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National Broadband Network Companies Bill 2010; Telecommunications Legislation Amendment (National Broadband Network Measures—Access Arrangements) Bill 2011

CHAIR —Welcome. Thank you for coming to talk to us today. The committee has received your submission as submission 16. Do you wish to make any amendments or alterations to your submission?

Mr Shaw —No thanks, Chair.

CHAIR —Do you wish to make a brief opening statement before we go to questions?

Mr Shaw —Telstra thanks the committee for the opportunity to appear and talk to the submission on these bills. Before turning to the bills themselves and the issues raised in our submission, I think it is worthwhile to reflect on the wider environment in which these bills fit. Telstra supports the government’s vision for the ubiquitous availability of high-speed broadband across Australia. Following the government’s announcement of its fibre-to-the-home rollout in April 2009, Telstra indicated its desire to engage in constructive dialogue with the government over the implementation of that policy. Subsequently, on 21 June 2010, we announced that we had reached a non-binding financial heads of agreement with the NBN Co. around our participation in the NBN rollout. More recently, in our half-year results we indicated that we had finalised the key commercial terms with NBN Co., which are expected to deliver approximately $9 billion in post-tax net present value to the company. In addition, we also indicated that we had reached in-principle agreement with the federal government over the specific measures that are expected to deliver a further approximately $2 billion in post-tax net present value.

These agreements were reached following 18 months of extremely complex negotiations. We are now working to complete the necessary documentation to enable the finalisation of these agreements. Once the agreements are finalised we will provide shareholders with detailed information on the substance of the proposal. What I can say about the agreements reached is that Telstra has provisionally agreed to commercial terms relating to copper network decommissioning, dark fibre and duct usage, exchange usage, certain rollout arrangements and a number of other matters with NBN Co. The parties are working to complete the associated operational details and ensure that all contingencies are addressed as part of the documentation process that is expected to be completed in the near future.

The company will then commission an independent expert report for shareholders so that the proposal and the report can be put to shareholders at an EGM which is provisionally scheduled for 1 July 2011. Given the complex and sensitive nature of these discussions, we are restricted in what we can say publicly about the status of the NBN negotiations. In our appearance today we do not propose to go beyond the information that I have just provided, and we trust that the committee understands the situation.

In terms of the bills before the committee, at the outset we would like to indicate that we support the passage of the bills. We think they are an important step in the creation of the NBN; however, we believe that aspects to the legislation could be strengthened to ensure the NBN holds true to the fundamental principles behind its creation. The government has clearly stated that its objectives for the NBN are to deliver significant improvements in broadband voice quality for all Australians, reshape the telco sector and establish a wholesale only open access network which will provide open and equivalent access at the lowest levels and the network stack necessary to promote efficient and effective retail competition via a layer 2 bitstream service and/or accommodate the reasonable expectation of retail competitors’ equipment in anticipation of multiple retail competitors.

Our concern is to ensure that the government’s stated purpose of a wholesale only open access network is achieved while, at the same time, ensuring that the retail service providers are not displaced from already competitive retail markets. For that reason we propose a number of amendments to the bill and express a number of concerns. Our first concern is the failure to ensure the core policy of wholesale only or prevent NBN Co supplying value added services in competition with RSPs. The companies bill fails to effectively enshrine the government’s key policy of wholesale only and there are three gaps in the NBN Co line of business that we think makes it possible. The first is that, because the restriction is based on the regulatory identity of NBN Co’s customer rather than the purpose of the wholesale supply being for on-supply to communication service to the public or large retail customers, these large retail customers could easily identify themselves as carriers or carriage service providers to acquire services directly from NBN Co. We think this concern could be addressed amending clause 9 of the bill. Secondly, the bill exempts certain customers, utilities and the like and state government entities from the wholesale only requirement in certain circumstances. We think the omission of clauses 10 to 16 of the bill would address that concern. Thirdly, NBN Co will be permitted to own interests in retail service providers for a period of 12 months, enabling it to be vertically integrated. We think that could be addressed by amending schedule 1 of the bill.

