Regulatory Measures Customer Service


Chapter 3

Regulatory Measures Customer Service

Terms of Reference (c) (d) and (e):

(c) the effect on delivery and quality of services for rural, regional and remote areas and for smaller States and territories;

(d) whether the provisions of the Telecommunications Act 1997 and the Telstra (Transition to Full Private Ownership) Bill 1998 provide effective and adequate consumer protection safeguards, including:

i. access to untimed local calls;

ii. free directory assistance;

iii. public telephone facilities;

iv. customer service guarantee; and

v. price caps;

(e) the effectiveness of the standard telephone service, as guaranteed under the Universal Service Obligation, in ensuring that rural and regional customers have access to modern telecommunications services and whether the standard telephone service definition needs to be expanded to take account of rapidly changing communications technology

Customer Safeguards Provided by the Bill

3.1 The preamble to the Bill, which is the subject of this inquiry, reaffirms the Parliament's commitment to the community and regulatory safeguards enacted in the 1997 telecommunications legislation.

3.2 In his second reading speech, the Minister for Finance and Administration, the Hon John Fahey MP, stressed the government's commitment to `comprehensive community and regulatory safeguards', including the following which are all currently enshrined in legislation and which the government has pledged to maintain:

a) a clear universal service obligation to ensure that standard telephone services and pay phones are reasonably accessible to all people in Australia on an equitable basis, wherever they reside or carry on business, as required by part 7 of the Telecommunications Act 1997;

b) continued access to untimed local calls, which is required by part 8 of the Telecommunications Act 1997;

c) the customer service guarantee imposed by part 9 of the Telecommunications Act 1997;

d) special benefits for rural and regional customers of carriage service providers under section 226 of the Telecommunications Act 1997;

e) a price-cap regime established in part 6 of the Telstra Corporation Act 1991; and

f) a flexible regulatory structure designed to stimulate competition in the telecommunications market and thus deliver cheaper prices, and new and improved services, to Australian residential and business telecommunications users, as set out in the Telecommunications Act 1997 and parts XIB and XIC of the Trade Practices Act 1974. [1]

3.3 The Department of Communications and the Arts (DoCA) also pointed to those regulatory aspects in its submission:

In recognition of the potential for differing levels of competition in different areas, the current regulatory regime contains a number of safeguards which will protect all consumers, but which are particularly important to those living in the smaller States and/or rural and remote areas where competition may be slower to develop. These obligations, such as untimed local calls, contributing to meeting universal service obligations and customer service guarantee, are imposed on all carriers, including Telstra. These are set out, in detail, in legislation and associated legislative instruments (eg licence conditions). Price caps only apply to Telstra but these will be retained in the legislation and are independent of the issue of ownership of Telstra. [2]

3.4 The Secretary of the Department stated in evidence to the Committee that:

The overall telecommunications regulatory regime provides a range of powers for governments to intervene on the provision of services through the universal service obligation and licence conditions. All of those are applicable to carriers, regardless of ownership.

He later added:

I believe the customer service guarantee we have here is as good as anything in the world. [3]

The Universal Service Obligation

3.5 As mentioned above, the Bill maintains the Universal Service Obligation contained in the Telecommunications Act 1997 and standard carrier licence conditions. The USO currently costs about $260 million per year, of which Telstra pays about 90 per cent.

