MINORITY REPORT
CHAPTER 3
IMPROVED COMMUNITY AND CONSUMER SAFEGUARDS
A number of the terms of reference address community and consumer safeguards,
particularly terms of reference (h) and (i):
(h) whether the Universal Service Obligations (USO) are adequately
protected, including:
and, in particular, the provision of USO in regional Australia;
(i) whether elements of equity of access, public interest and USO
in terms of telecommunications services beyond simple telephony can
be determined, especially in regard to facsimile data and interactive
transmissions.
3.1 Consumer protection safeguards will be maintained and extended
The evidence put to the Inquiry demonstrated comprehensively that the
Telstra (Dilution of Public Ownership) Bill provides for the maintenance
or improvement of key consumer safeguards. Key elements of the Bill
include the continuation of universal service objectives (in terms identical
to the current Telecommunications Act); introduction of a customer service
guarantee, with provision for performance standards and penalties for
non-compliance; and extension of the existing right to untimed local
calls, to include business customers. We consider that these consumer
protection safeguards are highly satisfactory, and go well beyond what
has ever been available before.
In addition to the provisions in the Bill, the Inquiry was told that
the Government has outlined its proposals for a comprehensive framework
of consumer safeguards to apply under the post July 1997 telecommunications
regime. [1] The overall benefits are
those flowing from regulation which promotes effective competition and
choice. [2] The specific elements proposed
are:
- enhanced universal arrangements;
- maintenance of the price control regime for Telstra;
- consideration of targeted assistance where appropriate;
- requirements for itemised billing and charging/billing accuracy;
- provision of tariff information to consumers;
- continuation and strengthening of the Telecommunications Industry
Ombudsman scheme;
- provision for public and consumer involvement;
- enhanced protection of the privacy of the content of communications
and personal information;
- Telstra to continue to be required to produce White Pages directories;
- service providers to provide access to emergency call services.
The consumer service guarantee provisions received a widely favourable
response. The peak body for business telecommunications users praised
the provisions warmly:
ATUG would submit that the Customer Service Guarantee requirements
of a carrier set out in the Telstra (Dilution of Public Ownership) Bill
forms the most significant element of consumer protection that has ever
been provided for this industry. [3]
Similarly, representatives of domestic consumers responded positively.
For example, the Consumers' Telecommunications Network said:
The consumer service guarantee set out in the bill is a welcome
statement of good intentions for consumer protection. [4]
Support for the proposed regime of consumer safeguards was also expressed
by the Tasmanian Consumers Association. In response to a question put
by Senator O'Chee as to whether one could get a stronger method of guaranteeing
such obligations than by the government's legislative route, Mrs Cora
Trevarthen, President of the Tasmanian Consumers Association, responded:
I do not think you can; I am not disagreeing with you. [5]
AUSTEL have also acknowledged the effectiveness of the legislative
route to consumer protection adopted by the Government, particularly
as regards price caps. In response to a question from Senator O'Chee
as to the effectiveness of preventing price increases by way of legislation,
Ms Sue Harlow replied:
If you definitely want to stop prices from going up, then regulation
or legislation, apart from competition to force prices down, is the
only thing I can think of. [6]
Telstra, too, indicated its support for the approach:
Telstra considers the Government's May 1996 Discussion Paper
and Telstra (Dilution of Public Ownership) Bill provide a framework
in which consumer benefits can be maximised and minimum service requirements
guaranteed...Telstra considers the proposed approach is adequate for
protecting consumers... [7]
We note that paragraph 1.26 of the Majority Report is critical of the
effectiveness of the Government's proposed legislative framework for
ensuring a range of customer service guarantees. We reject this criticism.
The government has consistently pledged that both the Universal Service
Obligation and Customer Service Guarantees would be secured within the
legislation. These guarantees will give consumers greater protection
and rights than they have ever had before.
A number of submissions to the Inquiry were along of the lines of “the
customer service guarantee is a major improvement, but we want more”.
We note, with a certain weary cynicism, the way that the Majority Report
gleefully cites these submissions; for example, it cites the Communications
Law Centre at paragraph 6.77. It also recommends that a working party
be established “for the purpose of formulating more satisfactory
legislative provisions concerning the Customer Service Guarantee.”
