesting and worthy of their attention.
Ikehara and Crosby (2005) found that eye tracking can provide evidence of levels of cognitive
workload, in that increased fixation and duration indicated increased cognitive workload for
computer tasks. Whether this can be translated into measuring cognitive workload while
reading captions has yet to be determined. Further research examining cognitive workload
using fMRI or EEG measures or subjective workload techniques such as the NASA TLX may
provide additional insight into these possibilities.
Deaf participants looked at the captioning text more often than the video content or the avatar,
and the converse occurred for HOH participants. This would seem to indicate that deaf
participants relied more on information from the captioning than the video, compared with
HOH participants. This was expected since deaf participants have much less access than the
HOH participants to the auditory information that would have been provided by the
soundtrack and they therefore relied on the captioning more than the HOH participants did.
However, it was surprising that deaf participants looked at the speaker’s name more, and less
at the avatar and video, compared with HOH participants. This could indicate that the avatar
and video were less interesting or useful than for the HOH participants or that it did not
require as much attention to cognitively process. Again, further study using cognitive
workload measures may provide more detailed insight.
The use of a person’s name for speaker identification, as found in most guidelines and
standards for captioning (CAB 2008) incorrectly assumes that using text descriptions is
adequate and satisfies the needs of both groups. However, deaf people typically identify
others by their physical appearance or personality (e.g., body size/height, hair, job/position,
etc.) rather than by their name. The speaker’s name information may have required more
cognitive effort and time to process resulting in the increased fixation duration found in this
study. The fixation duration for deaf participants also shows a slightly lower time for the
avatar captioning style compared with either of the enhanced captioning styles containing the
speaker’s name. In contrast, a name is a written speech identifier, which is a more familiar
convention for HOH individuals, and would likely take less time to cognitively process as a
result. The extra written text information provided by the speaker’s name may have required
additional effort and time which in turn could have caused deaf participants to find it less
These differences between deaf and HOH users provide some initial evidence to support
changing existing captioning practices, guidelines and tool design. Given that all of the
enhanced caption options are feasible for either digital television or online video content, a
'one-size-fits-all' approach used in conventional television can be replaced with an approach
that allows for user customisation options. Deaf users may prefer to use avatar or visual
indicators for speaker identification rather than text names, while HOH users may prefer text
The study reported in this paper provided some evidence from eye-tracking data that using
images to represent who is speaking is a feasible alternative to text-based speaker
identification, particularly for deaf users. Using real-time eye tracking data of fixation
duration and area-of-interest seem to provide useful data for analysing user viewing
behaviour and differences between hard of hearing and deaf users. Designing captioning
systems that allow for different captioning styles could provide customisable accessibility
options for deaf or hard-of-hearing users that better meet their needs. Designing intelligent
software that could automatically create avatar images based on face recognition and lip
movement in the video could reduce the manual work required to generate these images.
Finally, broadband telecommunications networks are more than capable of distributing image
and text data with video data in real-time.
The study reported in this paper is the first in a series of studies designed to examine
enhancements to captioning to provide better access to non-speech audio information. Future
work on speaker identification could include studies examining longitudinal effects as well as
system improvements. In addition, the captioning of other non-speech information such as
music and sound effects must be considered. Regardless, it is important to recognise that there
is considerable research and innovation that remains to be done to improve captioning, that
the captioning system for analogue television is no longer valid and must be changed, and that
high-speed telecommunication systems, rather than television, can facilitate those changes.
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Katie Ellis
Murdoch University
Like web 2.0, a participatory culture is central to university life. Several theorists have
recognized the importance of digital technologies in including students with disability.
Mainstream accessibility measures are beneficial to both students with disabilities and those
without. Data for this paper is entirely crowd sourced from web 2.0 platforms and explores the
ways students with disabilities are using mainstream accessible web 2.0 technologies – file
sharing, Facebook, FourSquare and blogs – to foster inclusion. By utilizing the knowledge of
the crowd this paper seeks to empower the disability narrative. People with disabilities are not
just assisted by web 2.0, they are innovators of it.
It wasn’t until I reached university that I realised that my disability was a problem.
Prior to university, I didn’t have many problems in terms of my disability – I had
supportive teachers who went out of their way to ensure that I was not excluded by
virtue of my hearing impairment... I tried to change the learning environment to
ensure that students with disability had the same access to the learning environment
as their non-disabled counterparts, but did not have much success. Sometimes, I
considered dropping out of uni, but I persevered. However, I left uni with a dearth
of self-confidence. (Saab 2011)
Up until the latter part of the twentieth century, those who were designated as disabled were
mostly denied access to a mainstream education. With increasing numbers throughout the
1990s, moving into the second decade of the 21st century, university students with disability
are an established and growing minority. In the United States they make up about 6% of the
student population while in Australia they number 4% (DEST 2007). From a charitable ethos
of “helpful” or kind staff “helping out” students with disability, an environment has emerged
whereby these students can expect and demand support through dedicated disability offices.
However, as the above student’s experience demonstrates, this is not always the case because
inflexible practices and people continue to inhabit academia.
Several theorists have recognised the importance of the Internet to students with disability.
While Li and Hammel (2003) suggest it can offer innovative ways to bypass the effects of
impairment that can prevent a student from participating, Mullen et al. (2007) believe
participation on the web can allow a neutrality of identification to allow the student with
disability to blend in as though not disabled. Finally, Alltree and Quard (2007) argue that
adjustments introduced to assist students with disability have far reaching benefits for the
non-disabled population also and Wood (2010) cautions that students with disability would
benefit the most from engagement with technologies that provide learning opportunities yet
inaccessibility often excludes them. These examinations provide a good starting point for an
investigation of the inclusion of students with disabilities in tertiary education; however, in
this paper I wish to expand the theorization to look at more recent web 2.0 technologies now
available to students with disability through the mainstreaming of accessibility measures and
the ways that these students and their allies are innovating their use to facilitate greater
inclusion of people with disabilities in University life.
Extending my previous argument (Ellis 2010) that any investigation of the ways digital
technologies assist individuals with disabilities must consider the communicative work people
with disabilities are undertaking on the web, this paper utilises the knowledge of the crowd, to
empower the disability narrative, to see how students with disabilities are taking technologies
designed for perhaps a more mainstream market and using them to their advantage. This
situation is only available because accessibility is becoming mainstreamed. Looking at web
2.0 through a disability lens highlights the ways people can work together under this
philosophical and technological concept to share ideas, information and creations while
working with others for a specific purpose. This review paper foregrounds the social aspects
of digital life, a concept particularly important to the inclusion of people with disabilities.
Universities foster innovation, they encourage students to become creative and critical
thinkers. Like web 2.0, a participatory culture is central to university life, academically and
socially. At university, students are encouraged to connect with others and engage with the
community. It is vital that people with disability, already excluded in much of social and
community life are not prevented from gaining a university education. While official
organizations have emerged to address this, significantly, the participatory culture of an
accessible web 2.0 allows people with disabilities the opportunity to innovate modes of
inclusion via digital technologies themselves. At the Australian Tertiary Education Network
on Disability’s 2006 Pathways Conference, pioneering disability academic Christopher
Newell gave a keynote address on accessible design as a way to include people with disability
in life long education and training. He envisioned a world where the rhetoric would become a
I long for, I dream of, I desperately desire, a world where learners, academics and
administrative staff with disability in higher education and training know that they
are embraced, know that we are found to be part of the moral community and where
when we speak of the nice, normal and natural we know that those of us with a
diverse range of disabilities are included. I dream of a world where the power of
narrative and dreaming helps to transform the world. (Newell 2006)
Also an academic with a disability, Newell saw the creation of accessible technologies as a
political move in actually embracing the inclusion of students with disabilities. The universal
design of technologies so that they can be used by the greatest number of people without need
for adaptation was especially important. Recent mainstream accessibility measures such as
those introduced by Apple, Facebook, and Google have changed the way web developers and
the general public view access for people with disability. No longer is it something extra,
unnecessary, special – accessibility is something everyone can benefit from (Ellis and Kent
2011). Mike Calvo, a blogger with vision impairment suggests this is particularly important to
students because they are increasingly encouraged to multitask throughout their education.
For example, screen readers designed to assist people with vision impairment now included
on Apple products such as the iPhone and iPad will become increasingly important to the
mainstream population:
if we can find our tunes eyes-free, we are going to want to do many other things
eyes-free. And that means a future where blind people like you and me no longer
have to struggle for accessibility just moved a whole lot closer (Calvo 2008)
Throughout this paper I acknowledge the chequered history of the web in excluding people
with disability but celebrate the current accessibility turn, and examine the ways people with
disabilities are using mainstream web 2.0 applications, to reflect on the opportunities this
provides for students with disabilities to participate in a tertiary education. Borrowing from
Newell’s (2006) argument that the power of narrative transforms the world, data for this paper
relies on reflections posted by students with disabilities on a number of web 2.0 platforms.
I begin this paper with a consideration of the increasing importance of collaborative web 2.0
applications to University education. Just as the number of students with disabilities enrolled
at University has increased, the general student population is becoming more diverse with
students regularly balancing any number of competing demands. Alternative pathways to
entry are also increasingly common to attract these groups. 1 Educators are finding that
incentives designed to improve access for students with disability actually improve the
educational experience for many students negotiating study with competing demands. For
example in 1998, Lectopia – the lecture recording and distribution system – was introduced in
Australia at the University of Western Australia (UWA) to enable students with disability
better access to lecture materials (Ellis & Kent 2008). The system has now been broadly
embraced by a diverse student population in many universities. Effective disability policy that
provides support and resources for students with disability often has an added benefit for
everyone. As the lectopia platform moves into providing transcripts of lectures, people with
hearing impairments are able to access the material independently and can now search for key
words along with nondisabled people benefitting from the technological advancement.
Legislation such as the Disability Discrimination Act 1992 and the Disability Standards for
Education 2005 influence disability service provision at the tertiary level. Most Australian
universities mandate disability policies and publications that proceed from the definition of
disability discrimination outlined by the Disability Discrimination Act 1992. Under these
regulations, the university cannot treat a student with disability less favourably than a student
without. Where disadvantage does exist, reasonable adjustments must be adopted to
compensate. The second section of this paper therefore moves to consider the importance of
providing accommodations for students with disabilities and highlights the role of universal
design in whether a student can access the information necessary to complete a university
These accommodations, while vital to the student with disability, are frequently stigmatized
and regarded as onerous and unnecessary for the wider student population, thus I seek to
demonstrate in the third section of the paper the importance of mainstreaming accessibility.
Through a number of case studies I explore the ways students with disabilities, as innovators
of web 2.0, are using web 2.0 communications platforms to complete a tertiary education.
According to John Jennings (2007), an “always-on” Internet connection transforms the
learning experience and improves inter-institutional collaboration, existing service provision
and significantly, enables wider access to an education. With a greater number of people
attending university and accessing a wider breadth of information, broadband has become a
significant resource in modern education. Instant access to previously unavailable information
and databases has and will continue to transform education for all students (Dempsey 2005).
Ongoing research at UWA demonstrates that students expect an increasing use of ICT
throughout their degrees, either provided by their lecturers or used during private study or
group work. While lectopia, WebCT, and powerpoint were the most used, increasingly
students and lecturers are turning towards blogs, discussion boards, and social networking
(Cluett & Skene 2009). With the majority of students owning a computer and mobile phone
along with the widespread availability of the Internet, students today have advanced skills in
ICT and expectations regarding their use in education as well as their own innovations in how
to use the technology. Educators likewise seek to exploit this and see new technologies
loosely defined as web 2.0 as particularly suited to the educational experience and thus seek
to experiment with user generated content .
Web 2.0, or the “read-write” web is taking the use of ICT in education to a more immersive
and collaborative level particularly with the availability of an always-on, low-latency network
broadband connection. The difficulties with these platforms, experienced by students with
disability, demonstrate the potential problems of bringing web 2.0 tools into the academy.
When design is disabling some students are unable to navigate these environments, while
others are forced to reveal their impairments. Despite this, the use of web 2.0 in education
may be beneficial – the ability to manipulate digital content in ways that suit the user’s
learning style is particularly useful to students with disability:
Once a piece of information or content is digitised its form is significantly
transformed. Whereas a work written on a page is locked in that format, once a
word is a digital file it can be transformed to suit any person trying to access it. It
can appear as the written word, it can be automatically translated into another
language, it can be interpreted as an image, it can be shown in sign language and it
can be displayed on a Braille tablet. Once that file is connected to the internet all
these different modes of access can take place simultaneously, all over the world.
This information can be requested through a traditional keyboard, by speech,
through eye tracking software or by moving any of a number of different mouse
devices. Making that content accessible is a choice. Making it inaccessible is also a
choice. (Ellis & Kent 2011)
Despite the strong rhetoric that digital information will automatically liberate students with
disability, many will struggle with content that is inaccessible by design (Martínez-Cabrera
2010). Universal design (see Newell 2006) to allow access using a number of different
methods is paramount to the inclusion of students with disability who often make use of
adaptive technology.
