05 October 2016

I acknowledge the Traditional Owners of the land on which we meet and pay my respects to their Elders past and present.

I’m extremely grateful for the opportunity to share Labor’s views with such a distinguished panel of speakers and participants, at what is recognised as a leading forum for communications industry expertise and thought-sharing in Australia.

When you represent a marginal seat in Western Sydney and you’re back for a third time when everyone else said you would lose (again), everything that happens after Election Day is a bonus.  As someone who has been an avid reader of Communications Day since starting out as a graduate lawyer in the Competition and Regulation team of Gilbert + Tobin in 2000, this opportunity is a very special bonus.

I would like to use it to discuss four things:

  • to set out the principles I believe should be applied to communications policy-making in Australia;
  • to compare the current implementation of communications policy against those principles;
  • to propose what I consider to be necessary as an overarching strategy for the digital economy; and
  • to examine some contemporary issues within this framework.

As a starting point, I would like to share the following observations and recollections that continue to inform my thinking on many of the contentious areas in the sector:

  • in 2003, the Communications Act was enacted in the United Kingdom and Ofcom was formed.  Two years later in Australia, the Australian Communications and Media Authority was born, but not a corresponding Communications Act;
  • there are 3 mentions of the word ‘Netflix’ in the main body of the Convergence Review Final Report (March 2012), each in the context of it being available in jurisdictions other than Australia;
  • I remember the first person who told me, many years ago, that soon we would look at our mobile devices more than we held them to our ear; and
  • I find myself going back to the Network Insight paper I presented in 2009 just months before I was first elected to Parliament, which documented the developing global narrative of broadband as a human right.

While there are elements of both the vibrant and the repetitive in these examples (to some extent, “the more things change”), I raise them as a note of caution.  It is tempting, and often taken as a given, that the communications sector be described as being in a state of “unprecedented change”, at “a critical juncture”, or “rapidly evolving”.  I regularly use those terms myself.

But they should not be taken as a licence for either hasty, or ill-conceived, reactive legislative or regulatory responses.  They should not supplant evidence-based policy-making.  And they certainly should not negate the need for a coherent national economic focus for communications.

The fact is this: the sector is never stagnant.  Its very nature is dynamic, and that forms the basis of my proposals below.

Principles and challenges of communications policy

There are some universally-accepted golden rules of best practice regulation, which of course may sometimes appear flexible to a player depending on the specific market in which they are operating.  These include to identify market failure; and to regulate only where, and to the extent necessary, to address that market failure.

The above principles are typically expressed to apply to regulatory design and decision-making, rather than policy formulation.  Nevertheless, I believe they are relevant to the Executive and the Legislature.  They inform what I believe to be the three principles of communications policy formulation:

  1. Piecemeal policy is poor policy

Broadcasting, radiocommunications and telecommunications are in a single portfolio for good reason.  There are few greater follies than assuming one can break off a piece of it, fiddle around, and neatly fit it back into the jigsaw later.

Such is the nature of the sector that the Convergence Review is now an historical document.  It may have had more of an impact had it been commissioned a decade earlier.  But the fact remains that piecemeal policy reflects a lack of vision and an incoherence which infects the formulation and delivery of sound, national objectives.

You need look no further than the ITU’s ICT Regulation Toolkit, the starting point for emerging regulatory environments, and its advice on how to approach technological change:

“The most fundamental shift…is the transition to all-digital networks which has profound implications for competition and regulation.  Networks used to be built vertically around specific applications (eg voice or PayTV) but digitisation ‘de-layers’ networks so that content or applications are no longer network specific.  A byte is a byte and Next Generation Networks are layered to serve all applications.” (para

  1. The legacy world must be confronted

I’ve previously noted there has been much talk about transitioning to an NBN world, but precious little appetite in the past term for deep, fundamental and complex reform.  There is a big risk with just tinkering around the edges with regulatory repeal, much of which in the communications portfolio was waved through in the last Parliament without great amendment and with relatively little debate.  The big fish remain issues such as re-defining the standard telephone service, and dealing with the legacy challenges associated with it.

Now, I’ve seen headlines proclaiming that current work being undertaken by regulators is about planning for the post-NBN world (see, for example, “Watchdog looks to the post-NBN telco future”, The Australian, 5 August 2016, p.23).  But what I don’t see is action on more substantive reform for truly convergent legislation.  Governments cannot think about confronting changes in telecommunications services without the corresponding implications in other areas, such as content services and spectrum management.