[8]
The Majority Report is curiously silent as to why these improvements
were never introduced during Labor's thirteen years in power. It is
human nature to ask for more, and self-appointed advocates of the consumer
interest are especially prone to do so, since they bear no part of the
costs their demands entail. The difficult challenge for government is
to balance up a range of competing claims. We are not surprised that
there are items left outstanding on the wish lists of a number of single
issue think tanks and pressure groups; but we are satisfied that the
consumer service guarantee provisions are a very substantial improvement
for telecommunications consumers, going far beyond measures introduced
by previous governments. We are also satisfied that this Government
should go ahead and deliver on this substantial advance for consumers,
rather than engaging in yet another consultative exercise which will
inevitably delay the introduction of this advance.
The Majority Report claims at paragraph 1.26 that the customer service
guarantees are not effectively protected because they rely upon regulations,
licensing conditions and the like. It is true that the detail of these
guarantees will be given effect by regulation. This is absolutely standard
practice in handling detailed matters of regulation across the whole
range of government activities. The alternative arrangement, under which
each individual customer service guarantee, referring to a specific
carrier and a specific service, is spelled out in full in the legislation,
is completely impractical and unworthy of serious consideration. We
vigorously reject the suggestion that the customer service guarantees
are in some way to be regarded as sub-standard because they are to be
given effect by means of regulation rather than legislation.
| Finding: The Telstra (Dilution of Public Ownership)
Bill improves the level of consumer protection safeguards. |
3.2 The universal service obligation
3.2.1 Existing obligations will be maintained and protected
We consider that the key principle in this area is that the ownership
of Telstra is a matter quite separate from, and independent of, obligations
imposed on Telstra as a carrier, such as those relating to universal service.
The latter are specified in legislation (currently the Telecommunications
Act and subordinate legislation, including carrier licence conditions)
and administered by AUSTEL. The degree of public ownership of Telstra
is not related to this regulatory framework. [9]
The attempts which have been made by Opposition Senators, during the course
of the Inquiry, to link together the privatisation of Telstra and the
retention of the universal service obligation is quite mischievous, as
they know full well that neither is dependant on the other.
The point was made well by the Western Australian Government:
The main game, therefore, is fostering open competition with
sound legislation. Ownership as such is not relevant to that issue.
As we have said in our paper, it is not necessary for a government to
own all the butcher shops in order to have effective health controls
apply to them. Telecommunications consumer protection is achieved through
carrier license obligations and so on. All carriers have to comply with
these obligations regardless of their ownership. [10]
As the Department of Finance pointed out, the 1991 changes to telecommunications
legislation largely changed the basis of USO delivery from being Telstra-specific
and ownership related to being industry wide and embedded in the regulatory
regime. Mechanisms open to the Government to deliver its USO policies
include:
• direct payments from the Commonwealth Government to either
carriers (as contracted suppliers of specific services), or to the
beneficiaries of the social equity policies (as purchasers of the
services);
• making appropriate provisions in the regulatory framework;
or
• attaching relevant conditions to the sale (for example, a "golden
share" was used to allow the New Zealand Government to retain control
over certain matters when TCNZ was privatised). [11]
The previous government chose the second of these approaches, by making
it a condition of the carriers obtaining their licences that they bear
a proportion of the cost of the universal service obligation. This approach
has been maintained by the present Government, and neither the Telstra
(Dilution of Public Ownership) Bill nor the post-1997 legislation will
change it.
The BZW Submission expressed the view that the universal service obligation
will continue to apply just as effectively with Telstra in partial private
ownership:
While the private sector has the potential to play a key role,
there are significant areas where the Government, through regulation
as opposed to full ownership should continue to play a key role, including
ensuring the effective provision of Universal Service Obligations,
certain price controls and monitoring of arrangements for service
quality. ...
We see no reason why the arrangements for provision of USOs
should not or will not continue on a level at least as high as at
present in an industry formula which allows Telstra to draw on the
benefits of private sector ownership. Indeed, with marketing and other
improvements flowing from privatisation, there is more likelihood
of enhancing the USO as services develop.
USOs are adequately protected through legislative and regulatory
arrangements rather than through continued full ownership. [12]
We have also found through this Inquiry that existing legislation covers
the provision of payphones and the Government's commitment to the continuation
of the USO post-1997 includes the provision of payphones.
We were informed that it is likely that AUSTEL/SMA will retain responsibility
for USO administration post-1997. AUSTEL's current guidelines cover what
are considered “reasonable” timeframes for the delivery of the
standard telephone service, in the light of community population and infrastructure
availability. DOCA informed the Inquiry that these arrangements would
be enhanced under the post-1997 legislation through the proposal for USO
providers to submit detailed plans on fulfilment of the USO for Ministerial
approval. [13]
The Majority Report's comments on the universal service obligation
are incorrect.