The companies bill also fails to enshrine protection against NBN Co moving up the value chain beyond layer 2 bitstream services to offer value added services and compete with retail service providers who are in fact its customers. The minister retains a discretion to restrict NBN Co but is not yet committed to doing so. The implementation study commissioned by the government made it clear that there are powerful incentives for NBN Co as a monopoly to move up the value chain. The industry needs certainty that this will not be permitted, and this can only be achieved in our view by providing a clear restriction in the companies bill. While we have no reason to believe that the current government’s intention is to act counter to its announced policy, we cannot ignore the risk that future governments may exercise powers to expand the marketplace occupied by NBN Co or to relax its regulatory environment in the future. That uncertainty is something that industry participants do not need if they are going to invest in the capabilities to supply services off the NBN. So we see it as important that a clear and unambiguous line is drawn from the outset in regard to what activities the NBN Co can and cannot undertake as a wholesale only provider of layer 2 bitstream services and thus recommend the bill be amended accordingly. We also have concerns around the provisions of the NBN access bill that regulates superfast networks to protect NBN Co from competing networks. We think this has the potential to reduce competition by deterring investment. We do not see these provisions as being in the interests of consumers and believe they should be excised from the bill.

Finally, the NBN access bill imposes a general obligation on NBN Co not to discriminate between access seekers and price and non-price terms of supply—that is in section 152AXC of the bill—nor to undertake specified related activities, including developing new services, extending facilities and providing information to access seekers. We believe these requirements will inefficiently straightjacket NBN’s activity and deter innovation to the detriment of efficient competition and ultimately to consumers. Telstra believes the NBN Co should be able to discriminate where this aids efficiency. We believe that the ACCC already has ample powers to monitor and review any discriminatory arrangements to ensure that such efficiency grounds do exist.

Thank you for the opportunity to make that statement, Chair. We would now be happy to take questions on our submission.

CHAIR —Thank you, Mr Shaw. It is quite interesting: you sound like Optus when they came to see me two years ago. How things change! Senator Fisher.

Senator FISHER —Gentlemen and Mrs van Beelen, thank you. In terms of volume discounts, what do you think of the arguments that the scope for volume discounts will unfairly favour Telstra?

Mr Shaw —As was stated in the opening remarks, where they aid efficiency we think that is a fairly well understood economic concept that applies in a number of markets across the economy generally. As long as it clearly abides by that criteria of aiding efficiency, we do not think it should necessarily be restricted to Telstra; it could be to any nimble organisation, as the chair indicated in previous evidence. We think it is not something that is there for Telstra’s benefit only. We think it is there for any organisation that can aid the efficiency of the NBN Co in providing services to consumers.

Senator FISHER —What do you think of the scenario painted in Optus’s submission about how, for example, Telstra could be unfairly advantaged in that respect?

Mr Shaw —We believe that the ACCC has sufficient powers to ensure that the market operates properly.

Senator FISHER —I want to move to the exemptions. In respect of the utilities—aside from them arguing that they are special because they are special—what does Telstra think? You have addressed it in your submission, but for the record: what does Telstra think of the argument that, if you do not provide them with the exemption, they will not use the NBN; they will do this themselves? Secondly, what does Telstra think of the argument that, even if retail service providers try to provide them with the services for their internal users, they will not want what they do or they will not want to pay what they charge them for doing it?

Mr Shaw —First of all, we do not think that the utilities generally have made a sufficient case to be treated specially. We believe that the retail service providers will want to provide services to the utilities of the types that they will want in the future. With issues around the smart grids and smart metering that they want to roll out, we are talking about future networks, not existing infrastructure. We believe that there will be a market there for retail service providers to provide the type of service that the utilities want and that it can be done in a way where we add value to what the utilities are after. It is an area where there will be competition and therefore there should be no need for these organisations to deal directly with the NBN.

Senator FISHER —How are you going to convince them of that? Are you saying, for example, that they do not know because we have not been there before and that they should just wait for you to show them?

Mr Shaw —No. We would say that the history of the telco sector of meeting the needs of consumers is well credentialed. A lot of innovation goes on in our sector. A number of companies have sprung up off the back of opportunities to provide specialised services. There are plenty of examples of larger companies setting up particular business units to deal with a particular area of the economy that needs an innovative solution. There are lot of good minds in our businesses, not just in Telstra but across the sector. If we think we can make a buck out of it, then we will invest in it, and we believe that providing utilities for the types of services they want in an NBN world—

Senator FISHER —Is worth a buck?

Mr Shaw —Is worth a buck.