3.6 In their submission to the Committee, the Country Women's Association called for assurances that those obligations would be maintained:

This Association seeks a guarantee from the present Government that interests of country people in the area of telecommunications, for private, business and educational purposes, will not be disadvantaged by this proposed Bill and if legislation is enacted on the proposed sale of the remaining two-thirds of Telstra, it enshrines a clause which will ensure that any subsequent government will maintain the intent of the 1998 legislation. [4]

3.7 The Minister's second reading speech not only gave that undertaking but he assured mobile phone users in regional Australia, that while the phasing out of the analogue AMPS mobile phone network was proceeding, the government would:

Introduce a package of measures designed to ensure that all areas of regional Australia which currently receive mobile coverage will continue to have reasonably equivalent coverage after 2000. [5]

Universal Service Plans

3.8 Any telecommunications carrier can be declared the national universal service provider for Australia. Telstra currently fulfils that role and will continue to do so until (and if) the Minister's declaration is revoked. As the national universal service provider, Telstra is required to give to the Minister for Communications, the Information Economy and the Arts a draft universal service plan for approval. The plan must set out how the selected carrier intends to progressively fulfil its universal service obligation. The Australian Communications Authority (ACA) assesses the plan and makes recommendations to the Minister.

3.9 The Minister approved Telstra's universal service plan on 18 May 1998 [6] after Telstra had made amendments to an earlier draft plan which had not been approved on the recommendation of the ACA in November 1997. The plan details how Telstra will give effect to its Universal Service Obligations. Under the plan, Telstra commits itself to specified timeframes for providing telephone connections, repairs, payphones and services for people with disabilities.

3.10 The commitments made on connection times are to be incorporated into the Customer Service Guarantee standards. For example, the maximum connection time for a remote area settlement of less than 200 people with no existing infrastructure has been reduced from 27 months to 12 months.

Customer Service Guarantee

3.11 When the Government developed legislation to enable the sale of one-third of Telstra in 1996, it amended the Telecommunications Act 1991 to require that the carrier meet certain standards for connection of services, rectification of faults and keeping of appointments. The legislation provides for penalties (to be credited to customers) for failure to comply with these requirements. These provisions were carried subsequently over to Part 9 of the Telecommunications Act 1997 and have applied to all carriage service providers since 1 January 1998.

3.12 The Customer Service Guarantee standard (CSG) has been developed by the Australian Communications Authority (ACA) and is set out at Appendix 5 of this Report.

3.13 The CSG standard sets out minimum service levels that the specified carrier is required to meet, such as for example:

i) Connection of a service within three working days where there is already an `in-place' connection;

ii) The repair of faults in metropolitan areas before the end of the next full working day after receipt of a customer report (two working days in rural areas and three working days in remote areas);

iii) All agreed appointments at customer premises are required to be kept, with penalties applying where the phone company attends more than 15 minutes later than the agreed appointment time.

3.14 The Committee heard evidence from Western Australian witnesses of Telstra's failure to meet its Customer Service Guarantee obligations. The WA Department of Commerce and Trade submitted to the Committee that a resident in Lake Grace, Western Australia was asked to wait over 6 months for an `in-place' connection to be made. It also gave examples of Telstra's failure to provide prompt repair services in the Hyden region of the State in October 1997 and February 1998. [7]

3.15 Both the WA Department of Commerce and Trade and Dr Walter Green of the Communications Expert Group in Western Australia called for amendments to be made to the legislation to ensure that Telstra (or any future carrier subject to the Universal Service Obligation) meet its Customer Service Guarantee obligations.

3.16 The Committee is aware that following a direction from the Minister, the ACA is currently looking at ways of ensuring that the service providers provide better information to their customers about their legal rights under the CSG scheme and put more effort into training front-line staff.

3.17 The Telecommunications Industry Ombudsman (TIO) told the Committee that lack of awareness of the existence of the Customer Service Guarantee and of the carriage service providers obligations towards telecommunications customers is a major problem. [8] The evidence before the Committee from individual consumers and small organisations suggests that there is indeed a need for the public to be better informed about their rights in accessing telecommunications services.