The inclusion of students with disability involves more than providing a space where they
don’t need to declare their impairment as many of the disabling problems of the “real world”
are reproduced on the Web in the form of inaccessible interfaces. University administrators
and academics should ensure digital content can be accessed in many different ways as Ellis
and Kent (2011) describe above. Students with disabilities will often make use of adaptive
technologies such as dictation software:
One thing that has helped me quite a bit as a blogger, writer, grad student and
person with chronic pain subject to flare-ups has been speech-to-text software. The
basic idea is fairly self-evident: You install the software, plug in the headset that
comes with it, open up the word processing program of your choice, and start
talking. (Annaham 2010)
Or screen readers and Braille displays to access ICT:
I have been using braille all my academic life, I write much more quickly and
smoothly in braille. Only in braille can I write fast enough to keep up with my
thoughts ... I write anything significant, such as essays … in braille first, then
transfer them over to my computer (using JAWS) if I need to do so. That said, I
have become much more proficient at typing since I started uni, and can almost
keep up with my thoughts typing as well. ... I just prefer Braille because I have been
doing it for so much longer, and use it more naturally. (Personal communication.)
In order for these students to be included in the online educational experience, the sites and
technologies used must be accessible and allow for the use of adaptive technologies. While,
for a long time, interfaces and programmes were inaccessible by design, accessibility is now
being built into the design of mainstream, popular products such as Apple and Google.
Paralleling the increasing visibility of students with disability who rely on adaptive
technology (Westin 2005) to compensate for their impairments has been the wide spread
uptake of ICT amongst the student population. Mainstream accessibilities measures are
beneficial to both students with disabilities and those accessing the web from mobile devices.
Although structural measures are in place to enable the full participation of students with
disability in the tertiary arena, many students find that their presence in the University
classroom is resented and themselves resent the amount of personal information they must
share about themselves to large numbers of academic and administrative staff:
Don't think that we're special people asking for special treatment. If schools were
not made to systematically exclude us, we wouldn't have to share so much personal
information because we wouldn't need accomodations. Accomodations (sic) are one
way that we can change normal schooling so that we can learn and express our
knowledge, because we want to learn, but accomodations can't do everything for us.
(Dene 2008)
As educational institutions come to increasingly rely on web based resources, mainstreamed
accessibility would be truly inclusive and address many of the issues outlined by this student.
A course that is planned to be inclusive of all people (including educators who may have a
disability) is much more effective than courses that undergo a belated accessibility retrofit:
Students need to be able to concentrate on course material day one – not be trying to
figure out how to use the workbook that is inaccessible to a blind student or track
down a key needed for a service elevator for a physically impaired student to get to
a class. The web designers, administrators and other decision-makers should have to
navigate their campus while simulating a variety of disabilities – – they have no
idea of the hell they put students through. (tbstoller cited on Parry 2010)
In the realm of online academic engagement, accessible design also offers greater academic
insight. For example, alternative (alt.) text, as it describes what an image is attempting to
communicate within the context of a site, allows both access by a screen reader and provides
other learners with additional course information. Courses should be made accessible from
the beginning because most students, regardless of disability, find fully accessible courses
easier to understand (Edmonds 2002). While demands for accessible content can and should
be made, students with disabilities, like students without, also value making innovative use of
existing technologies, in order to effect social change. The next section will consider the
innovative ways various web 2.0 platforms are being used by university students to access
academic resources, navigate the physical campus, and engage in social connections as well
as disability activism.
Accessing information can be a problem for students with disabilities, especially when
alternative formats are required:
Whereas a sighted student can go to the library, read a book for three hours and put
it back, I would have to borrow the book, organise for it to be read onto tape and
then listen to the tape. This all took twice as long and at the end of it, the book may
not have contained the desired information anyway. (University of Queensland
News 1997)
While digital documents on the Internet are celebrated for allowing people with disability
access to information, in a way not possible with hard copy books, this can be a complex
process as digital documents often need to be converted and corrected by a sighted person
before they can be accessed using adaptive technologies (Ellis & Kent 2008). This also
happens in isolation, with a number of different Universities converting books for their
individual students without sharing that resource. As the conversion process is a lengthy and
onerous task, many students with disabilities receive their course readings very late in the
semester. Web 2.0 technologies harness everyday experiences and build on current
knowledge and foreground the sharing of ideas amongst groups of people. Web 2.0 is
communicative, collaborative and documentative (Poore 2008) and has prompted the creation
of and connections between a number of databases and reference libraries such as the
Gutenberg Project and Bookshare which benefit students with disabilities requiring alternative
formats or who use adaptive technology.
______ is a free academic resource for US students with disabilities that is
revolutionizing education for eligible students. The searchable database offers 90,000 digital
books, textbooks, teacher-recommended reading, periodicals and assistive technology tools
(Bookshare 2010). Volunteers scan and proofread books and then upload them to the library.
This has significantly increased the amount of books available to students with disabilities:
I found out about Bookshare through my assistive technology teacher. My first
thought was that it was a gift from God because no longer [would] I have to get …
three books that I wanted to read at one time, I could just put them on my Braille
note and listen to them, or read them on my Braille note. I call it the blind man’s
laptop because everything that you find on a laptop is on this. You can have a place
where you type your documents called keywords, you have media player on here, a
file manager, a book reader which reads the books you download from Bookshare.
We have Internet, emails, where you can check your email. It's very much like a
laptop. (Bookshare 2009)
When a single page of text converts to several pages of Braille, a system where text books can
be downloaded and read from a computer using whatever the user’s preferred method of
output is particularly attractive. Doubly so when there are a number of different types of
alternative format required, for example one student may need large print, another audio, and
another again, Braille. The database can also be accessed by a large number of students at
different academic institutions. The innovation of connection and collaboration as illustrated
by the Bookshare platform and database enables the inclusion of students with disabilities.
Connection at University however involves more than academics and in the next section I
consider the relevance of social networking and Facebook especially in fostering connections
for students with disabilities.
For Lisa Cluett (2010), social networking sites such as Facebook, provide universities a
flexible way to establish a virtual presence and connect with their students, particularly during
the orientation process. Cluett who established a Facebook page at UWA in 2009 believes
these sites create a university community by connecting students with each other and to staff
and support services. This in turn creates a sense of belonging and captures emotional
Students with disabilities in particular benefit from structured and unstructured transition
initiatives like Cluett’s UWA Facebook page. Despite a history of inaccessibility (AbilityNet
2008), Facebook is now considered the most accessible social networking site . Other benefits
for people with disability include:
an opportunity to break stereotypes, exchange support and reduce isolation.
Facebook also offers a free method of publicizing helpful disability organizations,
books, products — and the people behind them. Advocates view it as a powerful
tool for social change. Throw in the fact that it's just plain fun, and suddenly you
have a lively, integrated community that's been hard to achieve in the physical
world. (Dobbs 2009)
There are several Facebook groups specifically dedicated to students with disabilities. Some,
such as Glasgow University Disabled Students Society are devoted to specific universities and
provide students with information about how to access disability support services. Others, for
example Students for Disability Awareness, are broader and seek to foster disability activism
and social justice. One of the most well-known disability Facebook groups (see discussions in
Ellis & Kent 2011 and Haller 2010) is The Official Petition for a More Accessible Facebook.
The group was started by a student and prompted Facebook to address many of its
accessibility problems (Ellis & Kent 2011).
Li and Hamel (2003) cite actually navigating the physical University campus as a powerful
site of exclusion for students with disabilities and suggest technology as a way to mitigate this
by allowing students to work from home. However, if people with disabilities always stay out
of sight, disabling physical environments are unlikely to change, further excluding people
with disability. Digital technology is now providing a way to enable people with disability
greater access. Several iPhone applications (apps) such as the location based social
networking app FourSquare have pioneered this phenomenon. Community accessibility (Ellis
& Kent 2010) where other users contribute to a database of knowledge regarding the
accessibility of certain locations is having an impact on way finding for people with
disabilities using FourSquare. FourSquare is reported to enable students with vision
impairment a way to navigate around university campuses (Parry 2010). This revolution in
way finding is possible because it was made accessible and also invites the participation of
the wider community:
Foursquare is a city guide, friend finder, social network, game, and various other
things. Essentially with a compatible phone like an iPhone the GPS finds nearby
locations and you check in to the location using the app. Checking in just means you
are saying that you are at the given location. You can also see where your friends
are in your city and around the world though various screens and optional push
notifications. For instance, if I saw that [a friend was close by] I could (from the
Foursquare app) send him a text message, call him, or communicate via Twitter to
…see if he wanted to have lunch or a coffee. Each venue can also have tips which
users add. This is an area where foursquare can be used as an accessibility
wayfinding tool. For example, I was just at the Coolidge Corner station on Boston's
green line. I added a tip to the venue stating when you get off the train which side
of the tracks had even numbers on the street and which side had odd numbers. Thus
if another user accessed the stations tips, either while on the go or through the web
site, they would see that navigation tip which I added. (Mika cited on Shandrow
Web 2.0 is characterised by networks that get stronger the more people in and contributing to
them. Accessibility on web 2.0 applications gets stronger when the community of users
becomes involved (Ellis & Kent 2011). Following this user led revolution; there is now a
National Institutes of Health/National Eye Institute funded project in development at the
University of Massachusetts Amherst that provides students with vision impairments audio
instructions as a navigational aid (Callahan 2010).
Wikis, blogs and other user generated content are embraced within academia because of the
strong rhetoric that the current generation of students are digital natives and that these sites
can be easily accessed by anyone with an Internet connection. The use of online social
network sites has been shown to be beneficial within the requirements of a university
education . Significantly for students with disabilities, these sites reduce social exclusion and
increase independent study. However, Foley and Voithofer (2008) argue that the example of
students with disability shows that social computing environments are not always easily
While prolific disability and feminist blogger Chally uses wikis, text message and email to
interact with other Sydney uni students or collaborate on projects, her blog Zero at the Bone
provides her significant opportunity for inter-institutional interaction to engage in social
justice work and participate in online disability activism:
My blog work is very important for connecting with other people with disabilities
interested in social justice. I don't interact with disability justice work a lot offline,
because I usually don't have the time and energy to get out there and work in
community what with all the pressures of my disability and the rest of my life! With
blogs, I can sit at home in my own comfort zone and have amazing discussions.
With students in particular, sometimes I'll blog about university accessibility issues,
and we connect over that. There are lots of students in disability communities on the
Dreamwidth platform, too, for instance. There's a lot of opportunity for discussion!
(Personal communication.)
For Chally, avoiding the situation Foley and Voithofer (2008) describe is paramount and she
maintains a commitment to accessibility on her blog:
Where accessibility is treated as a hypothetical a lot of the time (we don't need a
ramp, we've never had anyone who uses a wheelchair in here!), basic ethics as well
as personal friendship means that I couldn't make my blog inaccessible in good
conscience. I try to reflect regularly on what I can do to make my blog more
accessible, and take into account every suggestion. I've had to stop using the
blockquote function as the blockquote colouring in my blog theme is light grey on a
white background. I had tried changing this by forcing it through HTML, but that
affected the colouring on my RSS feed, which of course many readers would use as
their own accessibility tool (you can modify textcolouring, sizing and so forth in
your feedreader). It's a pity, because this is the most accessible theme I could find
that fitted my purposes on my blogging platform, Wordpress. I transcribe or
describe videos, I describe images, I use descriptive text (or include title text) in my
links: I do whatever I can think of to make my blog an easy reading experience for
all my users. (Personal communication)
Thus there are many different ways to include and exclude people with disabilities on web
People with disability and educators are often “early adopters” of new technology seeing the
potential benefits of these technologies within their lives. This is most true of ICT; the web
has been variously described as “opening a new world” for people with disability, a
“solution”, and an exciting mode of inclusion (Ellis & Kent 2011). Likewise, the web 2.0
pedagogical benefits for learners and educators are celebrated in terms of opportunities for
collaboration, communication and documentation. Technology allows flexibility and is a key
driver in trends of flexible learning. Ironically however, with the move to web 2.0, learners
with disability who potentially benefit the most from these platforms experience disabling
limitations . Educators and policy makers need to be aware of digital disability and approach
disability from a social perspective. Students with disability must be included in this
potentially revolutionary environment. While my focus in this paper is on students with
disabilities as innovators of web 2.0 technologies, integral to this discussion is the
mainstreaming of accessible technologies.
Throughout Disability and New Media, a book I recently coauthored with Mike Kent, a
number of ways the web is disabling for people with disabilities are identified. As educators,
we found the example of students with disabilities particularly illustrative. We recognized that
the web was increasingly important within university education and highlighted several
platforms including virtual worlds, social networking, ebooks and some learning management
systems, as inaccessible for students with a variety of disabilities. However, several high
profile companies including Google, Apple and Facebook announced mainstream
accessibility measures as we were completing our research, and we ended the book with
“more hope than trepidation” (p 146). Many technologies including text-to-speech and
dictation software are now released on devices designed for a mass market such as Amazon’s
Kindle and Apple’s iPhone and iPad. Reena (2009) claims that these innovative and
convenient technologies are available to the mass market only because people with disabilities
pushed for innovation and improvement. In this way accessibility does not pertain solely to
disability and benefits other groups of people.