After the initial deregulation flurry, significant issues appear consigned to the too-hard basket such as pre-selection obligations, untimed local calls, defining service levels on a wholesale basis so the customer service guarantee can be examined on a retail basis, providing some form of back-to-back service levels.

  1. Consumers must be at the policy core

There is essentially one element of this principle, which feeds into all others:  Australia must entrench universal access to broadband services as a right – that includes how speed, quality and affordability are defined.  This must drive how all other elements of the digital economy join up.

This is not a novel suggestion, but would provide the most coherent narrative a government could have.  Even former UK Prime Minister, David Cameron, thought so.  In November last year he recognised broadband as an essential utility, announcing:

“Access to the internet shouldn't be a luxury; it should be a right - absolutely fundamental to life in 21st century Britain.  That is why I'm announcing a giant leap in my digital mission for Britain.

“Just as our forebears effectively brought gas, electricity and water to all, we’re going to bring fast broadband to every home and business that wants it.”

Which brings us to the issue of universal service.  I am well aware this is a matter that has been referred to the Productivity Commission for review and report, and there is reluctance by some to proffer an opinion in the meantime.  It’s my view that in the long term, the best result for consumers to achieve access to broadband as a right is for the current USO arrangements to be harmonised as between the NBN and Telstra.  That includes recognition that a universally-priced open access NBN provides that at a wholesale level.  The key question to be addressed within this prism will be how to ensure access to the wide range of services that use broadband as an underlying delivery mechanism, including transitioning the voice USO to a voice over data USO.

I’m not alone in my assessment and I commend the work of Teresa Corbin and ACCAN, and the proposals advocated in and since the last Regional Telecommunications Review by the likes of Mark Gregory, Reg Coutts and various rural and remote advocates; as well as the measured comments by Telstra to work with government and industry on alternatives to the current model.

I am sure these are issues being considered by the Productivity Commission and, like the rest of the sector and all consumers, I look forward to reform in this very important area which will have universal benefits.

Issues of implementation

I believe an examination of two sets of contemporary policy inquiry neatly illustrate the comparisons with the three principles identified above.

The first is a recent set of communications sector inquiries initiated by the Department of Communications and the ACCC, namely:

  • the Departmental review of Part XIB of the Competition and Consumer Act 2010 (CCA);
  • the ACCC inquiry into mobile roaming; and
  • the ACCC communications market study.

Of these three inquiries, only the first readily anticipates a function for the legislature with a possible amendment to the CCA arising from the introduction of an effects test in its general provisions, with the second being subject to a potential declaration process by the regulator.  For this reason, I will focus on the anti-competitive conduct provisions of the CCA, but with some observations on the activities of the ACCC in its market study.

As you will be aware, Labor opposes the introduction of an effects test and the corresponding amendments to the general competition law provisions of the CCA.  Over the past 40 years, 10 out of 12 competition reviews have recommended against it.  It’s opposed by the likes of Graeme Samuel and the Productivity Commission.  It’s likely to cripple legitimate competition, depress innovation and deter investment.  Recent commentary includes a focus on this occurring in sectors and geographic locations where competition is desperately required, such as banking services in rural and regional areas.

Irrespective of the Government’s legislative agenda or the Opposition’s view, the Departmental discussion paper makes clear that the proposed amendments to section 46 of the CCA do not conflict with Part XIB, nor do they make it redundant.  Part XIB continues to cover a unique set of circumstances.  If changes in the market make those circumstances more unlikely, then the provisions will simply become unused.  That is not in itself an argument for repeal.  In fact, it is probably the purest reflection of ex-ante regulation actually working in the competition notice regime.  Even the Productivity Commission in its comprehensive study of telecommunications competition reversed its initial view to repeal these provisions, based partly on this argument.  Indeed, as the Explanatory Memorandum for the 1996 Bill which inserted these provisions states, the telecommunications-specific behavioural rules are perfectly capable of operating in conjunction with the general provisions:

“This regime will apply in addition to Part IV of that Act, which regulates restrictive trade practices in general”.