3.18 In this context, the Committee notes that:

The ACA is in the process of devising an information strategy for the [Customer Service Guarantee] CSG that will complement and support its customer information focus. The information strategy for the CSG will include the use of fact sheets, newspaper, radio, TV, as well as other targeted media and information outlets. The ACA will also be monitoring performance against the CSG standards, and will be informing customers about CSG entitlements. [9]

3.19 The Communications Law Centre (CLC) argued in its submission that it was not sufficient for the Customer Service Guarantee Standard to require that customers be informed of the service providers' obligations in relation to connection and fault repair times outside of the prescribed timelines:

The Standard should ensure that customers are informed of all service provider obligations and penalties under the Standard. [10]

3.20 The Committee shares the CLC's view that better public information would lead to a better standard of service. It recommends therefore that the requirement to keep customers informed should be enshrined in the Standard.

Recommendation 1

The Committee recommends that Clause 6 of the Telecommunications (Customer Service Guarantee) Standard 1997 require that customers be informed of all service provider obligations and penalties under the Standard


That Section 480 of the Telecommunications Act 1997 be amended to require providers of all services subject to the Telecommunications Industry Ombudsman's jurisdiction to supply to each customer a reasonable summary of the terms and conditions on which the service is supplied (and an updated summary where those terms and conditions change), including all service provider obligations and penalties set under any Customer Service Guarantee standard under section 234.

Expanded powers to the ACA

3.21 The Committee notes also that the current Bill seeks to amend the Telecommunications Act 1997 to expand the powers of the Australian Communications Authority (ACA) in regard to the CSG. In particular, the ACA will be able to require telecommunications carriage service providers to take remedial action to correct any systemic problems in meeting CSG performance standards.

3.22 The ACA could initiate such an action (in which case it would first need to consult with the Telecommunications Industry Ombudsman (TIO)) or it could be directed to do so by the Minister. The Bill provides for penalties (under Section 236A) of up to $10 million for failure to comply with an ACA direction under this new power.

3.23 The Committee notes that the size of the penalties that would apply under Section 236A of the amended Telecommunications Act 1997 should put pressure on telecommunications carriers to identify and solve recurring problems.

3.24 The ACA has also been asked to review the current standards after 12 months of operation (by 1 January 1999), in consultation with the Australian Communications Industry Forum and other groups and to suggest tighter standards where they might be practicable.

3.25 The Committee notes that the amendments in the Bill to enable the ACA to give directions to carriage providers to require them to take action to ensure that CSG performance standards are met are supported by the TIO. [11] The Committee agrees with the TIO that the details of the enforcement mechanism need to be made clear.

3.26 The Committee is mindful of the evidence from both the TIO and the Australian Telecommunications Users Group (ATUG) [12] which shows that customers would rather have the carrier adhere to its CSG obligations than receive compensation for non-compliance.

3.27 However, the Committee is concerned that at the current rate at which penalties are imposed, it might be cheaper for a carrier to pay the penalty rather than provide the service. The Committee believes that in order to deter telecommunications carriers from adopting this approach, the penalties applying in non-metropolitan areas should be increased. Accordingly the Committee recommends:

Recommendation 2

The Committee recommends that the penalty for failure to meet the Customer Service Guarantee standard in non-metropolitan areas be amended so that after a week, the $11 per day penalty could for example, accelerate incrementally or to $100 per day for each extra day that the service is not provided.

3.28 The Committee believes that when the measures described above have been implemented, the Australian Communications Authority's scope for monitoring the performance of the carriers, and for ensuring compliance, will be greatly enhanced for the benefit of consumers. The Committee believes that both the TIO and the ACA should closely monitor levels of consumer awareness and of consumer satisfaction after the above measures are implemented.

3.29 In the event of further non-compliance, the Committee's view is that ATUG's suggestion of introducing carrier performance standards through legislation (similar to the United States model) could be worthy of consideration.