This paper is an extension of that hope and recognizes that both mainstream accessibility
measures as well as community accessibility is having a positive impact on the inclusion of
students with disabilities. By drawing together insights from people with disability across a
number of web 2.0 platforms including, blogs, discussion forums, email, Twitter, Facebook
and YouTube, I have sought to focus on communication as innovation and foreground the
actual lived experience of students with disabilities prompted, by web 2.0, to collaborate and
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The University where I work in Western Australia – Murdoch University – offers On
Track, a pre University program to facilitate entrance of non traditional applicants or
people who have had major disruptions to their life or study, including applicants
with a disability. See
Cite this article as: Ellis, Katie. 2011. ‘Embracing learners with disability: web 2.0, access and
insight’. Telecommunications Journal of Australia. 61 (2): pp. 30.1 to 30.11.
Wayne Hawkins
Australian Communications Consumer Action Network (ACCAN)
Australia’s broadband future has the potential to realise tangible benefits for consumers living
with disability. This paper discusses the importance of bridging the digital divide between
Australia’s disabled and non-disabled consumers, the role that broadband industry standards
can play in bridging this divide and the importance of including people with disability in the
development and promotion of best practice standards for broadband products and services.
The paper argues that through implementation of best practice ‘access-for-all’ standards for
broadband products and services, which have been developed in consultation with end-users
with disability, the implementation of a ubiquitous broadband network will help bridge this
digital divide and provide Australians living with disability increased inclusion and
participation in all aspects of Australian society.
Through the delivery of high principled, best practice standards that have been developed in
close consultation with people living with disability, it will be possible to ensure that the new
and emerging products and services that will undoubtedly result from the introduction of a
ubiquitous Australian broadband network will provide real and tangible benefits for
consumers living with disability; products and services providing levels of access that have
previously only been imagined by Australian consumers living with disability.
Including the end user with disability in the development of these best practice standards will
not only ensure their relevancy but will also ensure that people with disability will have a
greater sense of self-determination and benefit from products and services that make a
difference in their lives.
Just as standards have proven to be widely important in other industries, standards for
broadband products and services will improve the usability of new broadband applications for
the whole community, provide economy of scale savings in manufacturing and marketing and
most importantly provide greater access to full economic, social and cultural participation for
consumers living with disability.
Disability Standards for Access to Premises, for example, have benefitted the whole
community. The provision of access ramps for wheelchair users has also been beneficial for
parents with baby strollers, trades people and the elderly who find it easier to use a ramp
rather than climb stairs. In the same way, broadband-related standards that provide greater
access for people living with disability can also benefit the larger community.
Another example of how standards have assisted in the social inclusion of people with
disability in the Australian context is the Interactive Voice Response (IVR) standard for
telephone menu navigation. This was initially developed by the banking sector, and has been
adopted by the Australian Federal, State and Territory Electoral Commissions in the
Electronically Assisted Voting schemes designed to provide Australian voters who are blind
or vision impaired access to fully independent, secret and verifiable ballots.
Standards developed with consultation of people with disability will be essential in helping to
provide the benefits of broadband which can bridge the digital divide of economic, social and
cultural participation experienced by many Australian consumers living with disability.
While standards alone will not provide full accessibility to broadband services, they can foster
access for all design, increase interoperability and encourage the necessary market
environment for mass production of affordable and accessible ICT equipment and broadband
The introduction of Australia’s National Broadband Network (NBN) offers the opportunity to
provide unprecedented social and economic value for all Australians. The benefits for our
society at large – although the subject of some political debate – are increasingly obvious to
many commentators (Clarke 2009; Broughall 2010). However, the same benefits of increased
social and economic participation for the growing number of Australians living with disability
are very uncertain.
The Australian Bureau of Statistics (ABS) reported that 18.5 percent of the Australian
population reported having a disability in 2009. The percentage increased with age, with
approximately 6.6 percent of those aged 15 to 24 having a disability, compared to 40 percent
of those aged between 65 and 69, and 88 percent of those aged 90 years and over (ABS 2010).
With the ageing of the Australian population, it is likely that the numbers of people with
disability will rise.
While the discussion of how best to develop and implement high-speed broadband in
Australia has been hotly debated and which technology will provide the greatest utility has
been a political football (Gerrand 2010) the potential long-term benefits that a national highspeed broadband network will provide to the Australian population in general, and the
disabled community specifically, has not been in question.
With the introduction of the World Wide Web in the early 1990s and the increased take-up of
Internet connections, we have seen dramatic changes in the way we live, learn, conduct
business and connect with our families, friends and community. The Internet has transformed
many of the ways in which we manage finances, find employment, and shop for everything
from groceries to holidays, and stay informed and in touch.
The NBN will bring broadband data-transfers that offer speeds up to ten times that available
to residential users today. It is likely that this widely available, high-speed broadband
connectivity, which will be easily accessible by the majority of Australians, will result in an
increased number of new services, both public and private.
But many Australians living with disability will be unable to readily benefit from these new
services, or even from services available using current broadband speeds.
Consumers who are blind or vision-impaired, for example, need to have access to equipment
and services that are audio-enabled. This allows functional usability through spoken
navigation, instructions and applications that are not solely graphics-driven but offer
alternative text functionality.
Consumers who are Deaf or hearing-impaired need full functionality of products and services
via graphics and text utility. Deaf consumers will require operational functionality in
broadband products and services via Auslan (Australian Sign Language) or text captions.
Consumers with physical or cognitive disabilities or complex communication needs will only
be able to take full advantage of the benefits offered through ubiquitous broadband if their
access requirements are incorporated in the design of these new products and services.
The role of standards is to provide guidance for developers and manufacturers in the most
efficient and productive way in which to bring new technologies to market. They also serve as
an important mechanism in making technology more accessible to the whole of society, not
just for those living with disability. Standards that provide the greatest value are those that
incorporate consultation and input from the end user of the product or service.
Standards for ICT products and services have several facets including issues of highly
technical detail, interoperability, market forces and usability. The development of relevant,
robust and appropriate standards involve several key concerns: defining what should be
standardised; recruiting a balanced team of contributors; achieving consensus of stakeholders;
public consultation; implementation; and educating end users of the relevance of the standard
in a product or service. (Gill 2007)
There are a range of different categories of standards from voluntary industry guidelines,
national, regional and international best practice standards to national standards that are
adopted by government as essential requirements for legislative conformance.
One of the most relevant examples of best practice standards is the World Wide Web
Consortium’s (W3C) Web Accessibility Initiative’s development of the Web Content
Accessibility Guidelines (WCAG 2.0 2008).
These guidelines provide best practice advice on how to design and author web content in a
variety of languages and platforms that provide maximum usability, not only for people with
disability but also for all users of web content.
One way in which the WCAG 2.0 guidelines can help both people with disability and the
greater population is the recommendation to provide a text equivalent for every non-text
element. This enables screen reader software to verbalise the graphics function for computer
users who are blind or vision-impaired, while at the same time providing additional
information for users who may not immediately recognise the significance of a graphical
webpage link.
In the last decade there has been an increased focus, both in Australia and internationally, on
inclusive information and communication technology. In 2010 the Australian Government
made a commitment to adopt the WCAG 2.0 guidelines for all Government websites (Federal,
State and Territory). Consequently all Government websites will be WCAG 2.0 ‘A’ rated by
end of year 2012 and ‘AA’ rated by end of year 2014 (Dept. of Finance 2010).
Internationally there has been a growing effort to raise awareness, educate and develop
inclusion standards for ICT products and services. For example the European Union has been
developing ongoing accessibility awareness campaigns through the European Commission’s
eAccessibility initiatives.
The European Commission’s Mandate M-376 incorporates a range of standards that will help
ensure interoperability across its member states, avoiding a fractured marketplace and
fostering a market for affordable and accessible ICT products that are developed using the
principles of access for all.
Similarly, in the mid 2000’s Japan developed a range of ICT accessibility standards, JSI X
8341-3: Guidelines for Older Persons and Persons with Disabilities: Information
Communication Equipment, Software and Services. These included five key categories for
Common Guidelines;
Information Processing Equipment;
Telecommunication Equipment; and,
Office Equipment.
These guidelines were developed through consultation with all stakeholders, including people
with disability. Whilst developed as best practice standards, JSI X 8341-3 has been adopted
by manufacturers across Japan.
Japan’s standards body, Japanese Standards Association (JSA), aware that Japanese
manufactured products incorporating these standards would only be marketable
internationally if these standards were harmonised through International Standards
Organisations, submitted JSI X 8431-3 to the International Organisation for Standardisation
(ISO) for adoption.
Consumer advocates and disability organisations have lobbied long and hard to have ‘access
for all’ incorporated into information and communications technology both in Australia and
internationally. These disability organisations have worked with industry, standards bodies
and regulators to gain accessibility for people with disability in a range of ICT products and
services, from fixed line handsets to audio-enabled set-top boxes.
As a result of consumer consultation and lobbying, for example, Australia’s
telecommunications industry has adopted a Standard requiring a raised dot on the "5" button
on telephone keypads, for the benefit of consumers who are blind or vision impaired (ACIF
2001). As an example of how standards designed to assist people with disability have been
adopted for a wider range of uses, the raised dot has migrated to most other devices that use
the standard number keypad, such as banking ATMs, retail checkouts, calculators and most
recently, accessible voting kiosks in the Australian Federal elections for voters who are blind
or vision impaired.
Often products and services that have been designed for use by people with disability have
also proved to be of great value to the wider community. The telephone was initially invented
by Bell to assist people with hearing impairments and yet for most of the 20 th Century the
telephone was our most widely used mode of communication (Goggin and Newell 2004).
More recent examples of ICT products that have been designed to assist people with disability
and then adopted for wider use are call vibrating mobile telephones, volume control on
handsets and the display of captions on video screens in noisy environments. All three of
these widely adopted technologies were initially designed to assist consumers who are Deaf
or hearing impaired.
Unfortunately, many advances in access and the wider awareness of access barriers have been
driven mainly by the desire to avoid discrimination suits brought by people with disability
under the growing number of national and international anti-discrimination legislation
mechanisms, including the Australian Disability Discrimination Act 1992 (Cth) (DDA 1992).
One of the key international anti-discrimination mechanisms is the United Nations
Convention on the Rights of Persons with Disabilities 2006 which specifically addresses the
need to make information and communication technology accessible for people with
disability, Articles 4 (f), 9, 21, 30 (UNCRPD 2006).
The landmark Australian Human Rights and Equal Opportunity Commission (now the
Australian Human Rights Commission) decision of Scott v Telstra in 1995 provided the first
recognition of the right of people with disability to have equal access to information and
communication technology. The Commission handed down a ruling that consumers who have
a profound hearing loss must be given access to a teletypewriter (TTY) in the same way as
other consumers are given access to a fixed line handset (AHRC 1995). In a later, seminal
anti-discrimination case, Maguire v SOCOG in 2000, the Human Rights and Equal
Opportunity Commission ruled that the Sydney Organising Committee for the Olympic
Games (SOCOG) was discriminating by not making its website accessible for consumers who
used screen reader software because of blindness or vision impairment (AHRC 2000). These
two cases have helped to raise awareness of the barriers that people living with disability face
in accessing mainstream technology when such technology does not incorporate the principles
of Universal Design and access for all.
With the introduction of legislative and regulatory instruments such as the European Union’s
Mandate 376 (EC 2005), the United States Rehabilitation Act Section 508 (USRA 1973) and
the introduction of the US Government’s Twenty-First Century Telecommunications and
Video Accessibility Bill (H.r. 3301 2010), ICT products and services will need to meet
minimum accessibility standards in order to be viable in these major markets.
If Australia is not to become a dumping ground for the inaccessible ICT products that are
unmarketable in these overseas markets, it will be necessary for our own development of
minimum accessibility standards for all ICT products and services, particularly as new and
emerging services become available as a result of a ubiquitous broadband network.
Until now, much of the effort to make products and services accessible for all has been an
exercise in catch-up as governments, regulators and industry try to adapt ICT products and
services that have been developed with little awareness of the important benefits of including
our colleagues, friends and family members with disability.
The introduction of Australia’s NBN offers the opportunity to learn from these past
oversights. But essential in the development of these standards is a paradigm shift in the way
Australian society views disability. Increasingly disability is seen as the result of social
barriers rather than as a shortcoming intrinsic to an individual (Goggin and Newell 2003).
With the introduction of the NBN, Australia has, effectively, a clean slate – an opportunity to
change our mindset from viewing accessible ICT not as a bolted-on fix, but rather as an
‘access-for-all’ necessity built into all new products and services.
Through development of best practice standards and the promotion of ‘access for all’
principles in both the public and private sectors, we can bridge the digital divide that
continues to keep many Australians living with disability unable to fully participate in the
technology that underpins the way we participate economically, socially and culturally in the
21st century.
In the same way that the Web Content Accessibility Guidelines (WCAG 2.0 2008) provide
best practice standards in developing accessible websites, best practice standards for products
and services developed for broadband will provide greater access for people living with
High-principle, technology-neutral standards for user interfaces that include accessible
functionality for all will not only make it possible for people with disability to participate,
they will make access for all more efficient, decrease the need for specialised, high-cost
adaptive equipment and incorporate the principles of inclusion enshrined in the United
Nation’s Convention on the Rights of People with Disabilities.
The accessibility standards that have been developed by the W3C can provide guidance on
how we can develop standards for broadband products and services that will increase
functionality and usability for all members of our society.
If Australia is to bridge the digital divide as we transform our e-infrastructure to the NBN, it
is absolutely essential that the development of standards should incorporate both a heightened
awareness of the benefits for all of high-principle best-practice guidelines, and consultation
with and input from end users with disability.