Senator FISHER —What do you say, then, of their argument—in my words—that you better get it right, because the community does not want to do without, for example, electricity if the retail service providers get it wrong?

Mr Shaw —If they believe that we are not providing the type of service that they want, they have options of going elsewhere within the sector or they have the option of getting a carrier licence and sourcing from NBN Co. I do not think that there is only one shot in the locker here.

Senator FISHER —That was essentially Mr Krishnapillai’s suggestion earlier: if they get a carrier licence then so be it. But, if I understand your submission correctly, you are saying there should be an additional requirement in respect of the carrier service provider that the services be around internal use.

Mr Shaw —That is correct. If they are going to provide it for internal use, they would need to source it from an RSP under the amendments that we propose, so they would then have the opportunity to shop around to RSPs. As I say, we have a very innovative sector of the economy here, the telco sector, and we have a good track record of meeting the needs of customers, be it our company or other companies.

Senator FISHER —So you are essentially saying that the licensing requirements are not sufficient to police self-use because the licensing requirements are written envisaging supply to the public.

Mr Shaw —Are you referring to clause 9 in the bill and our suggested amendment?

Senator FISHER —Yes.

Mr Shaw —Yes, we believe that the framing of clause 9 at the moment would allow a large entity to get its own carrier licence and then source from NBN Co. directly for self-supply. We see that as working around the intent of the principles of the NBN Co., which is to provide a wholesale only service and therefore it should be providing to carriers and carrier service providers who are then on-selling to consumers, be they large businesses or households.


Senator FISHER —I did not pursue this with Mr Krishnapillai because of time, so I am not sure what his view would be on this. But I heard him saying essentially that if a utility service provider were licensed as a carrier then so be it. That leaves open the issue that the services could then be self-consumed. But if I understand you correctly you are saying that for a carrier service provider, particularly in that scenario, there would be a requirement that there be on-supply to the public—

Mr Shaw —Correct.

Senator FISHER —under the existing regime.

Senator IAN MACDONALD —Do you have a concern that at some time in the future the wholesale network will not be as schmick as it appears to be now. It is a monopoly. It will not have those competitive pressures that we all talk about in the retail sector. What if they adopt the old Telecom stance and sit on their rear ends and do nothing as the world moves on?

Mr Shaw —There are a couple of answers to that. In the first instance, as colleagues from Optus said, if we keep NBN Co. as far down the value stack as possible—and that is at layer 2 albeit with some provision, as we suggested in our submission, around some services at layer 3—the pressure from the vibrant retail service providers will assist in ensuring that there is a consumer benefit there. The second thing is that the ACCC will be all over NBN Co.

Senator IAN MACDONALD —But you cannot go anywhere else. I have got no idea how you might upgrade a network in 10 years time. Who knew 10 years ago what we could do with telephony these days. But, being a monopoly, how are you going to be concerned or aware that there is not a better system around but you simply cannot get it because they are the wholesaler.

Mr Shaw —A lot of people have accused us in the past of being a monopoly and maybe back when we were the PMG that might have been the case, but in more recent decades there has been investment in the telco sector that has kept us keen in many areas. Second, we have always felt the hot breath of the regulator. They are very keen to ensure that the price—

Senator IAN MACDONALD —We will then have governments deciding what is the best system—the regulators.

Mr Shaw —I am sorry, in terms of pricing; I thought we were looking at pricing.

Senator IAN MACDONALD —No, I am not talking about pricing at all. Perhaps I am rehashing arguments that were relevant three or four years ago, but how do you as a major player—and I would have liked to have asked Optus this, too—know that the NBN is going to keep up with the latest in networks?

Mr Shaw —There is always the option for someone to step in and compete.

Senator IAN MACDONALD —Okay, let us get into the executive summary of your submission:

The provisions requiring regulation of all new superfast broadband networks risk damaging investment and foreclosing future network competition.

[sound missing] 10:03:06

as you go into a superfast broadband network in competition with NBN?

Mr Shaw —That option exists, but under the current formulation of the bill there are certain restrictions and obligations put upon you. We do not believe that those provisions are necessary, which is why—

Senator IAN MACDONALD —Is that the regulations you are talking about?

Mr Shaw —The cherry picking arrangements.

Senator IAN MACDONALD —If those provisions were not there what is to stop you tomorrow setting up your own network in competition with NBN?

Mr Shaw —In theory, any carrier could do that.