Untimed local calls

3.30 Among submissions which opposed the sale, fear was expressed that a privatised Telstra would want to do away with the cross-subsidies which keep access to the national network affordable for all Australians wherever they live. [13] The Flinders Council, in Bass Strait emphasised:

It is also important that there is access to untimed local calls and the same guarantee is given to customer service, regardless of point of origin of customer. Pricing should also be based upon equity in that all customers receive the same costing. [14]

3.31 The Committee notes that access to untimed local calls is guaranteed by Part 8 of the Telecommunications Act 1997. This is a requirement that is imposed on all carrier service providers supplying a standard telephone service. Changes in ownership of Telstra will not change these provisions. [15]

Definition of standard telephone service

3.32 The Universal Service Obligation (Part 7 of the Telecommunications Act 1997) also covers the provision of the Standard Telephone Service (STS). Although the standard telephone service is defined as voice telephony (or an equivalent service for a person with a disability), the voice service generally has the capacity to carry digital data such as facsimile, e-mail and Internet communications with varying success. The rate of digital transmissions on the standard voice grade telephone line is generally up to 55 kbps. [16]

3.33 A number of submissions and witnesses raised the STS as an issue, suggesting that the provision of a standard telephone be upgraded to include certain levels of broadband capacity to rural and regional areas. [17] The need for a 64 kilobits per second capacity was a recurring theme. In evidence before the Committee, the National Farmers' Federation considered that the obligation to provide a standard telephone service countrywide be upgraded to a guarantee to provide a `standard telecommunications system' so that rural communities would have access to the Internet and other data services. [18]

3.34 The Communications Expert Group, based in Western Australia, deplored the fact that in some areas of the State:

The delivery of ISDN or data services … has been delayed due to investments in high density areas. This has occurred under the existing legislation… Of particular concern is the diversion of funds to the “Cable Rollout Program” which has delayed the “FMO” [Future Mode of Operation] program.

The Group then recommended that:

… the Minister declare a program with fixed milestones for the introduction of ISDN services throughout Australia [and] that the standard telephone service be upgraded to 64kb/s and the existing data transmission speed of 2,400 bits/sec be deleted. [19]

3.35 In reply to the concerns raised, the Department of Communications and the Arts pointed out that:

Telstra will continue to upgrade its services in regional areas, building on its current program of upgrading all of its exchanges to digital around Australia, which is expected to achieve effective completion by December this year.

Already, over 95 per cent of Australians can receive high quality, high bandwidth ISDN services within 90 days of request. Under licence conditions, Telstra must extend availability of such services to 96 per cent of the population by the end of this year. Failure to meet this licence condition can result in similar penalties to those envisaged under new s.236A. [20]

Delivery and quality of services to Rural & Regional Areas

3.36 The implications for rural areas of the lack of access to telecommunications services readily available in metropolitan areas are profound. Access to all essential services, from health services as telemedicine expands [21], to education and financial services all depend on quality telecommunications services at an affordable rate.

3.37 A number of organisations suggested that rural and regional telecommunications services could be enhanced if part of the sale proceeds were allocated to improvements to rural and regional telecommunications infrastructure.

3.38 The Committee notes the position of the National Farmers' Federation and others in requesting an immediate upgrade of the Standard Telephone Service definition. They also suggested that rural and regional services would be enhanced if part of the sale proceeds were allocated to regional improvements. The National Farmers Federation Council adopted a resolution calling for `the social bonus component of the funds from the sale [to be] directed to capital projects', with $1.25 billion of proceeds from the sale of Telstra to be earmarked for the installation and upgrade of rural telecommunications services. [22] The Western Australian Department of Commerce and Trade supported the use of most of the sale revenue to retire debt but suggested that `a significant part of the remainder be used to improve access to telecommunications services throughout regional, rural and remote Australia.' [23]

3.39 It was also suggested to the Committee that at least $3 billion of the sale proceeds be allocated to the Universal Service Fund to ensure rapid roll-out of the significantly upgraded service that would be required if the existing definition of a Standard Telephone Service were expanded. [24] The National Farmers' Federation supported this approach but did not put a figure on the `provision of new and upgraded telecommunications services to rural and remote Australia'. [25]

3.40 The Western Australian Department of Commerce and Trade proposed that the existing Regional Telecommunications Infrastructure Fund (RTIF), established by the present government in December 1996, be allocated a further $1 billion and be used to distribute funding. The WA Government considers that the Fund is presently constrained by an `unrealistically low' allocation of $250 million over 5 years and by the current emphasis on `non-metropolitan populations'. This disadvantages Western Australia. [26] The National Farmers Federation also supported the RTIF being topped up by proceeds from the sale of Telstra.