Turning to the ACCC market study, the point has been made that the Coalition Government elected in 2013 had a strident commitment to a deregulation agenda and to reduce government waste.  One view is that nothing typifies government waste, nor the cost to corporations of regulatory burden, than pointless or unnecessary inquiry processes.  This is an observation most recently made by Grahame Lynch, who commented in relation to the market study as “driftnetting” for regulatory problems:

“On the surface, the ACCC’s overall telecom market study should perhaps be seen as relatively benign:  a fact-finding mission designed for the purposes of the regulator’s greater understanding of its dominion.  In practice, the study appears to provide the market with more ‘uncertainty’ than it has ever seen before.  Indeed, it seems to identify all forms of, hitherto, unknown problems with the progress of telecommunications technology and markets”. (Communications Day, 6 September 2016)

It is arguable that the market study paper poses as questions issues that have very specific technical answers, that the ACCC should either already be informed about or able to determine by commissioned research.  The ACCC’s reasoning commences:

“The Australian communications sector is going through a period of significant change.  In addition to rapidly evolving developments in technology and product innovation, consumer preferences are changing and the Australian industry is experiencing major structural change.” (para 2.3)

As I pointed out in my opening remarks, by its very nature the communications sector is always evolving.  But should that evolution be a green light for a regulator to, in the words of Lynch, “fish for problems to regulate”?  In any event, there do not appear to be any particularly new issues up for comment in the discussion paper, but I do look forward to reading the submissions and the inquiry’s findings as they will be helpful for understanding current and future issues.

I raise this to contrast it with the second example which is actually a non-inquiry.  I use in this case my public statements on the government’s proposed changes to media ownership rules.  Amongst other things, I have articulated the following:

  • traditional media outlets continue to dominate the production and dissemination of news in Australia, with different delivery platforms that do not obviate the current high level of ownership concentration;
  • any amendment to current cross-media ownership restrictions must ensure the diversity of Australian voices; and
  • an evidence-based approach is critical, especially considering there has not been a comprehensive inquiry into ownership, concentration and competition in sector since the late 1990s, a task which could be undertaken by an independent body, such as the ACCC or the Productivity Commission, to assess the state of play.

In response, the Minister dismissed such a review on the basis that, “all the relevant facts are already known” (Sydney Morning Herald, 10 August 2016).

So apparently, as some might conclude, it’s perfectly acceptable to send out a search party into the ether looking for regulatory problems in telecommunications; but Members of Parliament can’t possibly have an expert, independent body of evidence on which to base decisions of significant legislative change on content services.

Well, here are a few more facts the Minister may care to ponder since he made his comments:

  • at least one free to air network has reversed its position in support of his Bill until the issue of licence fees for free to air broadcasters is resolved;
  • the subscription broadcasting sector has called for a greater package of reform and;
  • the rise of telcos as content providers and international digital players in competition for sports rights is challenging the definition of what is defined as a broadcasting service right now.

The piecemeal nature of attempting to legislate on a discrete area of communications law clearly has issues for sound policy, the legacy world and consumers.

A digital economy strategy

I turn now to the topic of digital transformation and the need to implement a digital economy strategy.

The Digital Transformation Office (DTO) was established with the aim of transforming government services, by making services available online, and a focus on using design to deliver an enhanced user experience.

This remains a worthy objective, one which should enrich the trust of citizens in their government and support innovation in the broader economy.  I am optimist when it comes to our capabilities in this regard - there is no reason why government cannot set its innovation sights high.

In the lead up to the 2013 election, the then Shadow Minister Turnbull promised to provide, “real leadership on the digital economy and e-government”.  Yet on his watch, Ernst and Young concluded in its highly critical May 2015 report that Australia had fallen behind major economies on this front.

Mr Turnbull promised a Digital Economy Strategy in the course of his first term.  Like so many of his promises, nothing eventuated.  An expensive advertising campaign does not make a strategy.

Instead, all we have seen is a hollow innovation agenda.  Mr Turnbull continues to spruik an array of ambitious digital transformation projects over a timeframe that is questionable at best and, at worst, failing to meet expectations.  Take, for example, reports of the recent delay of the DTO’s national identity plan.

When Steve Jobs came back to Apple in 1997, he examined all the projects the company was trying to deliver.  What he saw was no cohesion or focus.  He ordered to company to can every project and just focus on getting four of them right.

We have a Prime Minister who constantly talks about innovation, but lacks the conviction to actually get anything done in this space.  James Riley neatly summarised this conundrum in a recent piece which highlighted a revolving door of chief operating officers (5 in 15 months); huge amounts of taxpayer dollars being spent on minimalist projects that have not been communicated to those citizens who could actually benefit from them; and its struggle to convey a consistent message to potential partners and collaborators within government (InnovationsAus.com, 13 September 2016).