Senator IAN MACDONALD —Having got $11 billion for old stuff that you could never use any more.

Mr Shaw —Which is why I would rather not answer any specific questions. I would rather talk about the capacity of the industry generally.

Senator IAN MACDONALD —You will laugh all the way to the bank with that. What is to stop it, except these regulations? So governments will say when the right time is to set up in competition to NBN.

Mr Shaw —I am not quite sure how those provisions would operate. So that if you go down the track—

Senator IAN MACDONALD —Can you explain to me what your submission is. In regard to the first dot point under the ‘NBN Access Bill unduly restricts future competition’ heading in your executive summary, can you explain to someone who is not as familiar with these things as most others in the room what that actually means.

Mr Gallagher —The access bill places a requirement on the ACCC to declare a new service, a layer 2 bitstream service, and it requires anybody who invests in and builds a new superfast broadband network or upgrades an existing network so it is capable of providing superfast services to then supply that layer 2 bitstream service, which has been declared—

Senator IAN MACDONALD —Which is what Telstra has allegedly been doing for the last four or five years. Others would disagree but you would say you were.

Mr Gallagher —Upgrading networks?

Senator IAN MACDONALD —No, supplying your network to anyone who wants it at a reasonable price.

Mr Gallagher —Yes, we do. We provide access to the CAN, to the copper network.

Senator IAN MACDONALD —But you are saying you are concerned that the regulator has that power now to insist—

Mr Gallagher —No, not at all.

Senator IAN MACDONALD —Sorry, I have interrupted you. I really asked you to explain in simple terms, in practical effective terms.

Mr Gallagher —Our concern is that the actual effect of these provisions is that it will act as a deterrent to people who want to make those investments. That is the simple explanation for it.

Mrs van Beelen —The legislation basically specifies the wholesale service that must be supplied and that it will be regulated upfront. So it is a bit of a deterrent to invest in such infrastructure.

Senator IAN MACDONALD —If it were not there, wouldn’t you, the industry, go back to where you were?

Mrs van Beelen —The stated purpose of the provision is to level the playing field, but I think we would argue that with national scale and the substantial government investment in NBN Co it does enjoy certain advantages. So I am not sure that the playing field needs to be levelled.

Senator IAN MACDONALD —You would go a long way to convince me that government is the best one to be running these sorts of high-tech industries. People would say that NBN is not the government—

Mr Gallagher —It is certainly true that the ACCC can always declare a new service on a network and has done so in the past. So the ACCC could declare a layer 2 bitstream service on a superfast broadband network that is built. It has not to date and the reason it has not to date is because it has formed the view that intervening in those sorts of markets will deter investment, which is the very argument we are making.

Senator IAN MACDONALD —You still have your wholesale lines between, say, Sydney and Melbourne.

Mr Gallagher —Correct.

Senator IAN MACDONALD —And you will be using those rather than NBN’s.

Mr Gallagher —NBN is substantially an access network, so it is more the reticulation network into the suburban streets than it is a provider of backhaul services.

Senator IAN MACDONALD —But you provide backhaul services.

Mr Gallagher —We do, and the others provide backhaul.

Senator IAN MACDONALD —I am trying to work out how your proposed amendment would change things from how they currently are.

Mr Gallagher —It would leave it to the regulator to determine in future whether or not declaring such a service is appropriate. The regulator is the best party to make that decision. We do not think it should be mandated from the start.

CHAIR —Senator Macdonald, we are going to have to move on.

Senator LUDLAM —Is Telstra okay in principle with preventing cherry-picking?

Mr Shaw —We have recommended that the current provisions in the bill should be taken out. We think that cherry-picking has been a natural part of the telco sector since competition existed.

Senator LUDLAM —Which is why we have got good service in Sydney and crap service in Laverton, because the free market cannot be bothered taking it out because it cannot turn a profit. Can I just get a yes or no on that. Are you proposing that cherry-picking provisions be repealed?

Mr Shaw —Correct.

Senator LUDLAM —I would draw your attention to page 14, section 41 of your submission:

If by cherry-picking the government means competitive entry in areas where this is efficient, it is not clear why this should be discouraged.

I thought the government has made reasonably clear that should be discouraged because private industry will want to go into the CBD, where it is a lot cheaper to provide services where people are a lot closer together, and you will leave the taxpayer picking up the rest of the country, where telecommunications are a lot more expensive to provide. Can you see the public interest argument in preventing Telstra, or anybody else for that matter, coming in and just pinching the easy bits and leaving the taxpayer to pick up the rest?