The Universal Service Obligation has ensured that rural and remote
communities have been provided with telecommunications services....
It is unlikely that a private carrier operating on a purely commercial
and profit driven basis would undertake these developments. [14]
The USO will have to be performed by the carrier with responsibility
for it (Telstra, or another carrier if that other carrier has successfully
tendered for it in a particular area), regardless of ownership. All
carriers will be required to contribute to the cost of the USO. There
will be no reduction in the performance of the universal service obligation.
There is ample evidence from around the world that privately owned carriers
in a competitive market are able to fund their contribution to a universal
service obligation type scheme.
We are therefore satisfied that the universal service obligation will
be adequately protected under both the Bill and the post-1997 legislation.
| Finding: The Bill reaffirms the Government's commitment
to the universal service obligation, an obligation which is given
legislative effect under the Telecommunications Act and which is
in not diminished or affected in any way by this Bill. |
3.2.2 Is there a need to widen the universal service obligation?
3.2.2.1 Definition of the USO.
Paragraph (i) of the terms of reference raises the question of whether
the current definition of the universal service obligation is adequate,
or whether it needs to be broadened:
(i) whether elements of equity of access, public interest and USO
in terms of telecommunications services beyond simple telephony can
be determined, especially in regard to facsimile data and interactive
transmissions.
The Telstra Submission to the Inquiry addressed the issue of the definition
of the USO in some detail. From the point of view of both consumers
and the carriers it welcomes the fact that there will be greater clarity
and certainty about what should be provided under the USO. It also puts
the view that for a service to be provided under the USO the test
should be how widely services are used. The Submission stated:
Telstra suggests services should only be considered as candidates
for universal service provision when they are widely used and socially
significant.
A recent report by the Rural Industries Research & Development
Corporation suggests Internet access, or at least higher speed data
service access, is suitable for inclusion in the USO. Telstra considers
this is far from clear, particularly as there may be more worthy candidates
for upgrade. For example, it may be possible to develop a stronger case
for the provision of mobile telephony via the USO. [15]
The same point was made in a telling fashion by Mr Peter Shore, Managing
Director, Commercial and Consumer, Telstra, in oral evidence to the
Inquiry:
...recently I was west of Alice Springs, trying to look at
the problems of upgrading access to information services. You can
drive 200 kilometres down a dirt road, turn right into a sandy creek
bed, come out through a bush and there are two houses and a small
Aboriginal community. This community has a telephone...The telephone
costs $60,000 to put on and there, spotted around that community -
around that area of thousands of square kilometres - every 20 or 30
kilometres, is a telephone service. We put those on and it costs us.
That is the universal service obligation today. We intend to comply
fully with all of our obligations under that.
By the way, that community does not have electricity or power but it
has a telephone. They can access the Internet, if they choose to, at 2.4
kilobytes per second. To give them access at 4.8 or 14.4 or 19.6 or high
speed access will cost another $60,000. The question really is whether
it is widely enough required that it necessitates the spending of an additional
$60,000 for all of those isolated homesteads, farms, Aboriginal communities
and people. [16]
3.2.2.2 Definition of the Standard Telephone Service (STS)
As the USO covers the provision of the STS, the definition of the STS
is an inter-related issue.
The Inquiry was told that in July 1996 the Minister for Communications
and the Arts announced the establishment of a Review Group to undertake
a review of the definition of the `standard telephone service' to determine
whether it should be upgraded to a higher level. The ten member group
includes representatives from academia, consumer organisations, rural
organisations and the industry and is scheduled to report to the Minister
by the end of November 1996. The review of the STS is intended to complement
the USO machinery issues under consideration in the context of the post-97
legislate framework.
We are advised that key factors to be addressed by the Review include:
- an assessment of the particular needs and expectations of people
living in non-metropolitan areas, including Aboriginal and Torres
Strait Islander Communities, and people with disabilities, in relation
to basic telecommunications services, including voice, data and facsimile
services;
- an assessment of whether the existing definition of the standard
telephone service is appropriate to ensure that existing needs are
met;
- an assessment of recent and emerging changes in telecommunications
technology, in terms of their implications for delivering basic services
to all parts of Australia;
- an assessment of the cost implications of any proposed upgrade in
the level or quality of the STS under the universal service obligation;
and
- an assessment of whether the requirement in respect of payphones under
the current universal service obligations is appropriate, particularly
in view of the importance of payphones in meeting basic telecommunications
needs in remote communities. [17]
We believe this review of the STS will be an important mechanism for
determining whether it is appropriate to upgrade the universal service
obligation.
| Finding: there is no sound reason for delaying passage
of this Bill until completing the distinctly separate examination
of the extension of USOs beyond telephony to other telecommunications
services. |
3.2.3 How the USO should be administered
Some witnesses commented in unfavourable terms about the Government's
proposal that post 1997 telecommunications legislation would provide
for new schemes to be used for the selection of a universal service
provider to operate in different regions of Australia where appropriate.