There is a range of barriers that confront people with disability in accessing broadband: the
cost of service and equipment; inaccessible hardware, software, services and web content; and
a lack of training and awareness of the opportunities that broadband services can offer.
A number of Standards would need to be developed in order to ameliorate these barriers. For
examples, Standards could cover:
Equipment, to incorporate the principles of Universal Design to ensure broad
usability and built- in interoperability with assistive technologies;
high-quality captions for all video content broadcast via broadband; and
high-quality audio description for all video content broadcast via broadband and;
graphical user interfaces for services offered via broadband that have both captioned
and text descriptors for all text equivalent operations.
With the roll out of Australia’s ubiquitous broadband network, there has been much talk about
a range of new in-home services that will be possible with the always-on high capacity
broadband connection - smart homes, smart grids, home security systems etc.
In order for these broadband services (which will increasingly be accessed via touch-screen
graphical user interfaces) to be accessible to people with disability it will be essential that
they are developed using the access for all principles of Universal Design.
One of the many potential benefits that the NBN offers us is the development of e-health
services in the home for people in regional or rural Australia. Ironically the target audience
for this type of broadband service will in many cases be people living with disability.
However, without accessibility features built into the user interface and operating hardware,
and Universal Design features incorporated into the development of an e-health network, the
potential benefits this type of broadband application could offer will not be available for
consumers with disability. On-screen menus and instructions would need to be verbalised for
consumers who are blind or vision impaired; all spoken instructions and communication
would need to be provided in text captions for people who are Deaf or hearing impaired;
controls would need to be designed for ease of use by consumers with physical or dexterity
impairments; and the user interface would need to be compatible with Braille displays for
consumers who are deafblind, and augmentative communication for consumers with complex
communications needs.
The creation of best practice touch screen standards developed in close consultation with end
users with disability will help developers, engineers and manufacturers design systems that
benefit all broadband consumers including those living with disability. With such standards
guiding uniformity of operation and functionality, touch-screens will enable people with
disability to effectively and efficiently interact with and benefit from these broadband
Because the incidence of disability increases with age, and as the Australian population ages,
the number of consumers who will need to have fully accessible ICT products and services
will increase. For example, the current estimate of the number of Australians living with
blindness or vision impairment is close to 400,000 and expected to double by 2020 (ABS
Another life-changing service that broadband is likely to facilitate is accessible e-learning,
which, by providing greater educational choice for people with disability, could improve
employment options for people with disability, a group which has experienced high levels of
unemployment and underemployment. In the Vision Australia 2007 Employment Report, 63
percent of Australians who are blind are either unemployed or under employed and of those
who are employed only ten percent have a weekly salary over $1000 (Vision Australia 2007).
Access to broadband services for people with disability has the potential to change this long
entrenched inequity of employment opportunities. A recent American study, for example,
asserted that broadband is expected to increase the level of tele-employment of people with
disability in one organisation by 100 percent (Lyle 2010).
In order for broadband to fulfil the promise of improved opportunities for people with
disability, through high-level, best practice standards – developed in close consultation with
the end users with disability – must be promoted within government, industry and the
disability sector.
National and international organisations are currently working on developing accessibility
standards for ICT. In November 2010 the World Standards Cooperation (WSC) convened an
international workshop on Accessibility and the Contribution of International Standards. This
workshop brought together experts from all stakeholder groups to discuss how to increase
development, promotion and adoption of accessible ICT standards. It included representatives
from industry, national and international standards bodies, regulators, government, consumers
and people with disability for three days of workshops, presentations and engagement.
The 2010 WSC E-Inclusion and E-Accessibility forum of the workshop recognised the
importance of awareness raising in the role standards can play in ameliorating barriers to ICT
accessibility. The workshop consequently made the following recommendations to enhance
the adoption of standards for accessible ICT products and services:
Identify major gaps in ICT accessibility standards present and future;
Develop harmonised definitions and metrics;
Bring standards into the education process; in particular train people with disabilities
Prioritise standards development/adoption to achieve maximum benefits as soon as
possible, thereby freeing up resources to target more “specialised” standards needs;
Include PWDs in the development process;
Make education and curricula for developers accessible and raise funds to train
Include standards in curricula; and
Create an accessible, open e-learning platform, and use it also for remote
While many Standards organisations are increasingly raising awareness of the value that
accessibility Standards in ICT products and services provide, it is essential that people living
with disability are included in the Standards development process and that when ICT access
Standards have been developed they be adopted into the education of ICT developers and
Australian researchers, Dr Scott Hollier and Dr Denise Wood, understanding the importance
of promoting standards in the education curriculum for developers, have developed an
accredited Unit of Study which is to be offered Starting in 2011 through the University of
South Australia. This professional unit of study, Professional Certificate in Web Accessibility
Compliance, is a collaborative endeavour between the University of South Australia and
Media Access Australia. Through its focus on adoption of the WCAG 2.0 guidelines, this
accredited Unit will increase awareness and implementation of standards that will make web
content more accessible for all Australians not just those with disability.
The implementation of a national broadband infrastructure offers the Australian economy and
society the possibility of unprecedented opportunities in the way we engage in all aspects of
life. The NBN has been hailed by many as a general purpose technology enabler like the
steam engine, railways and electricity. Just as the electricity network led to numerous farreaching social and economic changes, ubiquitous broadband may have ripple effects in our
lives over the coming years in ways that cannot yet be imagined.
However, without a concerted move to developing and promoting high level best practice
accessibility Standards for ICT equipment, applications and services Australia’s four (4)
million citizens living with disability (ABS 2011) will be further excluded and disadvantaged.
Including consultation with people living with disability in the development of these
broadband industry standards will ensure that the end user with disability has the greatest
opportunity to benefit from the potentially life transforming possibilities that ubiquitous
broadband can provide.
With greater adoption of the development of standards for ICT by industry, government and
academia, broadband products and services can become the life changing opportunity capable
of transforming the lives of many people living with disability in Australia.
Australian Bureau of Statistics (ABS). 2011. ‘4446.0 - Disability, Australia, 2009’, accessed 2
May 2011. Available from:
Australian Bureau of Statistics (ABS). 2010. ‘4430.0 - Disability, Ageing and Carers,
Australia: Summary of Findings’, accessed 12 January 2011. Available from:
Australian Communications Industry Forum (ACIF), AS/ACIF S040. 2001. ‘Requirements
for Customer Equipment for use with the Standard Telephone Service - Features for
special needs of persons with disabilities’, Australian Standard, Australian
Communications Industry Forum, accessed 12 January 2011. Available from:
Australian Government Department of Finance and Deregulation. 2010. Web Accessibility
National Transition Strategy, accessed 12 January 2011. Available from:
Australian Human Rights Commission (AHRC). 2000. Maguire v SOGOC, Accessed 12
January 2011. Available from:
Australian Human Rights Commission (AHRC). 1995. Scott v Telstra, Accessed 12 January
2011. Available from:
Australian Human Rights Commission (AHRC). 1992. Disability Discrimination Act,
accessed 12 January 2011. Available from:
Broughall, Nick. 2010. ‘The Internet Industry Association Supports the NBN’, Gizmodo,
accessed 12 January 2011. Available from:
Clarke, Trevor. 2009. ‘NBN Survey: Seven top ICT analysts think the NBN will be worth the
money spent’, ARN Online, accessed 12 January 2010. Available from:
_will_worth_money_spent /
European Commission (EC). 2006. Mandate M376, accessed 12 January 2011. Available
Gerrand, Peter. 2010. ‘The National Broadband Network: the defining issue in Australian
politics in 2010’, Telecommunications Journal of Australia, Vol.60 No.4. Available from
Gill, John. 2007. Involving People with Disabilities in the Standardisation Process, accessed
12 January 2011. Available from:
Goggin, G; Newell, C. 2003. Digital Disability: The Social Construction of Disability in New
Media, Rowman & Littlefield, Lanham, Massachusetts, United States.
Goggin, G; Newell, C. 2004. ‘Disabled E-Nation: Telecommunications, Disability and
National Policy'. Prometheus: Journal of Issues in Technological Change, Innovation,
Information Economics, Communication and Science Policy, 22. 4 (December 2004):
Lyle, Elizabeth. 2010. A Giant Leap and A Big Deal: Delivering on the Promise of Equal
Access to Broadband for People with Disabilities, accessed 12 February 2011. Available
UNCRPD. 2006. United Nations Convention on the Rights of Persons with Disabilities
Accessed on 12 January 2011. Available from:
United States Congress. 2010. Twenty-First Century Communications and Video Accessibility
Act of 2010, accessed 12 January 2011. Available from:
United States Rehabilitation Act. 1993. Section 508 amendment, accessed 12 January 2011.
Available from:
Vision Australia. 2007. Employment Report I, accessed 12 January 2011. Available from:
W3C Web Content Accessibility Guidelines (WCAG 2.0). 2008. accessed 12 January 2011.
Available from:
Cite this article as: Hawkins, Wayne. 2011. ‘Broadband, disability and the role of standards’.
Telecommunications Journal of Australia. 61 (2): pp. 31.1 to 31.9.
Warwick Davis
Frontier Economics
Recent developments in Australia have seen the telecommunications regulator, the Australian
Competition and Consumer Commission (ACCC), propose to step away from the use of
hypothetical cost models to set access prices for Telstra’s fixed line network, and move
towards a ‘utility style’ framework based on the recovery of historically-incurred costs. The
ACCC has been bolstered by a recent decision from the review body, the Australian
Competition Tribunal, which cast doubt on the adequacy of Telstra’s modelling of
hypothetical costs. The implications of the shift are profound for Telstra, but could also be
significant for other regulated entities including mobile operators and the new national
broadband company NBN Co.
Attention in Australian media and policy circles is very much focused on the National
Broadband Network. However, quietly in the background there have been regulatory
developments that are likely to have an equally meaningful – but probably more short-term –
effect on Telstra, access seekers and end-users. The developments relate to the way that the
ACCC sets prices for accessing Telstra’s existing copper network. A combination of new
legislation, giving the ACCC new powers under the (renamed) Competition and Consumer
Law Act 2010, and a re-evaluation of the principles by which these prices have been set, is
likely to result in a comprehensive overhaul of existing regulatory policies.
This paper has three aims. The first is to provide some (post 1997) historical context and
narrative to access price setting for fixed line telecommunications in Australia. The second is
to explore the underlying reasons that have contributed to the change in access pricing
approach. The third is to consider some possible implications of the change; not just for fixedline services, but for other services that the ACCC regulates, or may in future regulate.
To understand why the ACCC is re-visiting its approach to access pricing, it is helpful to step
back to 1997.1 At this time, the ACCC released its first set of pricing principles for
telecommunications services (‘1997 Guide’). The 1997 Guide was issued shortly after the
introduction of open entry into the telecommunications sector and the commencement of the
telecommunications access regime. It laid the foundations for the ACCC’s approach to
pricing telecommunications access services.
At the time, there was much optimism about the prospects of ‘full’ facilities-based
competition between fixed access networks; that is, duplication of Telstra’s copper network.
These expectations had been heightened by Optus’s – ultimately ill-fated – investments in a
hybrid fibre-coaxial network. As will become clear, these expectations were important to the
choice of pricing methodology.
The Part XIC access regime introduced in 1997 was to apply to ‘declared’ services;
essentially, those services which had monopoly or bottleneck characteristics. In the first
instance, prices for these services were to be negotiated between access providers and access
seekers. When the ACCC was required to intervene – for example, when considering whether
to approve an access undertaking by an access provider, or to issue a final determination in an
access dispute – it had to take into account certain legislative criteria, including:
The long-term interests of end-users (LTIE), comprising:
Promotion of competition in markets for relevant services
Any-to-any connectivity
Economically efficient use of and investment in infrastructure
The legitimate business interests of the access provider
The interests of access seekers
The direct costs of providing access2
The economically efficient operation of a network, service or facility.
In setting access prices to meet these criteria, the ACCC faced two difficulties.
The first is that no one access price can best meet each of the criteria and, therefore, trade-offs
between them will be inevitable. 3 A regulator would want to ensure that prices are high
enough to provide a return sufficient to maintain and invest in the network, but not so high as
to allow returns on imprudent investments.
A second difficulty is that all regulators have imperfect information regarding the factors
needed to establish access prices that best meet the objectives and criteria. That is, there will
be an information asymmetry between the regulator and regulated firm. The regulated firm
will always know more than regulator about its:
costs and demand for its services; and
actions, particularly its ability to reduce costs.4
A regulated firm commonly has little or no incentive to reveal this information to the
regulator. Rather, the firm would like to convince the regulator that it faces high costs and low
demand, so that the regulator will then set high prices for the services it provides; thereby
increasing the regulated firm’s profits. The conventional regulatory approach to addressing
this incentive problem is to break the link between actual costs and prices, and, where
possible, to provide firms with incentive to reveal accurate information about its costs
(Laffont & Tirole 2000). A regulator can do this by allowing the regulated firm to retain some
profits from its cost-reducing efforts: for example, by setting a cost forecast and allowing the
regulated firm to keep any profit if costs are less than forecast, the regulator may gain
valuable information about the true level of costs when setting prices for the next regulatory
In selecting an access pricing approach for fixed line services, the ACCC had to balance these
various considerations. The decision it made was that for ‘mature’ services, access prices
should be no more than the total-service long-run incremental cost (TSLRIC) of providing the
relevant access services (ACCC 1997).5
TSLRIC is best understood by explaining its three key components:
The ‘total service’ (TS) refers to the production of an entire service, which includes
both the access service supplied to access seekers and the access provider’s
equivalent self-supplied service. For example, the total service in the supply of the
unbundled local loops supplied to access seekers also includes the local loops that
Telstra, as the access provider, uses itself. This enables both parties to benefit equally
from any economies of scale or scope in providing that service.