This underscores the central problem: this government lacks clarity and cohesion in Digital Transformation, which has two related consequences:

  • consumer mistrust in what should be a beneficial function of government service delivery – consider the Census debacle, ongoing complaints by individuals and small business attempting to access the MyGov portal or the MyTax website, the recent accidental publishing of potentially sensitive health data, all feeding a distrust that will probably, most unfortunately, impact on the implementation of electronic voting; and
  • the urgency to deliver universal access to broadband – a digital strategy which lacks focus on this fundamental imperative is worthless.  The trinity of promises by Mr Turnbull to deliver broadband faster, sooner and more affordably to all Australians was broken long ago.

In Government, Labor released its Digital Economy Strategy and in June 2013 the update entitled Advancing Australia as a Digital Economy.  This overarching Digital Economy strategy was essentially a roadmap for, “How to drive national productivity through the use of broadband infrastructure.”  Much of what Mr Turnbull introduced was actually in that June 2013 report, but ours included so much more, including the utilisation of broadband in health, education and aged care.

A Digital Economy Strategy doesn’t need spin or ads or the relentless repetition of buzzwords.  It is about combining a holistic policy framework, addressing legacy, and placing the broadband right of consumers at its centre.

As David Tudehope frequently reminds me, broadband should be about what we do with it, not what we say about it.  Judging from the fact that a lack of access to reliable, affordable broadband remains the top source of unsolicited complaints from my constituents, they want to do a lot more than I think we assume.

Contemporary issues

NBN pricing

On that note, I turn to the NBN.  It would be remiss of me not to make some observations on the burning issue of access pricing, and I want to do so in the context of the principles and issues I have articulated thus far.

As I see it, the biggest issue with the Connectivity Virtual Circuit (CVC) charge is that it does not relate to the cost associated with the CVC itself.  Indeed, the Access Virtual Circuit (AVC) picks up the usage concept that is applied by others.

The effect of the current CVC design is to discourage usage.  Rational retail service providers will simply throttle the backhaul to match the retail price to the CVC.  In effect, the CVC pricing arrangement signals to RSPs that they should under-use the capability of the network.

NBN Co has caught itself in a bind on CVC charging.  It knows that if RSPs order more capacity then they can drop the prices, but they don’t know how to co-ordinate the price reduction with orders.  That RSPs don’t order enough CVC then puts downward pressure on upgrades to the AVC, as consumers doubt they will get the benefit from the higher speed.

This raises two perspectives:

  • applying an economic lens, this is about setting a CVC price signal that can reflect actual costs; and
  • on a political level, it’s fundamentally about how quickly the invested capital is to be paid off.  If it is quickly, then RSPs and, by extension consumers, are paying too much for services.  If it is slowly, then the Government needs to be a patient investor waiting longer to recover its investment.  This is then a political question:  does Government want to stimulate the use of broadband in the economy, or not?

Sensible resolution in this area would be consistent with an LTIE (long-term interests of end-users) approach, placing consumers at the policy core.  Lowering costs will be of greatest benefit to those whom we are trying to help the most.  But as I recently commented in the Australian Financial Review, I do not believe the fundamental problems end here.  As I see it:

“The biggest challenge for retailers isn’t just the fact that Turnbull’s NBN costs more.  It is the fact that it does less. It is much harder to grow your revenue if you can’t offer your customers a reliable service with guaranteed access speeds.  We also know maintaining the second-rate copper will be a significant burden on cash flow, and on the internet experience of Australians, for decades to come.” (AFR, 29 September 2016)

The fact is, the implementation of Mr Turnbull’s MTM has increased costs, especially operating cost, and negatively impacted revenue due to the inability to offer guaranteed wholesale performance.

So as I see it, the options to reduce CVC pricing are limited, without taking a write off or going beyond the bond rate.

NBN infrastructure choice

Issues regarding the infrastructure mix in the present NBN have been topical in recent weeks.  These include the scaling back from 4 million to around 2.5 million premises scheduled for HFC delivery in the latest Corporate Plan, followed by last week’s abandonment of the Optus HFC network in the mix.

Two pertinent questions arise in this context:

  • whether the mix is indeed moving to maximise fibre; and
  • what would be the consequences in both a political and infrastructure sense.

My predecessor, Jason Clare, addressed this issue in his October 2015 speech to this Congress.  He noted:

“In a Senate Committee recently NBN revealed that they had already trialled Fibre to the Curb—or Fibre to the Distribution Point.

As you know this involves bringing the fibre all the way to the pit nearest your house.  Basically to the driveway, leaving just the lead-ins.

NBN has also recently revealed that they are about to trial G.Fast in the lab.