In particular, the USO could be put out to tender. We think it is unfortunate
that a knee jerk hostility to change has led some to respond in this
way to a proposal which in our view is likely to result in the USO being
delivered more efficiently and responsively.
DOCA explained the likely operation of a tender process in its supplementary
submission to the Inquiry. We understand that the USO arrangements would
provide for there always to be a national universal service carrier
with the obligation to serve all areas of Australia that do not have
a specified regional universal service carrier.
Regional carriers would be appointed by tender. A tendering carrier would
specify the subsidy it required; the carrier specifying the lowest subsidy
would win the tender. The underlying purpose of the scheme would be to
reduce the cost to the economy of the USO, subject to the services involved
being provided at a high level of service quality. [18]
We note that Telstra has indicated its support for tendering of the
USO:
Telstra considers there is significant merit to the Government's
tendering proposal. The following advantages would accrue:
- current market distortions would not be perpetuated;
- service delivery by the most efficient means would be encouraged;
- incentives for investment in USO areas would be maintained;
- the administrative task would be achievable;
- costs and service expectations would be clear;
- USO arrangements would be more consistent with social policy
arrangements in other industries;
- the system would be transparent and understandable. [19]
So too has the National Farmers Federation:
This would be an effective way of driving efficiency and giving
greater transparency to actual costs and revenues involved. [20]
We believe that the approach of tendering for the USO is a sensible
one and should be supported.
Another issue in relation to the USO is the question of how it is to
be funded. One funding option raised in submissions by WACCI and some
other business groups is an explicit budget expenditure. We do not believe
this approach would be preferable to the present arrangements under
which the USO is funded by the carriers.
3.2.4 Assurances on certain specific services
Paragraph (h) of the terms of reference refers to certain specific
services:
(h) whether the Universal Service Obligations (USO) are adequately
protected, including:
and, in particular, the provision of USO in regional Australia.
As discussed above, and contrary to the assertions of the Opposition,
there is no inherent link between these matters and the degree of public
ownership of Telstra. We are satisfied from the evidence which the Inquiry
has received that both the existing and proposed regulatory frameworks
make adequate provision for these services as follows:
- Directory Assistance - Telstra is currently required to provide
a consolidated telephone directory as a condition of its licence,
and provides a manual directory inquiries service for local and long
distance numbers. It is envisaged that these arrangements will not
change substantially in regulatory terms post-1997. There are statutory
arrangements in place for oversight of any directory assistance charges
by Telstra (the Telstra Carrier Charges - Price Control Arrangements,
Notification and Disallowance Determination 1995) and these are
unchanged by the Bill.
- Untimed Local Calls - The Bill extends to all customers, including
business customers, the current requirement (in ss. 72 and 73 of the
Telecommunications Act) for carriers to provide the option of untimed
local calls.
- Provision of Public Telephones - Reasonable access to payphones
is part of the USO. The Government has indicated that this will continue
in post-1997 USO arrangements.
| Finding: The Bill will not in any way affect the
existing legislative and other protection of directory assistance,
untimed local calls and the provision of public telephones, all
of which remains unaffected by this Bill. |
3.3 Telstra's public accountability regime
Terms of reference paragraph (f) deals with Telstra's public accountability
regime:
(f) whether the proposed accountability regime in the Telstra
(Dilution of Public Ownership) Bill 1996 is adequate to protect
the public interest.
3.3.1 The current regime
The Inquiry heard that since its incorporation in 1991 Telstra has
operated in a framework comparable to a private company under the Corporations
Law. The current arrangements for accountability to the government as
sole shareholder reflect the Telstra Board and management's responsibility
for the day-to-day running of the company. It is required to do the
following things in discharging its responsibility to report to Government:
- to prepare Corporate Plans covering a three year period and updated
on an annual basis;
- to prepare quarterly reports on the company's financial performance;
- to advise in writing of any events that may affect the achievement
of the objectives, strategies, financial targets of the company or actions
by the company to form, purchase or acquire a major shareholding in
a company or undertake a new business activity. [21]
We note that the Bill gives added support to the current reporting
arrangements by inserting into the legislation obligations to provide
information to the Commonwealth. This means that the Government continues
to gain access to the information that it requires to assess the financial
and service performance of Telstra on behalf of Australian taxpayers.