3.41 The Committee supported the position put to it by these organisations but considered that the mechanism of delivery of the rural upgrade, the sum allotted and its geographic distribution should be left to the government to decide.

Recommendation 3

The Committee recommends that a portion of the proceeds from the sale of the remaining two-thirds of the Telstra Corporation Ltd be used to upgrade the existing infrastructure available for telecommunications services in rural areas.

Quality Service At what price?

Small Business

3.42 The Small Enterprise Telecommunications Centre Limited (SETEL), one of the groups representing the small business sector needs in relation to telecommunications issues, stated in its submission that there is general support for privatisation in the small business sector. It stressed however, that small businesses should be recognised as a separate class of consumer, distinct from residential consumer and noted the recent improvements in recognising the telecommunications needs of small business in the Telecommunications Act 1997. [27]

3.43 The Council of Small Business Organisations of Australia Ltd (COSBOA) also supports the full privatisation of Telstra but it had some reservations:

COSBOA recognises the need to balance the Federal Budget and acknowledges the Government's mandate, but were it not for these, we would have difficulty supporting the transfer of such an increasingly essential service to the vagaries of the private sector. [28]

3.44 Small businesses are increasingly made up of single employees or family employees only and are often home based. This confuses the residential/business line rental issue. There is also an increasing reliance on electronic commerce and the Internet in operating a business. It is for these reasons that COSBOA considers that a major issue for small business is the fact they are charged on a business rather than a residential basis, without the benefits of being able to negotiate bulk discounts. [29]

Rural small business

3.45 SETEL considered that small businesses that were home-based, non employing and micro-businesses should be treated as residential customers under the Telecommunications Act 1997. [30]This would include some rural small businesses.

3.46 There is a concern in the small business community, particularly in rural and remote areas, that there are insufficient Points of Presence (POPs) for Internet Service Providers to ensure access to electronic commerce and other Internet services at local call rates. [31]

What do small businesses need in telecommunications?

3.47 COSBOA argued that the usage pattern and telecommunications needs of single to five line firms are identical to those of residential users, and it is therefore inappropriate for 37% of Telstra's profits being derived from 32% of its lines used by small business. [32] However there is some concern about the current accuracy of the data and COSBOA itself suggested that `we re-examine the data that we brought out several years back because it is dated'. [33]

Rural Schools

3.48 The Committee was told by the Australian Secondary Principals' Association (ASPA) that in the past two years, schools have been required to pay commercial rates (rather than residential rates) to Telstra for fax services that dropped out, poor quality of line and very slow Internet service. [34] The amount quoted by Telstra was $240 pa compared to $140 pa. While this was not considered by the Association to be significant for larger schools, it could be a problem for small primary schools. [35]

3.49 The Association could only prepare preliminary figures for a comparison between the costs for telecommunications facilities for rural and urban schools, as requested by the Committee at the Melbourne hearing. The figures show a range of costs for schools of similar size:

$ 2 400 at Point Gellibrand, Vic (city - 1998 estimate)

$18 000 at Orbost, Vic (country – 1998 estimate)

$ 23 400 at Nightcliffe, NT (country – 1997 actual)

$ 34 400 at Katherine, NT (country – 1997 actual).

