On the 27th August 2021 we submitted to the Commerce Commission in relation to their open letter to stakeholders on the topic of the marketing of alterative services to consumers during copper and/or PSTN withdrawal.

TUANZ has over time received anecdotal evidence that the information being provided to consumers facing the decision to switch services as a result of a switch off of the PSTN or the underlying copper network is confusing at the least and misleading at worst. While we know that the requirement to switch in this situation is valid, in our experience there are also cases where this is being used to market alternative services where neither of the underlying reasons is currently being undertaken.

Furthermore, we have been concerned over the general marketing of alternative access services not only in this specific situation but across the board, especially where the consumers are less technologically aware.

Based on the information provided in the open letter, the report that we commissioned from BIT and our general anecdotal evidence we recommended the following actions:

a. We agree with the Commission issuing the principles and outcomes to the industry as guidelines under section 234 in the expectation that RSPs would incorporate them into an Industry code through the TCF;

b. That any code development be with the involvement of user representatives including TUANZ, and utilise the idea of testing prior to implementation;

c. That this new code cover not only the marketing of alternative services in the situation of copper/PSTN withdrawal but across all marketing of all connectivity options; and

d. That this new code replaces or updates the Product Disclosure Code with requirements to present information about services clearly in simple to understand statements which are easily accessible for all users.

You can read our submission here.

 

5th July 2019

Today we have filed with the Commerce Commission our submission responding to the preliminary issues that they identified in a paper released as part of their Mobile Market review on the 16th May (You can see that paper here).

In our submission we cover our position supporting the multi-player market that has developed in NZ but with the desire to see a further development of the wholesale market (especially MVNOs), spectrum allocation and our continued support for infrastructure sharing – particularly outside the major urban areas

You can download the full document here.

2nd February 2018

Today we have filed with Parliament our select committee submission on the current bill before the house to amend the Telco Act.  Our focus is in ensuring the Act can respond quickly to changes for the benefit of users.  At the recent board meeting, the discussion was very much around how any changes to the Act needs to be forward looking in line with technology advancement and user requirements. 

In our submission we picked out a small number of specific issues:

• The Pricing Model – generally supporting the proposed utility model but with real concerns that the anchor products may not be flexible enough in definition
• >Unbundling Fibre – encourage the requirement for unbundling of fibre to remain in the Act
• Withdrawal of Fibre – asked for a very strong copper withdrawal code to protect end users
• Service Quality Monitoring – pushed for as much transparency around monitoring and reporting
• Consumer Disputes – strongly supported strengthening the Commerce Commission’s powers in this area
• Line of Business Restriction – withheld our opinion on this matter at this point
• End User Involvement in Advocacy  – once again pushed for the introduction of a model similar to the Australian model where funding is provided to develop high quality consumer focused advocacy.  This is to help overcome the imbalance in resourcing between parties who participate in regulatory process for this market.

You can download the full document here: 18Feb02 Select Committee Submission re Telecommunications Bill Final.