This is another issue on which the Opposition Senators have consistently
attempted to distort the facts: the fact is that there will be no reduction
in reporting to the Parliament and to Senate Committees. The Bill contains
provisions which enable proper use and communication of information
received from Telstra by Commonwealth officers and agents. These provisions
in no way limit, curtail or otherwise detract from the ability of the
Parliament to seek and obtain information about Telstra's operations.
This was clearly demonstrated in evidence from the Attorney-General's
Department, responding to a question from Senator Carr.
Carr: ...can you indicate to the committee
what other dilutions of parliamentary scrutiny will occur should this
legislation be passed by the parliament?
Markus: The legislation in the bill that
is presently before the parliament does not dilute parliamentary scrutiny
of Telstra in any way. [22]
3.3.2 The current regime will be little affected
Evidence received from the Department of Communications and the Arts,
the Department of Finance and Telstra demonstrated to our satisfaction
that part-privatisation will not diminish official accountability in
any practical way. Moreover, as Telstra's shares will be listed and
publicly traded, the company's total accountability will be enhanced
through becoming subject to the more transparent and public scrutiny
applied to companies whose shares are traded.
The only noteworthy change from the current arrangement is the removal
of the Minister's general power of direction to the Company under the
Telstra Corporation Act, from the time of sale of the first shares. The
power has never been used. Advice from the Department of Finance indicates
that retention of this power when the Company is partially privatised
would be inappropriate, and possibly amount to a power that could disadvantage
minority shareholders in a way that would be inconsistent with provisions
of the Corporations Law. [23] We are
satisfied that the removal of this power is appropriate.
The Majority Report is quite inconsistent on the significance of the
removal of the section 9 power. At one point it asserts that this power
is very important. [24] Elsewhere, though,
it admits that as the majority shareholder, the Government will still
have the power to stop Telstra acting in ways it does not like:
Although the Ministerial direction power is removed by the Bill,
the Commonwealth and the private shareholders could exercise their voting
power to curb a major sell-off of assets if that course of action was
construed as not being in the company's best interests. [25]
We are also satisfied that the changes to reporting and other obligations
which will arise as part of privatisation are likely to result in Telstra
being subject to more effective scrutiny, by the Government and by the
financial markets, and also to result in Telstra reporting at least
as comprehensively and effectively as it does presently.
Telstra pointed out that the Bill also imposes additional obligations
on the company and its Directors in relation to preserving a Commonwealth
majority ownership. These obligations include requirements that Directors:
- ensure that Commonwealth majority ownership is maintained; and
- take all steps to ensure that unacceptable levels of foreign ownership
do not exist.
Directors must also assist the Commonwealth as required in connection
with the sale of Telstra. [26]
The Department of Communications and the Arts Submission summarised
the additional accountability benefits of market listing of Telstra's
shares:
The listing of Telstra shares on the stock exchange will also
provide scope for greater assessment of Telstra's financial performance
by analysts and private shareholders. As with other listed companies,
decisions by Telstra's Board and senior management will be assessed
on a day to day basis through the share price. This will improve accountability
of management and place pressure on the entire Company to improve its
performance. [27]
| Finding: The Bill will increase the level of Telstra's
accountability to and scrutiny by the public while maintaining to
the full its obligation to report to Parliament, including Senate
committees; the only change is removal of the never-used power of
the Minister himself to “direct” the company, which has
no practical significance. |
3.3.3 Government will retain powers as two thirds shareholder
The retention of two-thirds equity in Telstra will mean that the Commonwealth
will retain the rights and powers which attach to majority ownership of
a company. The Commonwealth Government will therefore retain powers to
influence the direction of the Telstra through the appointment of the
majority of Board members, and through the voting rights attached to its
two-thirds shareholding. [28]
3.4 Safeguards against excessive foreign ownership
Paragraph (m) of the terms of reference concerns foreign ownership:
(m) whether proposed foreign investment restrictions on Telstra and
other telecommunications carriers are appropriate or adequate, and
take account of regulation and monitoring of financial transactions
and currency flows.
We have heard detailed evidence on the first limb of this term of reference,
and we are satisfied that the restrictions contained in the Bill are
adequate and effective. The second limb of this term of reference is
highly confused and we do not believe raises any meaningful issue.