3.50 ASPA explained that there are a host of reasons for the variations, one of which is the size of the State and added that ` there is no doubt that the difference between rural and city schools of similar size is out of proportion to any additional funding they may receive. A factor of perhaps 2 or 3 would seem to be the norm'. The figures show:

…just how significant access to reliable and effective telecommunications facilities is to country schools seeking to redress the disadvantage suffered by their students. [36]

3.51 The Committee fails to see how Telstra can justify its new approach to schools. The proportion of schools around Australia that are run on a commercial basis is infinitely small. In the Committee's view, Telstra's decision to charge commercial telephone rates cannot but disadvantage rural schools in an area (telecommunications) where their needs are arguably greater than their urban counterparts.

3.52 The Committee believes that Telstra should reverse this decision. Small rural schools in particular should have access to telephone services at residential rates. The current price control arrangements imposed on Telstra under the Telstra Corporation Act 1991 may be the most appropriate way to ensure that schools are given a choice on how they should be charged for telephone services. The Committee notes that some large schools may benefit from the opportunity to use bulking arrangements available under the commercial rates option.

Recommendation 4

The Committee recommends that schools, and in particular rural schools, be given the option of having access to telephone services at the rate Telstra charges residential customers, rather than being required to pay commercial business rates.

Quality of service

3.53 The needs of indigenous communities in remote areas were presented to the Committee in a submission from the Aboriginal and Torres Strait Islander Commission, who explained how some of their concerns about Telstra's service quality had been met:

ATSIC has been monitoring the services provided by Telstra to discrete Aboriginal and Torres Strait Islander communities in rural and remote areas. This has resulted in a more focused attempt by Telstra to address the backlog of need [in service delivery]. [37]

The Committee notes that Telstra has employed Aboriginal liaison officers in relevant areas.

3.54 Concerns about the standard of service provided by Telstra to country areas have been confirmed by statistics contained in the ACA's Telecommunications Performance Monitoring Bulletin for the December 1997 Quarter. There were declines in the provision of new services on or before the `agreed commencement date'; in the number of faults cleared within one day and within two days; and in the clearing of faults with payphones within one and two days. [38] It was further put to the Committee that:

…in regional Victoria, for instance, the number of ACDs met in January this year still remained 12% below the levels of 12 months ago. [39]

3.55 Telstra released its own quality of service figures for the March 1998 quarter, before the end of the quarter, which showed some improvements on the December 1997 quarter. The Australian Communications Authority as part of its normal monitoring activity has not yet released these figures. [40]

3.56 Mr Blount, CEO of Telstra Corporation Ltd., argued that recent difficulties in service provision were not limited to the bush:

I am very painfully aware of the fact that in the last quarter of last year, and even into the first part of this year, we had a blip in our customer service on at least two elements, and that's service provisioning for new /access lines and all fault repair. And it was not…focused on the bush or the country, it was throughout. And it really was caused by, I think, two major factors: one was weather like I don't think we've experienced in 10 years in that last quarter with rains and lightning and the like…we really had a flawed, very flawed introduction of a new force load management system in our commercial and consumer division…So let me just acknowledge that we've had some service difficulties, but let me also tell you that it had nothing to do with privatisation. [41]

3.57 Telstra Corporation told the Committee:

If I take you through the service standards being provided today right across the board in Australia,commercial, consumer, directory assistance, access, faults and so on,there is some variability, but the standard of service being applied across Australia overall is certainly no worse than a couple of years ago. [42]


3.58 The Committee deplores the apparent drop in the level of Telstra services during 1997. The onus is on Telstra to provide better service to its customers. However, the evidence before the Committee failed to prove that the problem was linked to the partial privatisation of the company or that full privatisation would exacerbate it. The Committee is satisfied that the amendments to the operation of the Customer Service Guarantee obligation introduced through the current Bill will assist in improving the level of service.



[1] The Hon John Fahey MP, Minister for Finance. 2nd reading speech, House Hansard, 30 March 1998, p. 1891.

[2] Submission No 30 (Department of Communications and the Arts), p.159.