‘Long run’ (LR) means that all factors of production (capital cost, labour and
materials) are able to be varied and form part of the cost increment (or ‘incremental
cost’ as described below).
‘Incremental cost’ (IC) is the additional costs to the access provider of producing the
total service compared to not producing it at all.
To calculate the unit costs (and price) of supplying the total service, the incremental cost is
annualised and divided by the total annual service units that are demanded. This means that
TSLRIC leads to prices that are based on the average costs of providing a total service, not
marginal costs of supplying additional units of output.
The ACCC also provided some further guidance to on how it proposed to implement TSLRIC
in its 1997 Guide.
The first point was that TSLRIC was to be estimated using forward-looking replacement
costs.. Estimation of TSLRIC-based prices using forward-looking replacement costs assumes
that a network is built ‘as new’ at the start of the price-setting period. 6 This meant that, unlike
in other utility industries, the depreciated value of Telstra’s network did not have to be
estimated, and that there was no clear link between the depreciated value of actual
investments and access prices, which were based on the undepreciated TSLRIC-based
replacement cost valuation.
The second point was that the costs should be those incurred in providing services using bestin-use commercially available technology and production processes. In other words, some
optimisation was to be applied to ensure that TSLRIC would be an estimate of the
economically efficient cost of supplying the access service. The qualification is that available
efficiencies have been limited to take account of the existing network design, particularly with
respect to the location of exchange nodes in the fixed network (ACCC 1997, 36-38). This is
referred to as a ‘scorched node’ approach to network optimisation, which contrasts with a
‘scorched earth’ approach where no such constraints on the location or number of nodes is
A key reason for adopting optimised replacement costs was that the ACCC originally thought
that Telstra’s historic costs of building its network may have been inflated above efficient
levels, and that setting access prices using these costs could encourage inefficient bypass
decisions by access seekers – building when it would be more efficient to buy access. In
practice, this assumption has proved incorrect, with modelling of the copper fixed line access
network now commonly indicating increasing replacement costs for the network as a whole. 7
The ACCC has also allowed inclusion of indirect costs (such as corporate overhead costs) that
would be incurred by an efficient wholesale firm. This has been designated by the addition of
the term ‘+’ to form the acronym TSLRIC+.8
We can therefore see how the ACCC, in choosing a TSLRIC methodology with the specific
implementation details described, made the necessary trade-offs:
the TSLRIC approach was to allow for full cost recovery (albeit of a hypothetical
efficient network); not just recovery of marginal or incremental costs of a particular
by allowing recovery of the optimised replacement costs of the fixed network, and not
actual costs, there would be incentives for access providers to produce efficiently; but
optimisation would be curtailed to reflect more commercially-feasible efficiencies.
The ACCC received support (either directly or by implication) for TSLRIC from a number of
sources, including the Australian Competition Tribunal (Tribunal), international regulators
and other industry sectors.
The Tribunal has reviewed a number of the ACCC’s decisions where TSLRIC pricing has
been as issue. In 2004, the Tribunal strongly endorsed its use, holding that:
…in our view, it would generally not be in the LTIE to depart from TSLRIC pricing
where access is regulated. Accordingly, where an access regime requires, or creates
an unacceptable risk, of non-TSLRIC pricing, the Tribunal considers that such a
regime is unlikely to encourage the efficient use of, and investment in,
infrastructure. (Tribunal 2004a)
There was also a considerable degree of support for a long-run incremental costing approach
in overseas jurisdictions, including the United States, Europe and New Zealand:
In the United States, the Federal Communications Commission (FCC) required State
utility commissions to price local access services on the basis of total element long
run incremental costs (TELRIC). This involved pricing individual network elements
(such as switches, transport and loops) rather than access services, so an access seeker
could then aggregate them to deliver retail services. Otherwise, the application using
forward-looking costs and the existing network nodes was virtually identical to
TSLRIC as applied in Australia. The FCC’s TELRIC methodology, first introduced in
1996, was subject to legal challenge by incumbent local exchange carriers. While
initially successful at the US Court of Appeals, the challenge to TELRIC was finally
rejected by the US Supreme Court in 2002 (Verizon et. al. v FCC 2002). A majority
opinion found that the FCC was not acting unreasonably in choosing an optimised,
forward looking costing approach.
The majority of Western European incumbent telecoms operators had their
interconnect prices determined on the basis of a long-run incremental cost (LRIC)
methodology. This was driven in large part from the European Commission’s 1997
directive on ‘cost orientation’ for operators with significant market power (SMP) and
subsequent recommendation on the use of forward looking LRIC. The LRIC
methodology with allowance for common costs was in practice close to identical to
TSLRIC (European Commission 1998).
The telecommunications specific access regime in New Zealand, under the
Telecommunications Act 2001, specifically set TSLRIC pricing principles for a
number of regulated services (Commerce Commission 2009)
TSLRIC also survived relatively unscathed through the Productivity Commission’s 2001
review of Telecommunications Competition Regulation (Productivity Commission 2001).
Although extensive submissions were made and an appendix was devoted to exploring the
arguments for and against TSLRIC, the Productivity Commission criticised the ACCC for
pricing below long-run efficient costs but did not explicitly object to the continued use of
TSLRIC (Productivity Commission 2001, 398).
Arguably, the ACCC’s approach in telecommunications was also consistent with its approach
to the regulation of other industries like electricity and gas transmission networks. In
particular, the use of optimised, replacement cost asset valuations (as used in TSLRIC) was
endorsed for these industries. In a 1999 statement on the regulation of electricity transmission
networks, the ACCC suggested that an optimised replacement cost asset valuation approach
had significant advantages on economic efficiency grounds (ACCC 1999).
By the middle of the last decade, TSLRIC had received endorsement from a wide range of
parties. Nonetheless, some nagging doubts remained about its utility. Conceptually, these
doubts included a concern about whether TSLRIC was necessary to encourage efficient ‘build
or buy’ decisions by access seekers, and whether, because it implied ongoing optimisation of
Telstra’s copper network, it might prove to be a form of regulatory expropriation. 9 However,
and perhaps more importantly, doubts were also being expressed because there was little
success in actually agreeing a set of modelling principles, and developing a predictable and
stable time path of access prices.
In part, the more practical problems were exacerbated by fundamental flaws in the access
regime itself. Part XIC at the time provided no formal power for the ACCC to set prices over
a defined period across access seekers, as its role was limited to conducting arbitrations and
assessing undertakings. The structure of Part XIC also discouraged certainty, and various
minor reforms have been ineffective in reducing disputation between Telstra and access
seekers (Department of Broadband, Communications and the Digital Economy 2010). Some
of these problems may be resolved with a new set of reforms introduced late in 2010, as
discussed later in this paper. Having said that, many of key TSLRIC implementation issues
have never been satisfactorily resolved, and this has undoubtedly contributed to its demise.
In the following section, we analyse the two purported comparative strengths of forwardlooking TSLRIC methods. Then we comment (to the extent they are separable) on the
practical problems with implementing it effectively.
The ACCC’s two primary conceptual bases for using TSLRIC to set access prices were that it
1. Encourage efficient ‘build or buy’ signals for access seekers.
2. Provide appropriate incentives for access providers to be efficient, but also allow for
recovery of efficiently-incurred costs, and would therefore not deter new investment
(ACCC 1997).
The ‘build or buy’ motive for using TSLRIC is now recognised as being significantly
oversold – if not entirely discredited. The ACCC now accepts that, despite expectations that
there was a greater potential for infrastructure-based competition in telecommunications than
in other regulated industries, Telstra’s copper customer access network was “more of the
character of an enduring bottleneck” (ACCC 2009b, 16).
The original ‘build or buy’ rationale for TSLRIC prices was that inefficient bypass might
occur if access seekers compared ‘build’ costs on the basis of efficient, forward-looking costs
with ‘buy’ costs based on historic costs (ACCC 1997, 29, fn 36). So, an entrant, when faced
with an access price based on historic costs that no longer reflect efficient best practice, might
inefficiently bypass the incumbent’s network (build) when it would in fact be more efficient
to buy access. For example, if the access price when based on historic cost was 100, but only
80 when based on efficient replacement costs, then the access seeker might inefficiently enter
if its costs were below 100 but above 80.
At face value, this logic seems sound. However, the argument intrinsically rests on a
‘contestable market’ standard in which sunk costs (those investments which have no value in
an alternative use) do not exist.10 It therefore ignores the role of cost structure: most of the
incumbent’s costs are sunk, while an entrant’s costs only become sunk once the decision is
actually made to enter. The entrant will need to consider what will happen if it does enter.
Prices will not be determined by sunk costs, but by the incumbent’s marginal costs of
producing a service - because it will be more profitable to sell at this price than to let the
entrant make a sale. Therefore, the entrant must be confident that it can recover its sunk
capital costs even though the incumbent will price down to its marginal costs. Unless the
incumbent is tightly constrained by other regulations, this seems highly implausible.
Therefore the likelihood is that prices will have to be a lot higher than 100 (in the example
above) to drive entry, so TSLRIC may in fact be no better at promoting efficient build or buy
decisions than historic costs.
The second conceptual issue is whether the TSLRIC approach can allow for recovery of costs
that are efficiently incurred, or, more colloquially, whether it could provide a ‘fair bet’ for
Telstra: that when it makes investments, it can expect to recover the costs of the investments.
If that is not the case, then the long-term viability of the approach must be questioned, and
other access pricing or costing methods should be preferred. 11
It is difficult to determine whether TSLRIC creates under-investment problems, and, if it
does, whether these problems arise from conceptual problems with TSLRIC or just particular
implementations of TSLRIC. In highly simplified settings, it is trivial to show that TSLRIC
can be consistent with recovery of efficient costs. But, as one moves into the realm of the real
world, the treatment of technological progress and asset optimisation creates uncertainty for
the access provider about whether even efficient costs can be recovered. Four points can be
made in this regard.
First, forward looking pricing concepts such as TSLRIC create uncertainty for both the access
provider and access seekers, and, unless the expectations set at the commencement of the
preceding regulatory period are exactly realised 12, then the access provider will be subject to
windfall gains or losses.
Second, while, of itself, uncertainty is not a desirable feature of a regulatory regime,
economists recognise that it can have an important role to play in encouraging efficient
behaviour. Recovery of actual costs, regardless of the prudence with which they are incurred,
provides minimal incentives for the access provider to be efficient. Risks introduced by the
use of forward-looking costs and optimisation can be used to drive efficiency (King 1996).
Third, if TSLRIC is to promote efficient investment, the risks must be symmetric, giving
probability of upside to the access provider as well as downside. Many of the risks that
change allowable TSLRIC costs over time do appear to be symmetric, so long as the forecasts
used are unbiased and sufficiently account for future network optimisation. For example,
foreseen optimisation, or simply falls in new asset prices, can be accounted for by anticipating
these changes in annual capital charges. The risk then borne by the access provider is that the
forecast optimisation or decline in prices proves inaccurate. For example, if replacement costs
of an asset are forecast to fall by 10% over the next regulatory period, but in fact fall by 20%,
then the access provider will not recover the TSLRIC costs specified at the start of the first
period. But equally, if replacement costs do not fall at all, then the access provider will over
recover (the initially-specified TSLRIC) costs.
Fourth, recent research indicates that there are some reasons to think that forward-looking
costing approaches like TSLRIC might not induce efficient investment as well as other
costing approaches, as they create costs that are not inherent in other approaches.
Evans and Guthrie argue that because TSLRIC approaches shift risk onto the access provider,
the access provider will need higher revenue to break even on new investment (so that net
present value equals zero, the minimum condition under which a firm will invest). This extra
revenue is required to cover the expected cost of asset under-utilisation in the future, as these
costs will be optimised out by the regulator, and to deliver the higher returns needed to
compensate for the increased risk from capital price and demand uncertainty (Evans &
Guthrie 2005).
Further, Guthrie, Wright and Small find that forward-looking cost rules (like TSLRIC) are
dominated by backward-looking cost rules (like historic cost) when the objective is to induce
investment, regardless of whether forward-looking costs are rising or falling over time. The
intuition behind this result is that where forward-looking costs are rising, allowing recovery of
either backward-looking costs or forward-looking costs induces investment, but backwardlooking costs will be lower and therefore deliver lower prices. Conversely, when forwardlooking costs are falling, backward-looking rules imply higher prices but do much better at
encouraging a firm to invest earlier than it would under a forward-looking cost rule. The
authors find the gains from encouraging earlier investment are likely to outweigh the losses
from the higher prices (Guthrie et al 2006).