While some unsubstantiated claims were made about the possibility of
foreign ownership having an adverse effect on Telstra's ability to set
its own strategic directions in Australia and overseas, the evidence
demonstrated to us quite clearly that the limits imposed by Government
and provided for in the Telstra (Dilution of Public Ownership) Bill
would effectively ensure Telstra remains Australian-owned and controlled.
We were advised that the Bill amends the Telstra Corporation Act 1991
to:
- restrict aggregate foreign ownership to an 11.6667% ownership stake
in Telstra (ie 35% of the one third of Telstra equity that can be
held by persons other than the Commonwealth);
- restrict individual foreign ownership to a 1.6667% ownership stake
in Telstra (ie 5% of the non-Commonwealth equity in Telstra);
- impose related offence, anti-avoidance and enforcement provisions;
- ensure that the Telstra's head office, base of operations and incorporation
remains in Australia and that its Chairman and the majority of its
directors are Australian citizens; and
- enable remedial action to be taken where there has been a contravention
of the ownership limits and other requirements, including applications
by Telstra or the Minister for Federal Court injunctions and special
provisions for prosecution of offences. [29]
We are satisfied that there can be no more than 12% foreign equity
in Telstra without new legislation being passed. The passing of such
legislation, of course, would require the support of the Opposition
Parties, given that the Government does not have a majority in the Senate.
So their repeated claims that this legislation is only a stalking horse
for foreigners acquiring control of Telstra raises the question - how
would that occur? Would the Opposition vote for it? If they would not,
then they ought not to raise it as an issue now.
Finally, we would point out that while the Bill has recognised the
importance of ensuring that Telstra remains an Australian-owned and
controlled company, a degree of foreign involvement is likely to be
beneficial. In the current world climate of liberalisation of telecommunications
markets it would not be practicable to preclude any foreign involvement.
Nor would it be desirable. The presence of foreign shareholders would
be likely to assist Telstra in entering overseas markets and could help
cement strategic alliances between Telstra and companies overseas. It
is also likely that foreign shareholders will be a positive influence
for Telstra to achieve world's best practice through their ability to
compare Telstra's performance directly with its overseas counterparts.
| Finding: The Bill maintains Australian ownership
and control of Telstra of at least 88.3 per cent by restricting
foreign ownership to maximum individual holdings of 1.7 per cent
and to a total of 11.7 per cent, while ensuring Telstra's Chairman
and the majority of its Directors are Australian Citizens. |
Footnotes
[1] Department of Communications and the Arts,
Submission No. 131, p. 701
[2] BZW, Submission No. 267, Vol 9, p. 1850
[3] Australian Telecommunications Users' Group,
Submission No. 202, Vol 8, p. 1485
[4] Official Hansard Report, 12 July,
p. 507
[5] Official Hansard Report, 30 July
1996, p. 953
[6] Official Hansard Report, 30 July
1996, p. 970
[7] Telstra, Submission No. 189, Vol 7, p.
1315
[8] Majority Report, List of Recommendations,
p 3
[9] Department of Communications and the Arts,
Submission No. 131, p. 713
[10] Official Hansard Report, 4 July,
p. 241
[11] Department of Finance, Submission No.
188, Vol 7, p. 1273
[12] BZW, Submission No. 267, Vol 9, p. 1854
[13] Department of Communications and the
Arts, Submission No. 131, Vol 4, p. 714
[14] Majority Report, para 1.21
[15] Telstra, Submission No. 189, Vol 7,
p. 1321
[16] Official Hansard Report, 3 July
1996, p 133
[17] Department of Communications and the
Arts, Submission No. 131, Vol. 4, pp. 714-16
[18] Department of Communications and the
Arts, Submission No. 131, Vol. 4, p. 702
[19] Telstra, Submission No. 189, Vol 7,
p. 1321
[20] National Farmers' Federation, Submission
No. 133, p. 780
[21] Department of Communications and the
Arts, Submission No. 131, p. 710
[22] Official Hansard Report, 26 July,
p 879
[23] Department of Finance, Submission No.
188, Vol 7, p. 1281
[24] Majority Report, para 3.48
[25] Majority Report, para 3.40
[26] Telstra, Submission No. 189, Vol 7,
p.1303
[27] Department of Communications and the
Arts, Submission No. 131, pp. 710-711
[28] Department of Communications and the
Arts, Submission No. 131, p. 711
[29] Department of Communications and the
Arts, Submission No. 131, p. 722.