Mr Shaw —We look at it through the prism of economic efficiency, which says that if the market can function with competition in it then competition should be allowed because that will drive greater innovation and better prices.

Senator LUDLAM —That comes straight out of a textbook. How is the taxpayer meant to provide services to the far-flung parts of the country with the current cross-subsidising of the very same areas where you would be quite happy to run your entire business?

Mr Shaw —I think addressing those sorts of issues is precisely why the government has set up the NBN.

Senator LUDLAM —But it is why they have also put their antichoking provisions in there to stop you from just turning up and pinching the good bits.

Mr Shaw —And that is where we have a difference of opinion with the government.

Senator LUDLAM —Let us be clear: that is just commercial self-interest; there is no rational economic theory that underpins that.

Mr Shaw —No, we would say the theory of markets does underpin that: if you can support competition that will drive efficiencies and innovation and let consumers benefit.

Senator LUDLAM —It has not driven it very far into the bush with your mobile networks notwithstanding.

Mr Shaw —I think the mobile networks are a good example of how competition is improving services in regional areas. We are feeling our competitors building out by the day in response to our investment in the Next G network.

Senator LUDLAM —How do you think that applies to fibre build, which Telstra had many years as the incumbent and, as a business, you never did it because it was not profitable. NBN Co. is only going to be able to do it by cross-subsidising services in the bush by levying a slightly higher price on people in the city. I would have thought that that is a reasonably uncontroversial proposition.

Mr Shaw —I think we just have a difference of opinion on that.

Senator LUDLAM —Thank you for clarifying that. The Internet Society has raised some concerns with a touch of amusement that we are determining and locking into legislation the definition of superfast broadband that is probably not going to look like super anything in 10 or 15 years time. Have you got concerns about locking in a technical standard into a piece of legislation in that way?

Mr Shaw —In our suggested amendments, they go to our suggestions around Layer 2 and the like, which I think starts to pick up some of the language that is used elsewhere around superfast broadband in the legislation. Our advice has been that it is an appropriate thing to do, so we do not share those concerns.

Senator LUDLAM —So the standard—I think it is 25 megabits per second and above—is classified as superfast. I would have thought the speed at which the technology is shifting and Moore’s Law et cetera would tend to mitigate against putting that kind of standard into a bill. We are going to have to come back every couple of years and get it up to speed. Do you think your amendments in particular would catch those concerns?

Mr Gallagher —Our amendments would take those provisions out and leave it to the regulator to make those decisions in the future.

Senator LUDLAM —That deals with that. There are issues that you have raised around people taking up a carrier licence so as to become effectively an internal retailer. I put the question to you that I put to Optus more as devil’s advocate: if companies can get a cheaper service by dealing directly with NBN Co. as their own retailer, why would it somehow be efficient to insert a retailer who is going to want to whack their own margin on their service into the middle?

Mr Shaw —We would suggest that over time it would not be cheaper for those people to go down that route. We see that the retail service provider is going to add a lot of value between the service acquired from the NBN Co. and that provided to the entity at the end of the day. That will go to putting a whole lot of network applications and services across the bitstream product, putting a lot of security protocols and other things across those, and tailoring those individual needs of the entities that are needed. We see that there is a lot of value add from the RSP; however, there is a superficial attraction, we believe, for people to go out in the first instance and say, ‘We’ll do all this ourselves.’ I think, as Optus said, we are back to a situation of several decades ago. We want to preclude from that potential outcome by drawing a bright line very early on in the fees to say that this is how the market is going to be restructured because that is effectively what we are doing with the NBN Co. We are restructuring the telco market. We are not restructuring it with a view to increasing ambiguity or allowing ambiguity to occur in the sorts of areas that are identified here; we are restructuring the market with the clear understanding of how it will function and what the component pieces are.

Senator LUDLAM —I do not necessarily disagree with you. I think the government sold this as a wholesale-only network and I have got some concerns about scope creep as well. But I am also very much aware that the entities that you refer to do not necessarily want you there. So you are saying, ‘We can provide all this added value,’ and they are saying, ‘Well actually we just want cheap service; we do not want you there at all.’ I was not completely satisfied with the answer that Optus provided either. If you are a big enough institution and you are more than happy to provide these services yourself, why do we artificially need to insert a retailer into the picture just to satisfy some kind of competition principle?