These conceptual concerns should make a regulator wary of the use of forward-looking
costing methodologies like TSLRIC to set and re-set access prices over long periods. The
potentially superior incentive properties of TSLRIC compared to a costing framework using
actual or historical costs would need to be substantial to overcome the inherent disadvantages.
At this point, it is also worth briefly considering the conceptual criticisms of cost-based
access pricing (including forms like TSLRIC) that have been raised by economists. Perhaps
the best known is that developed by Baumol and Willig – the efficient component pricing rule
(ECPR) – and extended by Laffont and Tirole – a global price cap, which incorporates both
access and retail services (Baumol & Willig 1994a) (Laffont & Tirole 2000).
The Laffont and Tirole critique of cost-based pricing essentially rests on a basic proposition.
If the access provider is a monopoly, but is forced to set cost-based prices in that (upstream)
market, then it will want to try and capture some monopoly profits by acquiring market power
in the market downstream from the monopoly input. Conversely, if access price regulation
allows for access sales to be as profitable as retail sales, then the access provider will be
happy to sell on a non-discriminatory basis because this will maximise its profits. The tighter
is the upstream price regulation, the more the monopoly will lose and the more it will be
worth denying access or somehow raising its rivals’ costs.
These are far from theoretical concerns. The Federal Court fined Telstra over $18 million in
2010, on the basis that Telstra had blocked competitors from accessing its local exchanges by
telling them that the exchanges were full when they were not (Federal Court 2010).
The ECPR and global price cap access pricing rules address such discrimination concerns by
allowing the access provider to make a margin on access sales that is similar to the margins
made on retail sales. This reduces or even eliminates the incentive problem inherent in costbased regulation of access. But each rule creates new problems. The ECPR does not address
concerns about excessive returns earned in the (monopoly) supply of access services. A global
price cap would allow for normal economic returns overall, but would require regulating both
access and retail markets. This does not seem desirable and runs counter to the Hilmer
approach of deregulating competitive or potentially competitive market segments
(Independent Committee of Inquiry 1993). Neither approach has been seriously contemplated
as a universal access pricing solution in telecommunications.
Estimating TSLRIC requires estimation of a ‘modern equivalent asset’ that would be built to
provide service today and into the future. It is an imaginary cost of an imaginary network,
and, that being the case, it can be imagined in different ways.
Perhaps symptomatic of the general lack of agreement about how to implement a TSLRIC
approach in Australia is the proliferation of models that have been used to estimate TSLRIC
prices. The ACCC has commissioned two of these models (the NERA model and the
Analysys model, named after the firms that were hired to construct them), while Telstra has
developed three (known as PIE I, PIE II and TEA).
In this paper, I cannot hope to exhaustively analyse the disputes about how to correctly
implement a TSLRIC model of the fixed network. Rather, it may be helpful to break down the
major implementation problems into three sets of issues. 13
It is common ground that TSLRIC attempts to measure the efficient forward-looking costs of
supply. But whose supply, and what constraints are assumed to apply to it? As we have seen,
the ACCC has preferred models of the incumbent’s existing network architecture, rather than
that of a new entrant, unconstrained by the incumbent’s past decisions. But how far does this
extend? In a recent Tribunal decision (Tribunal 2010), the Tribunal rejected the use of
Telstra’s TEA model on the basis that the ‘new entrant’ approach to modelling costs that was
implied by the model was undermined by the model’s use of much of Telstra’s existing
network architecture.
The Tribunal did not directly address whether this was a difficulty with the scorched node
approach itself, or just Telstra’s implementation of it, but is hard to see how it is not an attack
on the former:
231. The TSLRIC+ approach seeks to estimate Telstra’s ongoing costs of providing
the ULLS. But on the face of it Telstra’s ongoing costs have nothing to do with
those of a hypothetical new entrant to the market providing the declared service,
especially as the TEA Model is premised on a scorched node approach. 14 (Tribunal
The Tribunal’s position here points to the inconsistency between arguing, on the one hand,
that the cost of a new network should be modelled to ensure that an access seeker faces the
right build or buy decision, and, on the other, arguing that the incumbent’s network design
decisions should be taken into account because that would be fairer to the incumbent. No
single approach can achieve both objectives.
As already noted, the ACCC’s position is that what should be modelled is the efficient costs
of the incumbent (ACCC 2009c). The trade off made undermines the build/buy incentive for
access seekers. If an incumbent does have certain cost advantages deriving from a legacy
network, and these are incorporated into the TSLRIC model, then an entrant that is equallyefficient in all other respects will rationally choose to buy access rather than build.
Disputes about appropriate inputs for costing purposes are, of course, common to all costing
approaches. Any approach must make decisions about the way in which capital costs are
recovered (asset lives and path of depreciation) and a reasonable rate of return (ordinarily,
based on an estimate of an efficient firm’s weighted average cost of capital). Needless to say,
these have been areas of great controversy between the ACCC and Telstra. 15
When compared with simpler regulatory approaches based on depreciation of actual costs
incurred, the additional burden that TSLRIC modelling imposes is the greater degree of
foresight required. Such models require long term forecasts of future asset price changes and
assumptions about obsolescence of assets. Although this may be easier for civil works, as
labour costs are relatively predictable, for other assets these forecasts and assumptions are
highly speculative in an era of rapid technological change.
Although setting TSLRIC-based prices for the first time has proved contentious, arguably the
greater challenge is how to update the costs and prices.
This has been a particular source of concern for Telstra, and for regular Telstra adviser, Henry
Ergas. Ergas has repeatedly criticised the ACCC for introducing ‘time inconsistency’ by
setting a path for (rising) prices at the outset of the regulatory period (2000/2001) that have
turned out to be inconsistent with those actually set in subsequent regulatory periods –
because prices have not risen in accordance with the price path set in the first TSLRIC model
(Ergas 2008a; 2008b; 2009). The ACCC denies these claims, noting that earlier costing
models were less sophisticated, and by arguing that costs have fallen because earlier models
simply estimated costs that were too high (ACCC 2007b, para 423).
The Commerce Commission in New Zealand has encountered a similar problem with
TSLRIC. It uses a TSLRIC model to estimate the net costs of the telecommunications service
obligations (TSO) imposed on Telecom New Zealand. The Commerce Commission found
that continuing to optimise Telecom’s network over time in annual TSO determinations
would be inconsistent with the assumptions made about recovery of depreciation in earlier
periods and would likely result in cost under-recovery. It elected to solve this problem by
essentially ‘locking in’ the TSLRIC values and committed to no longer optimising Telecom
New Zealand’s network by assuming an efficient operator would use new technologies
(Commerce Commission 2008).
To summarise, the implementation of TSLRIC is far from straightforward, and has led to
considerable argument over the past 10 or so years. Key implementation decisions are still not
agreed between the ACCC and Telstra, and even the Tribunal has expressed frustration with
the current state of affairs. Indeed, the Tribunal, after being such a strong advocate for
TSLRIC, has now expressed serious reservations over the TSLRIC approach (Tribunal 2010):
Quite separately, the Tribunal notes that the ACCC proposes to examine TSLRIC+
as part of its review of pricing principles. The Tribunal encourages that review and
the consideration by the ACCC of alternative pricing regimes, for example whether
pricing on the basis of depreciated optimised replacement cost [DORC] might be
Alternatively, if TSLRIC+ continues to be preferred, more guidance needs to be
given on how it should be implemented17.
By 2009, the ACCC had developed its own cost model capable of setting TSLRIC-based
prices (Analysys model), and proposed in a draft report to use the outputs from this model
(ACCC 2009b). However, the model was never actually used to set indicative or arbitrated
Quite when the ACCC started to turn away from TSLRIC is unclear. Its Analysys model was
commissioned in February 2007, but it seems plausible that, by then, developments
surrounding the national broadband network had crystallised reservations that the ACCC had
been having about the use of forward-looking cost models to set prices. Later in 2007, a group
of nine access seekers (known as the G9) submitted an access undertaking for a fibre-to-thenode (FTTN) network. In a draft decision on the G9’s undertaking (which was withdrawn
before a final decision), the ACCC noted that it was not bound to a TSLRIC approach, and
that access providers could propose alternative methodologies, perhaps reflecting changing
conditions in markets or for pricing new, as opposed to legacy, networks (ACCC 2007b).
The NBN tender process likely provided a further point of reflection for the ACCC. The cost
of the new investments needed to build an NBN would need to be recovered. An access
provider would want some certainty that its actual costs would be recovered – and not subject
to the vagaries of an optimised replacement cost approach. Interestingly, Telstra’s fear did not
seem to be that the newly sunk investments would be later found to be imprudent. Rather, its
concern seemed to be that the TSLRIC models themselves were already producing cost
estimates that incorporated network upgrades (particularly the use of fibre) that would in
practice require significant new investments by Telstra. Telstra’s Regulatory Affairs Manager
was quoted in 2006 (around the time when negotiations were underway around the building of
a FTTN network) as saying:
“…the TSLRIC models [are] actually already optimised, so the cost pool out of
which access prices are determined is already in place and in fact is already almost a
[FTTN] network. What that means is that we could spend multiple billions of
dollars doing a [FTTN] roll-out – multiple billions – and the total cost pool we are
allowed to recover from wholesale and retail prices would not go up a jot.” (ACCC
So as prices determined by the TSLRIC models would not rise when the substantial new
investment was made, there was little incentive for Telstra to actually undertake the upgrade. 18
Although administratively messy, it would have been possible to value new assets required
for an FTTN at their actual costs, and maintain the valuation of existing sunk assets that were
not to be displaced by FTTN at their optimised replacement cost. However, in its advice to the
Government during the first NBN tender process in early 2009 (ACCC 2009a), the ACCC
said that in relation to the sunk network, the approach that was now typically used in the
electricity and gas sectors, with a ‘locked in’ regulatory asset base, may have some merit
because it would remove uncertainty created by continued re-optimisation of the asset base,
and would link prices to cost recovery and therefore prevent opportunities for investment cost
By the end of 2009, the ACCC (ACCC 2009b) noted:
For some time the ACCC has recognised that its long held approach to pricing fixed
line telecommunications services, a forward looking TSLRIC+ approach with
revaluation at every regulatory reset may not be appropriate given the enduring
bottleneck nature of fixed services.
Through the course of 2010, the ACCC consulted publicly on new pricing principles. It
proposed, in a draft decision, to switch to a building-block model (BBM) that is more in line
with models used in the gas and electricity sectors. In these models, a depreciated regulatory
asset base (RAB) is set once, and not re-valued. 19 New investments are then rolled into this
RAB at their expected cost, which removes the uncertainty caused by re-optimisation and revaluing of the network assets. An annual revenue requirement is then derived, incorporating
operating expenditure, depreciation and a return on capital. This revenue requirement is then
allocated to particular services – making it essentially a form of fully distributed cost pricing.
Compared to the TSLRIC approach, a BBM framework involves different trade-offs. Like
TSLRIC, it allows for recovery of the efficiently-incurred costs of supplying services.
However, the ongoing actual costs of operating the network, rather than hypothetical costs,
are estimated. This provides greater certainty of cost recovery for the access provider, but
gives the access provider weaker incentives to produce efficiently. Arguably, it might also
increase information asymmetry problems, because there is a greater reliance on measuring or
forecasting the costs that are (or will be) actually incurred – information that must come from
the access provider.
Although the ACCC had made considerable progress in its review of pricing principles by the
end of 2010, it was suspended due to important changes to the telecommunications access
regime under Part XIC of the Competition and Consumer Act 2010, which became effective
on 1 January 2011. The ACCC no longer has the power to make pricing principles. Instead, it
has a new power to make ‘Access Determinations’ which can specify price and non-price
terms for access seekers not currently subject to an existing commercial agreement with
Telstra. The new Access Determinations are expected to formalise the new pricing approach,
with prices set for a number of years.
The ACCC’s switch of access pricing methodologies raises a number of interesting problems.
Some are only transitional in nature; for example, establishing accurate forecasts of operating
expenditure. Others seem more elementary: two that are worthy of further consideration are
the effect on the NBN, and the potential flow-on effects to other services that the ACCC
As we have seen, a TSLRIC pricing approach does not provide strong incentives to upgrade
existing network infrastructure, because part of the cost of the upgrade may well be factored
into current TSLRIC access prices (if, for example, it was considered an optimised network
would use more fibre than the existing network). In contrast, the ACCC’s new preferred
approach explicitly accounts for depreciation of existing assets, and allows for actual costs to
be rolled into the regulatory asset base on which a return is earned. At face value, this should
make the transition to the NBN much more straightforward. Costs incurred now are much
more likely to be considered efficient (subject to yet-to-be-determined prudence measures), so
that the risk associated with questions of optimisation of the asset base over time should be of
less concern.
A problem that may arise from the new methodology is due to the ‘lumpiness’ of investment
required for the NBN: much of total capital investment will be required in the early years of
the project. It is well known that actual cost approaches can lead to problems with a
conventional building-block approach when large, lumpy investments are made because of
the rapid increase in the regulatory asset base and, therefore, in prices.