[3] Transcript of Evidence, p. 190 (Mr Stevens)

[4] Transcript of Evidence, p. 86 (Country Women's Association, Opening Statement)

[5] The Hon John Fahey MP, Minister for Finance. 2nd reading speech, House Hansard, 30 March 1998, p. 1891.

[6] Alston, Senator the Hon. Richard, Minister for Communications, the Information Economy and the Arts, Media Release, 18 May 1998

[7] Transcript of Evidence, pp 140-141 (Mr Skelton)

[8] Transcript of Evidence, p. 165 (Mr Pinnock)

[9] Submission No. 26 (Australian Communications Authority), p. 110.

[10] Submission No. 55a (Communications Law Centre), p. 827

[11] Submission No. 48 (Telecommunications Industry Ombudsman), p. 352.

[12] Transcript of Evidence, p. 61 (Mr Horsley)

[13] Submission No. 17 (Mr Sidebottom), p. 2.

[14] Submission No. 49 (Flinders Council), p. 2.

[15] Submission No. 26 (Australian Communications Authority), p. 2.

[16] Note: A bit is a unit of digital signal transmission: binary digit (bit) per second, often used with prefixes kilo (k) meaning one thousand, mega (M) meaning one million, and giga (G) meaning one thousand million.A 64 Kilobit service provides a platform for faster access to a range of services, such as fax, email, access to the Internet, electronic commerce and educational applications. For example, a 64Kbit service enables a standard A4 page to be faxed in 4 seconds, compared to 100 seconds on a 2400bps service, or 9 seconds on a 28.8Kbits service (28.8 Kbits is achieved on many standard voice grade telephone lines).

[17] Submission No. 15 (Communications Expert Group) p. 44, 15a (Communications Expert Group), Submission No. 63a (National Farmers' Federation), p. 648.

[18] Submission No. 63a (National Farmers' Federation), p. 653.

[19] Submission No. 15 (Communications Expert Group), p. 44.

[20] Department of Communications and the Arts, Answers to Questions on Notice, 9 May 1998, p. 14.

[21] Transcript of Evidence, p. 87 (Mrs Smith)

[22] Submission No. 63a (National Farmers' Federation), p. 660.

[23] Submission No. 32 (Government of Western Australia), p. 247.

[24] Submission No. 32 (Government of Western Australia), p. 248.

[25] Submission No. 63a (National Farmers' Federation), p. 660.

[26] Submission No. 32 (Government of Western Australia), p. 248.

[27] Submission No. 65 (The Small Enterprise Telecommunications Centre Ltd), pp 543-546.

[28] Submission No. 78 (Council of Small Business Organisations of Australia Ltd.), p. 676.

[29] Transcript of Evidence, p. 243 (Mr Bastian)

[30] Submission No. 65 (The Small Enterprise Telecommunications Centre Ltd), p. 544.

[31] Submission No. 65 (The Small Enterprise Telecommunications Centre Ltd), p. 545.

[32] Submission No. 78 (Council of Small Business Organisations of Australia Ltd), p. 677.

[33] Transcript of Evidence, p. 243 (Mr Bastian)

[34] Transcript of Evidence, p. 172 (Mr Eakin)

[35] Additional information to Submission No. 50 (Australian Secondary Principals'Association)

[36] Additional information to Submission No. 50 (Australian Secondary Principals'Association)

[37] Submission No. 62 (Aboriginal and Torres Strait Islander Commission), p. 481.

[38] Australian Communications Authority, Telecommunications Performance Monitoring Bulletin for the December 1997 Quarter, 31 March 1998, 25 pp.

[39] Submission No. 47a (Communications Electrical Plumbing Union), p. 511.

[40] Submission No. 55a (Communications Law Centre), p. 6.

[41] ABC TV Lateline. Maxine McKew interviews Mr Frank Blount, CEO, Telstra Corporation Ltd, 15 April 1998

[42] Transcript of Evidence, p. 116 (Mr Shore)