I think it is likely that sometime between now and the next election the new Minister will announce that NBN will be rolling out Fibre to the Curb—using G.Fast.

And when he does this, remember this – this won’t be evidence of ‘agility’ or ‘innovation’ or ‘technology agnosticism’.

It will be evidence that Labor was right and Malcolm Turnbull was wrong.” (14 October 2015)

How prophetic.  Consider what we have witnessed in this latest episode:

  • an announcement that the Optus HFC network will be ditched and 700,000 customers connected to FTTdp instead;
  • a Minister whose response is that old chestnut, “Labor took a theological approach.  If there was any deviation from the one true path of fibre to everywhere, then for Labor that was heresy”. (Fifield, Sky News 6 October 2016); and
  • that same Minister has conveniently forgotten that earlier this year, he reportedly rejected FTTdp as “fantasy fibre”, on the basis that such choice of which would have resulted the NBN rollout being halted for 2017 to complete necessary testing (Delimiter, 16 May 2016).  Similarly, Senate Estimates questioning around this time revealed considerable reluctance by NBNCo to favour FTTdp.

Remember, this was barely 5 months ago.  An incoherent, piecemeal excuse of a policy trying to be implemented because of what seemed convenient to Mr Turnbull at its inception.

And for all the conjecture about the benefits of maximising fibre, which was indeed the central component of the Labor’s 2016 election policy, consider these facts:

  • on a wet and windy night last week, I headlined a broadband information forum in the outer suburbs of Perth.  Over 100 local residents turned up.  They were most vocal in their frustration with their lack of broadband access, many of them not on any rollout maps, and the unreliable services currently delivered by copper.  They did not want a bar of any delivery infrastructure other than fibre;
  • a purpose-built photographic and video studio run by small business who made the choice to move into Riverstone in my electorate, one of the first FTTP deployment sites, transforming a semi-rural area into a local technology success story; and
  • actual constituents who frequently and readily share their experiences with me, such as (and I quote):

“In this day and age of e-commerce, how are we supposed to survive like this?  We are IT professionals, unable to work in such conditions…We are seriously considering moving out of the area because of this reason”.

Consumers are savvy, they are informed, they have a higher degree of technological expertise than they are given credit for, and they know what they want.  I am yet to meet one who has demanded a copper-based solution over a fibre one.  Mike Quigley was right to describe the current model as a “colossal mistake”, “short-sighted, expensive and backward-looking” (22 June 2016).

There are two other contemporary issues I would like to consider.

Satellite services

As we know, the second of Labor’s NBN satellites is scheduled for launch today.  It is indeed an important step for residents and businesses in rural, regional and remote parts of Australia.

However, the story of these satellites exposes the duplicity and short-sightedness of this government – and a Prime Minister who, when in Opposition, opposed them, but now lauds them as a “game changer”.  As I commented in the Parliament in relation to the first Sky Muster launch:

“The Minister’s description of the long-term satellite service as a game-changer which will be a huge step forward for those living in regional and remote Australia came as somewhat of a surprise to me.  That is because the member for Wentworth, when was the Shadow Minister for Communications and was on a crusade to demolish the NBN, condemned these satellites as a ‘Rolls Royce solution’ and as ‘wasteful spending’.  What was then wasteful spending is now a game changer for regional and remote Australia.  The inconsistency is breathtaking.

But the Minister's contempt for the long term satellite service did not stop there.  In 2012, the Member for Wentworth argued that the NBN Co should be renting capacity on existing satellites, rather than building and launching its own satellites.  He said, ‘There is enough capacity on private satellites already in orbit or scheduled for launch for the NBN to deliver broadband to the 200,000 or so premises in remote Australia, without building its own.’  He also said at the time, ‘Once again the NBN is investing more than it is needed to achieve its mission.’

And he was not done there, tweeting on 7 February 2012, ‘Why buy when you can rent?’ (Hansard, 17 August 2015)

Such duplicity is bad enough, but now we have reports of the installation process being compromised for these satellite services.  Service provider, Activ8me, has described the Sky Muster installation process as an “absolute bugbear”, with complaints from consumers at an all-time high.  Activ8me has reported that while it has 10,000 customers connected, it has a backlog of 24,000 premises waiting to be connected to NBN satellite services.  Such is the level of complaints that some customers are waiting between 3 and 4 hours just to be connected to its call centre staff.