How significant a problem this will turn out to be depends on two factors: how low Telstra’s
existing regulatory asset base is valued, and how much flexibility the ACCC is willing to
allow NBN Co in recovering its costs. Assigning a low value to Telstra’s regulatory asset base
(based on the copper network being heavily depreciated) will cause transitional issues for
NBN Co. This will manifest in either end-user unhappiness, as customers will effectively be
forced to migrate to NBN Co products that offer inferior value, or in damage to the NBN Co
business case. Depending on the views of the ACCC, NBN Co may have some flexibility to
address this problem by deferring its recovery of the capital costs of the NBN. That is, by
setting prices initially to stimulate demand, but increasing contributions to recovery of sunk
network costs over time as the customer base (and, hopefully, consumer willingness-to-pay
for new and innovative services) increases. Although not a common regulatory problem, as
most regulated firms tend to have much more stable costs and revenues than will NBN Co,
there is theoretical support for this kind of pricing in the economic literature (Laffont & Tirole
2000, 68).
The ACCC also regulates the price of two other services: domestic transmission capacity, and
the mobile termination access service (known as ‘MTAS’). Both services have previously
been found to be suitable for the adoption of TSLRIC-based pricing.
There have long been concerns about how to apply the TSLRIC principle to transmission
networks, but (perhaps fortunately) the ACCC has never been required to arbitrate or to assess
an access undertaking for transmission services. The ACCC has now flagged a move away
from TSLRIC-based pricing, but, rather than move towards a BBM as for access network
services, it has elected to rely on a combination of benchmarking of competitive routes and
other information from service providers (ACCC 2010).
Fixed and mobile network operators must acquire MTAS in order to complete calls to other
operators’ mobile networks. The ACCC has regulated this service since 1997, and, since 2007
it has used a TSLRIC model to estimate the forward-looking efficient costs of supplying this
service to inform its price setting. It therefore seems apposite to ask whether the justification
for the use of TSLRIC remain as valid now that the ACCC has stepped away from this
approach for fixed lines.
Interestingly, and contrarily to its prominence in relation to fixed line pricing, the ACCC has
not used the ‘build or buy’ justification for the use of TSLRIC pricing of MTAS. Rather, the
ACCC concluded that TSLRIC was the appropriate price because it:
reflects the direct cost of supplying the service;
ensures equally-efficient access seekers in related markets are able to compete on an
equal footing with integrated access providers as both will face similar input costs for
the declared service;
takes account of the interests of both access providers and access seekers; and
encourages the economically efficient use of, and economically efficient investment
in, the infrastructure used to provide telecommunications services (ACCC 2004).
Given that build/buy decisions are not an issue, is there a reason to think that the conceptual
and practical issues with TSLRIC would be any less for MTAS that for fixed line services? It
is difficult to see why, as, if anything, mobile technology evolves even more rapidly than does
fixed line technology, and there must be significant uncertainty as to how accurate future
asset price trends will turn out to be.
Might the ACCC similarly consider a move to historic costs and a fixed RAB as a basis for
setting MTAS prices? As has been recognised by the Tribunal, the costs incurred by mobile
operators were relatively recent (compared to fixed line networks) and subject to competitive
market pressures due to the presence of between three and four competing network operators
(Tribunal 2006). One would therefore expect that the prospects of costs being inefficiently
incurred are much less. Of course, adoption of an actual cost approach may also raise some
difficult issues. For example, there are three suppliers of MTAS services: Telstra, Optus and
Vodafone (having absorbed ‘3’ in 2009). If historic cost is to be used, will each operator be
allowed a different MTAS charge? And does comparable historic cost information even exist
for the three suppliers? These difficult questions will be subject to review by the ACCC in
2011 as part of a periodic review of the mobile sector.
It has been a long road, but the ACCC is now close to replacing the (futile) TSLRIC approach
with a utility model in setting prices for access to fixed line access networks. This will be
positive if it can reduce disputes and encourage investment, and ensure a smooth transition to
the NBN, without compromising on end-user interests in low prices. Whether the pricing
approach can or will be extended to other services is an issue on which there is sure to be
further conjecture.
Helpful comments were received from colleagues at Frontier Economics, Stephen Farago and
Richard York, and an anonymous reviewer, but the opinions and remaining errors in this
paper are my own.
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ACCC. 2007b. Unconditioned Local Loop Service Access Dispute Between Telstra
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seeker) (monthly charges) Statement of Reasons for Final Determination Version
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The history with access pricing for telecommunications in Australia does go back
further than this. From 1991, under the duopoly model, prices for accessing Telstra’s
network were set by the Minister (with advice from Austel) at ‘directly attributable
incremental cost’ (Lindsay and Williams 1995).
This criterion appears to be the only one specifically directed at restraining access
prices. The explanatory memorandum to the legislation introducing the new access
regime indicated that the reference to ‘direct’ costs of providing access was “intended
to preclude arguments that the provider should be reimbursed by the third party
seeking access for consequential costs which the provider may incur as a result of
increased competition in an upstream or downstream market.” (Trade Practices
Amendment (Telecommunications) Bill 1996 Explanatory Memorandum, 44). This
could have potentially prevented the use of an access pricing methodology such as the
‘efficient component pricing rule’ associated with economists Baumol and Willig.
As the Tribunal has noted (Tribunal 2006, para 19), these criteria are not particularly
limiting in nature, and that there will rarely be one correct or appropriate figure in
determining reasonable costs or a reasonable charge.
In economics, these are respectively known as problems of ‘hidden information’ and
‘hidden action’ (Armstrong et al1994).
This was not applied in all circumstances, even for mature services provided on the
fixed network. For wholesale local calls (local carriage service or LCS) for example,
the ACCC was concerned that the use of TSLRIC based-pricing with the presence of
a retail price cap of 20 cents (excluding GST) could have meant that, the access price
plus allowance for efficient retail costs would have exceeded the retail price cap. This
would have meant that access seekers would not have been able to compete in with
Telstra in the sale of local call to retail customers. To meet the legislative criteria, and
particularly the promotion of competition objective, the ACCC therefore set LCS
prices using a ‘retail-minus’ methodology which subtracted from the retail-capped
price, an estimate of per call efficient retailing costs.
Further discussion of this background was provided in ACCC (2009a)
See, for example, Application by Telstra Corporation Limited [2010] ACompT 1 (10
May 2010)
Hereafter, references to TSLRIC are implicitly references to TSLRIC+.
Telstra challenged the access regime in the High Court of Australia on the basis that it
was an acquisition of property on unjust terms; in particular, that it did not allow
recovery of “the company’s actual costs” (Telstra 2007). The High Court rejected the
claim on the basis that there was no acquisition of property because the access regime
existed prior to Telstra’s privatisation, and so did not look at the question of particular
access terms set by the ACCC.
In contestable markets, prices for a multi-product firm are bounded by stand-alone
costs and incremental costs of a product (Baumol & Sidak 1994b).
An important qualification is that Telstra’s retail share of lines remains around 80%
(Telstra 2010), so it is not obvious that under-recovery of costs on access prices
would necessarily cause significant under-investment. This will depend on the
profitability of serving the remaining 80% of customers and their distribution.
An example may help here. Suppose that replacement costs are forecast to decline by
5% over the next two years, but when the model is actually updated two years later,
they have actually declined by 25%. It is possible to account for the falling asset
prices (through the use of a tilted annuity), meaning that the 5% loss of value is
factored into prices. But the remaining 20% is not. When the cost base is reset, the
loss of value will not be accounted for and the access provider will make a windfall
Ergas identifies a more extensive list of nine key modelling issues (Ergas 1998),
although he does not discuss how the models should be updated, which is the focus of
his later work that is discussed below.
It is not clear how the Tribunal would reconcile this opinion with its view in East
Australian Pipe Line (Tribunal 2004b) in which it did not object to the potential new
entrant approach to estimating optimised replacement costs:
“51. If, as defined and described by the ACCC, DORC is the price at which a
potential new entrant making `a buy or build' decision would value an existing asset,
it is difficult to see why the ORC used to calculate the DORC of an existing pipeline
(such as the MSP) should not include a contingency factor to cover omissions.
Clearly, a prudent potential new entrant would allow for contingencies and include
them in its calculation of its ORC to arrive at its `buy or build' DORC value.”
See, for example, the discussion of asset lives in ACCC (2009) or of the cost of
capital in the Tribunal (2007).
The Tribunal does not further elaborate on how the use of DORC, which would still
require estimates of optimised replacement costs to be made, would help matters.
With that in mind, the dissenting judgement of Justice Breyer looks prescient
(Verizon et. al. v FCC 2002,16):
“The hypothetical nature of the Commission’s [US Federal Communications
Commission’s] system means that experts must estimate how imaginary firms would
rebuild their systems from scratch—whether, for example, they (hypothetically)
would receive permission to dig up streets, to maintain unsightly telephone poles, or
to share their pole costs with other users, say, cable operators—and they must then
estimate what would turn out to be most “efficient” in such (hypothetical) future
circumstances. The speculative nature of this enterprise, the critics say, will lead to a
battle of experts, each asking a commission to favour what can amount to little more
than a guess.”
This might not hold if the upgrades substantially reduced costs. However, the fibre
upgrades did not substantially decrease cost but increased the service potential of the
remaining parts of the copper network.
It is not always the case that building block models use a fixed regulatory asset base.
(ACCC 1999).
Cite this article as: Davis, Warwick. 2011. ‘From futility to utility – recent developments in fixed
line access pricing’. Telecommunications Journal of Australia. 61 (2): pp. 32.1 to 32.16.
Paul Budde is the managing director of Paul Budde Communication (trading as
BuddeComm), a global independent telecommunications research and consultancy company,
which includes 45 national and international researchers in 15 countries.
He specialises in the strategic planning of interactive services such as video media, Internet,
multimedia and intelligent and value-added networks based on telecommunications,
broadband and satellite networks. His particular expertise is on how these new media can be
used by organisations to enhance their competitive edge in the market and how to apply and
use these new media in mass markets. His Strategic Workshop is a popular consultancy
service, conducted throughout the Asia Pacific region.
Since 1978 he has been involved in writing strategic plans and market reports for many of the
world's leading companies involved in the new media. He advised organisations and
government authorities on the initiation, setting up and implementation of e-commerce and
information services. He was involved in Europe's first broadband cable TV services in 1982
and established many public and private online services (now called Internet and Intranet).
In 1983 he came to Australia and since then has provided management consultancy services
in the Asia Pacific region. During that period he also established 70 telecommunications
business publications and initiated the largest telecommunications research site on the Internet
In 1996, he initiated the Electronic and Online Services Forum. In 2001, he organised a
National Broadband Summit, UtiliTel (telecoms opportunities for utilities) and the Local
Council Summit on broadband, putting cities and communities in charge of their own
Broadband Agenda. In 2003 this was followed up with ‘mini summits’ in Perth, Armidale,
Bendigo, Brisbane and Adelaide, and a range of others are underway. The aim of these
undertakings was to create an environment of improved understanding between major players
in the industry. Since 2002 Paul has also been organising monthly Roundtables, each one
addressing different business issues. So far all event have been sold-out, indicating the
interest they receive from the industry.
He is the honorary consultant on telecommunications and broadcasting for the Australian
Macquarie Dictionary and is the author of regular telecommunications columns.
At Now 2000 he received the Australian industry award for services to the industry. He was
also voted “Industry Advocate of the year 2000’ by the readers of Communications Day.
[email protected]
Pondarosa Communications
Peter Darling is the Principal of Pondarosa Communications Pty Ltd, an Australian industry
consulting company. Prior to the establishment of Pondarosa, Peter had a long career with
Telecom/Telstra as a network planner, finishing as Telstra's General Manager, Industry
Regulation. He was an active participant in the national planning of new radiocommunication
developments such as GSM, CDMA and 3G mobile, and in the planning of Australia's new
numbering plan. He has been active in international standardisation for over twenty years.
Peter has long been interested in new directions in telecommunications. He led the pioneering
work in the industry body, ACIF, on NGN, has been active in the international standards
bodies IETF, the ITU-T and ETSI, and has served as the Rapporteur for NGN in the Asian
standards body, ASTAP. He has undertaken consultancy for the Federal Government and the
Victorian Government on related technical and policy issues.
[email protected]
Frontier Economics
Warwick Davis is an economist at Frontier Economics. His work at Frontier has focused on
competition and regulatory economics, and his areas of specialisation include: issues
associated with market analysis (market definition and market power); analysis of anticompetitive pricing conduct (in particular, predatory pricing and price squeezes); and the
regulation and pricing of fixed line and mobile services. Warwick previously worked as an
economist for the telecommunications regulators in Australia (the ACCC) and the UK (Oftel,
and its successor, Ofcom).
[email protected]
Communications Electrical and Plumbing Union
Ros Eason is a Senior National Research Officer with the Communications Division of the
Communications, Electrical and Plumbing Union (CEPU), a position she has held since 1994.
Since that time she has been responsible for advice to the union on telecommunications
industry policy issues, including regulation, and for preparing the union’s contributions to
public policy debates.
Ros also has a history of engagement with industry training. She represents the
Communications Division on the ICT Sectoral Advisory Committee of the industry’s Skill
Council (IBSA) and on the board of training advisor Communications and Information
Technology Training (CITT).
In 2009 she was appointed to the Federal Government’s Information Technology Innovation
Ros holds degrees in Arts and Commerce from the Universities of Sydney and Melbourne.