Mr Shaw —I think it is more than a competition principle; I think it is a fundamental principle behind the restructuring industry to start with, Senator. Over and above that, it does not necessarily follow that you are going to get the market functioning most efficiently and appropriately by having that sort of structure where people are buying off NBN Co. for self-supply. There are a whole range of issues—Optus have raised some of them and I think we touched on some in our submission as well. The capacity for the retail service providers to continue to innovate and provide a whole range of different services and products is, I think, greater than the capacity of individual institutions to continually do that for themselves. So I think there are a lot of benefits in having a vibrant RSP component to the telco sector for end users.

Senator LUDLAM —It is a wonderful irony having Telstra come and run these arguments to us.

Senator FISHER —Mr Shaw, you think the cherry-picking provisions should go. If they stay, will Telstra continue to roll out fibre in areas where it is profitable?

Mr Shaw —Senator, I think we are getting into areas that we would prefer not to touch on, given that we are negotiating the status of our network in the future with NBN Co. at the moment.

Senator FISHER —Thanks. We will wait and see.

CHAIR —We are running a few minutes over time, but Senator Wortley has a few questions and then we will have morning tea.

Senator WORTLEY —Thank you. Mr Shaw, in the absence of level-playing-field rules in the bill, will Telstra be out there building new networks as a vertically integrated operator?

Mr Shaw —I think I just touched on that in terms of the question from Senator Fisher. We will certainly continue to invest in things such as our mobile networks, our enterprise fibre and the like, but we are currently in discussions with the government and NBN Co. about the status of our access network.

Senator WORTLEY —Would you still support the legislation without the level playing field provision?

Mr Shaw —We have indicated we think the bills need to be passed. Our suggested amendments we think would strengthen the bills, but nonetheless if the parliament chooses otherwise, we would just move forward with the legislation that is passed, so we would not be seeking to oppose it.

Senator WORTLEY —Thank you. We have touched on a whole number of areas. If you were in the shoes of one of the smaller players, in what circumstances might you ask for different terms of access?

Mr Gallagher —Different players have different advantages, so there is no doubt that players like Telstra and Optus have scale. That is one of our advantages. Smaller players have the fact that they are more nimble, they can be innovative. So one advantage that they might have and that they might take to NBN Co. would be to ask NBN Co. to build a particular process or system around the supply of the service. That may be something where NBN Co. might in a sense discriminate and build a process for them.

Senator WORTLEY —You have also expressed concerns about NBN Co. moving up the stack offering more layer 2 services. Do you see any difficulties with having such a technology specific registration set out in the legislation?

Mr Shaw —No, Senator, we do not.

CHAIR —So there would be enough flexibility for NBN to carry out all of its technical operations?

Mr Shaw —In the formulation that we have provided in our submission, we believe so, yes.

Senator WORTLEY —One of the areas that I wanted to ask you about was the exemption for utilities. It is very narrow. Is that right?

Mr Shaw —No, we do not think the exemption is very narrow, to be quite honest. We think that in some parts it is quite broad.

Senator WORTLEY —They cannot provide retail services to the public, can they?

Mr Shaw —That is correct. They can provide a variety of services to themselves internally, which we believe as a retail service provider we could provide to them in a value-add situation. That is our concern.

Senator WORTLEY —They can only use NBN services internally?

Mrs van Beelen —That is retail purchasing. If you buy services for your own consumption, then that is a retail supply. That conflicts with the wholesale-only policy.

Senator WORTLEY —Does Telstra supply the utilities at the moment or can you see it as a market that you could move into?

Mr Shaw —I believe that we supply a number of utilities and state government authorities, and entities of the type that are listed make those exemptions in the bill.

CHAIR —You said you support the passage of the bill. What are the imperatives in the bill’s passage and what hangs off the passage of the bill?

Mr Shaw —We have stated that we would like to take a proposal to our shareholders for an EGM on 1 July this year around our participation in the NBN and how the NBN will operate. The rules in which it will be providing services and the like is part of what we need to know in order to inform our shareholders for that vote.

CHAIR —Thank you very much for your attendance here this morning.

Proceedings suspended from 10.21 am to 10.33 am