The rationale behind these satellites was indeed consumer-driven, as revealed by the enormous pent up demand for services.  And it exposes as incredulous the mantra of the current and former Minister that a theological approach was applied to Labor’s NBN, when they in Opposition railed against the deployment of these satellites.

Mobile black spots

The second issue is the mobile black spot programme.

Having worked with similar style programs in the past, including an output-based aid program for fixed wireless access in Cambodia, I thought I had a reasonable idea of the elements and likely complexity of the program, which I supplemented with attendance at information sessions during the course of its inception.

I was therefore confident when I wrote to the Auditor-General on 1 September 2015 highlighting the following:

“I have concerns regarding a lack of transparency around the Program and how the funding was allocated.  More than 80 per cent of the locations for new mobile phone towers announced are in Liberal or National electorates with less than seven per cent in Labor electorates”.

I further requested investigation into specific aspects of the program including the selection criteria, measurements of effectiveness, and participation.

I was not surprised by the findings released by the ANAO nearly exactly a year later, including:

  • the criteria used to assess the merits of proposed base stations did not sufficiently target funding toward the expansion of coverage where none previously existed;
  • there were not established methodologies to inform the technical and financial assessment of applicant proposals from across Australia; and
  • there is insufficient performance measurement and evaluation.

Perhaps the most damning assessment was that 25 per cent of new mobile phone towers funded in round one of the program provided no new or extended coverage.  Despite rhetoric about areas of prone to national disaster being a priority, the bushfire-prone Labor-held electorates of McEwen and Wakefield in regional Victoria and South Australia respectively received little, if any, funding.

These criticisms are not my main reason for raising this issue.  Like the NBN satellites issue, it’s again the favouring of short-term contemporary politics over a principles-based framework in the formulation and implementation of policy.  There certainly are ways and means to incentivise coverage, and government absolutely has a role to play in the face of market failure.

It’s again the duplicity that I take exception to.  I summarised these views in some Parliamentary remarks last year in which I quoted the work of Henry Ergas:

“In his book, Wrong Number: Resolving Australia's Telecommunications Impasse, he [Ergas] notes $3 billion frittered away by the Coalition under John Howard - $3 billion.  He writes:

These direct 'command and control' regulations have been paralleled by other interventions, often lacking in transparency and accountability … Thus, since 1997, over $3 billion (at 2007 prices) of taxpayers’ money has been appropriated to schemes aimed at promoting the availability of use of telecommunications, mainly in non-metropolitan areas.

It goes on.  It refers to the Communications Fund.  It gives line items: ‘Mobile Connect’ and ‘Clever Networks.’  What does that equate to?  It equates to $3 billion wasted under John Howard while the convergence debate came and went, and here we still are today talking about basic voice accessibility in black spots.” (2 March 2015).

I contend that a principles-based approach to these two contemporary issues would have had far more preferable outcomes for governments and consumers alike.


I’ve set out here three guiding principles which I believe should be driving Australian communications policy.  It’s my view that present Government policy and outcomes are not consistent with those principles.  We have:

  • a preference for piecemeal over coherent policy;
  • an inability to address legacy issues due to a lack of transition to the NBN world; and
  • a neglect of consumers as the core of all policy decisions.

Whether or not you agree with me, I’m yet to identify a Digital Economy Strategy from this Government; or a framework within which decisions on the various portfolio issues I have raised are being formulated and assessed.

I note in a recent edition of Communications Day that the Minister was interviewed on topics such as what he would have done differently had the NBN never been initiated, and big policy issues that require urgent attention.  The response to the first was predictable and purely political; the second I would like to augment with some views of my own.

I agree that it is important to conclude the review of the ACMA and deliver the legislative response to the spectrum review.  Indeed, I proposed these imperatives some four weeks earlier in Communications Day:

“According to Rowland, issues such as spectrum reform and the ongoing Australian Communications and Media Authority review should be on the agenda now, with a view to legislation being realised.

She said on the spectrum review, it was understood that drafting instructions for public consultation were already in existence and could be used as the basis for a bill.

‘The conclusion and outcomes of the review are critical for the sector and should be a legislative priority,’ she said.

Similarly, she said it was her understanding that the ACMA review had been completed, ‘raising the question of what action is going to be taken in response, and even what consideration could again be given to more substantive reform for truly convergent legislation.’” (Communications Day, 30 August 2016)

Labor is up for a constructive approach in the Parliament, to maintain deep relationships with the sector, and apply expertise to these policy challenges within the principles framework I have articulated.

I look forward to working with you in this term, and I look forward to learning from the other distinguished presenters here today.

Thank you.