The ACCC is currently doing a 'communications sector market study', its wholesale level stuff.
Submissions can be seen at the url below.
https://www.accc.gov.au/about-us/market-studies/communications-sector-market-study/submissions
IT News has come coverage
https://www.itnews.com.au/news/govt-asks-accc-to-leave-nbn-alone-until-after-2020-486641
https://www.itnews.com.au/news/telstra-demands-proper-nbn-service-standards-by-july-486628
Vocus has a submission which doesnt seem to be covered anywhere;
It is supportive of the ACCCs positions, and goes further in some areas, with recommendations about peering in particular tryign to address a long term issue, some extracts;
"Achieving any to any connectivity depends on the exchange of traffic between the networks of different internet service providers. This requires interconnection. If service providers are unable to obtain interconnection on competitive terms, the result is that entry or expansion in the supply of downstream services will be deterred. It is in this context that the settlement-free peering arrangement between Telstra, TPG, Optus and Verizon (TTOV) needs to be considered."
"The TTOV peering arrangement is a prima facie cartel arrangement. Therefore, calls for the ACCC to consider whether such an arrangement is acceptable should be akin to pushing on an open door."
"Vocus submits that when the ACCC is assessing whether access to internet interconnection services is available on competitive terms, the ACCC should specifically consider whether each member of TTOV individually satisfies the criteria for peering with TTOV that TTOV require non TTOV carriers to satisfy."
Vocus want to see TTOV apply one set of rules to everybody, which should be an easy thing to get ACCC to look into, but they have had opportunity before and haven't AFAIK.
The Vocus submission also talks about action on 'market aggregation' not being needed.
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