[email protected]
Murdoch University
Dr. Katie Ellis is a lecturer in the School of Media, Communication and Culture at Murdoch
University in Western Australia. Her main areas of research focus on disability, cinema, and
digital and networked media, extending across both issues of representation and active
possibilities for social inclusion. She is the author of Disabling Diversity: the social
construction of disability in 1990s Australian national cinema (2008, VDM Verlag) and coauthor of Disability and New Media (2011 Routledge). Previously, Dr Ellis worked in
disability support and alternative formatting at The University of Western Australia and has
facilitated a community workshop for emerging filmmakers with disabilities. For more
information about Dr Ellis visit her website
Ryerson University, Canada
Dr. Fels has a PhD (1994) in Human Factors from Industrial Engineering at the University of
Toronto, and a Masters of Health Science (1987) in Clinical Engineering from the University
of Toronto. She is currently employed as a professor in the Ted Rogers School of Information
Technology Management, and the Director of the Centre for Learning Technologies at
Ryerson University.
Her research interests include access to multi-media computer applications and interfaces for
people with disabilities, inclusive media such as captioning and described video, web-based
applications, entertainment interfaces. She is currently participating as an academic member
of the accessible content best practices guide for digital environments working group.
[email protected]
Editor-in-Chief, TJA
Peter Gerrand is a company director, academic and independent consultant in ICT strategy
and business innovation. He was awarded the Charles Todd Medal by ATUG in 1998 'for
outstanding contributions to the telecommunications industry', a Centenary Medal in 2003 'for
outstanding service to science and technology particularly to public science policy', and Life
Membership by the TSA in 2003.
Amongst career highlights he has been a general manager in Telecom/Telstra, successively
leading network research, product development, planning and network strategy (until 1993);
and subsequently a professor of telecommunications at two universities (RMIT and
Melbourne) and the founding CEO (1996 to 2000) of a publicly listed company (Melbourne
IT). From 1993 to 2003 he was Chairman of the Telecommunication Society of Australia
Ltd, and since 1994 has chaired the Editorial Board of this Journal (TJA). He holds a PhD
from La Trobe University (2008) for his research on Internet linguistics.
[email protected]
Simon Hackett is managing Director of Internode, Australia's largest privately-owned
broadband company. Since 1991, Simon has built Internode into a nationally recognised
Internet company that is renowned for its customer-friendly service.
After graduating from computer studies at the University of Adelaide in 1986, Simon was
involved in the establishment of AARNet – the Australian Academic and Research Network –
a national Internet Protocol-based network that connected universities throughout the country.
Simon was also a co-founder of the Internet Society of Australia and founding president of
the South Australian Internet Association.
In 1991, Simon founded Internode, a company that since its inception has established itself as
a trailblazer in Australia's innovative Internet access sector. As one of the earliest entrants in
the Broadband ADSL services market, Internode has recorded strong year-on-year growth
since 2000, creating a first-tier, high-capacity international broadband network while
preserving the quality service that earns it strong customer retention rates.
Seven years after founding Internode, Simon launched Agile Communications, a privately
owned licensed carrier that has pioneered Internet Protocol-based communications in many
regional areas of Australia.
In August 2008, Simon received the Australian communication industry's top honour for
individual achievement, the 2008 Telecommunications Ambassador award. Presented at the
Communications Alliance ACOMMS Awards in Sydney, the award acknowledged Simon
Hackett as an outstanding individual who has shown strong leadership and made a significant
and visible contribution to the Australian communications industry.
The ACOMMS08 accolade followed Simon's receipt of the 2004 The Bulletin-Microsoft
Smart 100 Information Technology & Communications Award, which recognised his role as
"a thinker and a doer; a businessman who proudly wears his tech-savvies on his sleeve"
[email protected]
Australian Communications Consumer Action Network (ACCAN)
Wayne Hawkins is a disability advocate who works for the Australian Communications
Consumer Action Network (ACCAN). Wayne is legally blind after losing his eyesight in
2005 as an adult due to retinitis pigmentosa. He is dedicated to issues concerning people with
disability, especially in relation to accessibility for television, cinema, the internet and other
media. Wayne recently returned to Australia after living in New York for 26 years and
worked with Blind Citizens Australia before joining ACCAN in 2010. Wayne has a Bachelor
of Business Administration from the City University of New York, a Master of Public Policy
from the University of Sydney and is starting a Doctor of Arts degree at the University of
Sydney in the area of Australian Telecommunications Policy and Disability. Wayne has a
dog-guide named Harrison.
[email protected]
Independent consultant
Allan Horsley is a Professional Engineer, a Fellow of the Institution of Engineers and has
some 45 years of experience in the Australian telecommunications industry.
He has been responsible for designing, building and operating substantial communications
networks, with the State Electricity Commission of Victoria in the 70’s and 80’s, and as
Managing Director with Vistel Ltd, the Victorian Governments’ telecommunications provider
in the 80’s and 90’s. He led the Australian Telecommunications User Group in the 90’s and
was a Member and acting Deputy Chair of the Australian Communications Authority, (ACA)
during the period 2001 to 2005.
In recent years he has acted as an advisor to both the Australian Communications and Media
Authority, (ACMA) and the Department of Communications, Information Technology and
the Arts, (DCITA) on telephony services and facilities for Indigenous communities.
He has provided Telecommunications Regulatory training programs to Governments and
Regulators in APEC Economies and to the South Pacific Forum telecommunications
NSW Farmers' Association
Dave Lee graduated from Curtin University in 2005 with a Bachelor’s Degree in Commerce,
majoring in Economics and Finance. This included time studying at the University of Oregon
on an international scholarship. To pursue his interest in policy, he undertook a Post-Graduate
Diploma in Energy and Environment at Murdoch University.
Whilst completing his final semester in 2007 he accepted a position with the Department of
Agriculture, Fisheries and Forestry in Canberra. At the Department he gained agricultural
policy experience whilst earning a Diploma of Government. In recognition of his outstanding
performance, he received an Australia Day award from Government for his work on the 2008
Drought Review.
In early 2010 Dave commenced as a policy advisor at the NSW Farmers’ Association and is
currently responsible for the areas of drought policy, transport and telecommunications.
He is currently studying a Masters of Public Policy at the University of Sydney
[email protected]
The Royal Institute for Deaf and Blind Children
Melissa is the Head of RIDBC Teleschool at The Royal Institute for Deaf and Blind Children.
She is a qualified teacher of the deaf and has been using telecommunications technologies to
support families since 2004. She joined RIDBC in 2004 as a Teacher/Consultant in the Early
Learning Program (Hearing Impairment). In 2007, she was appointed Coordinator of the new
RIDBC Teleschool and in 2008 was appointed to her current role as Manager of RIDBC
Teleschool. She holds the qualifications of BA, MED, LSLS Cert AVT.
Swinburne University of Technology and Telstra Corporation Limited
Robert Morsillo is a part-time Research Fellow with the ARC Centre of Excellence for the
Creative Industries and Innovation (CCi), located at the Institute of Social Research,
Swinburne University, and focussing on the Broadband Services 2015 project. He also
continues part-time as Group Manager, Consumer Affairs, Telstra Corporation Ltd.
Australian Medical Association
Dr Andrew Pesce was elected Federal President of the Australian Medical Association
(AMA) in May 2009. The AMA represents the interests of more than 27,000 medical
practitioners from all specialties and locations across Australia. He is an Obstetrician and
Gynaecologist who works both in private and public practice. He has been Clinical Director
of Women’s Health for Sydney West Area Health Service since 2006.
Dr Pesce’s priorities as AMA President include engaging with government to influence
national health policy debate for the benefit of patients, the medical profession and the
broader community. He is also committed to increasing the AMA’s membership base.
In 2006, he was awarded the AMA President’s Award for his work representing the
profession during the medical indemnity crisis. Dr Pesce was chair of the AMA Medical
Indemnity Taskforce from 2003 to 2007 and was appointed to the Federal Government’s
Medical Indemnity Advisory Panel in 2003 and to the Medical Indemnity Review Panel in
Dr Pesce was the Obstetricians and Gynaecologists Craft Group representative on AMA
Federal Council from 2001 to 2007 and an AMA Executive Councillor from 2005 to 2007. He
was Chair of the Ministerial Expert Advisory Committee on Pregnancy Counselling from
2007-2009 and Chair of the National Association of Specialist Obstetricians and
Gynaecologists from 2006 to July 2009.
Dr Pesce graduated from The University of NSW in 1983 and became a Fellow of the
Australian and New Zealand College of Obstetricians and Gynaecologists in 1990. He was
awarded the Chris Hudson Fellowship for 1991-92, which enabled him to train at Whips
Cross and St Bartholomew Hospitals in London.
Dr Pesce is married with two teenage daughters.
Gibson Quai – AAS
Mike Rocke is a Senior Associate with Gibson Quai – AAS. He holds a Bachelor of
Engineering (Electrical) and an MBA.
Mike has more than 35 years experience in the industry, as both an engineer and senior
business manager with Telstra and subsequently as a consultant with Gibson Quai - AAS.
His interest in end-to-end performance standards stems from both his engineering experience
in transmission planning and consulting, and as Telstra’s commercial policy manager for the
standard telephone service. In this latter role he was responsible for inclusion in Telstra’s
Standard Terms and Conditions of the telephone service quality delivered to customers.
Swinburne University of Technology
Mandy Salomon researches the disruptive properties and opportunities of the immersive
Internet. As a member of the Smart Services Cooperative Research Centre, based at
Swinburne University of Technology, Mandy is at the nexus of industry and academia,
working across as range of service industry domains including health, education and
enterprise. Mandy’s personal blog on virtual environments, DigitalDownunder, can be found
[email protected]
Australian Telecommunications Users Group
Rosemary Sinclair recently resigned from the position of Managing Director of ATUG, an
appointment she had held since 1998, to take up a position at the Australian School of
Business at the University of New South Wales. Previously she had extensive senior
management and strategic planning experience in telecommunications at Telecom Australia,
in broadcasting at the Australian Broadcasting Corporation (ABC), and in publishing at
Scholastic Australia. She is also a former board member of ATUG and of the
Telecommunication Society of Australia.
From 1976 to 1990 Sinclair worked with Telecom Australia in New South Wales. In 1984,
she became the first woman in Telecom to occupy the position of District Manager. She then
became General Manager, Commercial Operations for NSW, and finally National General
Manager, Communications Accounts, in the Corporate Customer Division.
After a brief period as General Manager of the small recruitment company, McKenzie
Consulting Service, Sinclair joined the ABC as General Manager of the ABC Radio Division
that encompassed Technology, Finance, Human and Industrial Relations, Technical Support,
Property and Business Development. She then became Director of Strategic Development
with responsibility for the strategic planning and development unit.
While at the ABC, she was a member and chair of the Minister’s Broadcasting Industry
Advisory Council Working Group, and an executive member of the International Institute of
Communications, Australian Chapter.
From the ABC, Sinclair moved to Scholastic Australia, a unit of Scholastic Inc. the world’s
largest publisher and distributor of children’s books, magazines, educational and multimedia
materials, as Scholastic Australia’s Director, Education, New Media and Export, before
joining ATUG in 1998.
Communications Alliance
John Stanton is a seasoned communications industry executive with over 18 years of
From 2006-2009 John was Chief Executive Officer of ASX- and NZX-listed
telecommunications carrier, People Telecom. Under his leadership, People Telecom became
profitable and was recognised as Australia’s Best Regional Service Provider in the Australian
Telecom Awards 2007. In early 2009 the Company was sold to M2 Telecommunications.
Prior to that Mr Stanton was an executive with Intelsat, the largest provider of fixed satellite
services worldwide. Based in the UK from 2001-2005, he was President and Director of
Intelsat Global Sales & Marketing and of the Data, Carrier and Internet Business Unit. Mr
Stanton also spent two years in the US with Intelsat as Vice President of Sales and Marketing
from 1999-2001.
Mr Stanton joined Telstra in 1992 as a result of the merger with OTC where he was Manager
of Public Affairs. From 1992-1999 Mr Stanton held a number of roles with Telstra including
Managing Director of Payphones and Card Services. From 1996-1997 he was also Chairman
of the Intelsat Board.
In his early career, Mr Stanton worked as a journalist and as a press secretary with the
Australian Government.
Ryerson University, Canada
Quoc Vy is an MSc Candidate in the Department of Computer Science ( and a
researcher at the Centre for Learning Technologies ( at Ryerson
University, Canada. He is currently exploring various solutions for conveying sound
information to people who are deaf or hard-of-hearing through innovative techniques and
[email protected]
Gibson Quai – AAS
Kit Wignall is a Director of Gibson Quai – AAS. He holds a Bachelor of Engineering
(Communications), is a Member, Institute of Engineers (MIE) and a Chartered Professional
Engineer (CPEng).
Kit is part of the management team responsible for the strategic development and corporate
direction of Gibson Quai - AAS. He is also responsible for the management and development
on a national basis for the company’s professional activities in public safety and major
national projects.
Kit's key areas of expertise in relation to network and services performance standards arise
from his involvement with the development and management of service delivery,
communication services description and service level procurement arrangements, and the
planning of communications systems involving business application planning, regulatory
issues and technology and commercial option analysis.
ACS-TSA (the Telecommunication Society of Australia, a special interest group within the
Australian Computer Society), is grateful to the following sponsors for supporting its journal
TJA and ACS-TSA’s other activities in support of a well-informed telecommunications

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