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Submission to the NBN Regulatory Review

This submission suggests that long term affordability and medium term integration with mobility are
more important than the short term issues that have dominated the debate to date (i.e. structural
separation of Telstra, fixed regulation and a focus on short term pricing) in the context of
unrealistically high absolute speeds, and a false assumption of fixed broadband being independent
of mobile.

Australia is at a fork in the development of fast and ubiquitous broadband. It is in danger of taking
the wrong path towards further industry consolidation, higher prices and under-utilisation of an
important national asset. In this “more of the same” scenario, the current NBN Co. pricing and POI
policies continue to support the emerging oligopoly of retailers.

The other fork, or scenario, can still be navigated and leads to greater retail competition, improving
the affordability of access and quicker convergence of broadband communications putting Australia
at the head of global broadband innovation rather than playing a game of catch-up from far behind
in fixed broadband. In this “more innovation” scenario, the brakes are taken off the NBN service,
more affordable entry-level pricing is made possible and opportunities for service innovation are
opened up.

Neither February’s Regulatory Issues Framing Paper (RIFP) nor December’s Strategic Review
explicitly address the impact of the high cost of the NBN (still high after policy changes) on
affordability. The Strategic Review shows that the situation is worse than previously understood and
the culprit is the ACCC approved ICRA which underpins the high CVC charges. Both need to be
replaced. These recommendations are discussed in Section 2.

To read more please click on the link Submission to Vertigan Panel (March 2014)