Minister Conroy has asked for more NBN submissions. The release states;
Issues that interested parties may wish to address include:
The optimal access regime for the National Broadband Network, including, for example:
* the legislative obligations that should be required to ensure the National Broadband Network company operates on a wholesale-only, open access basis,
* the process for identifying services to be offered,
* how the prices and non-price terms and conditions of those services should be set, and for how long, and
* the role of the Australian Competition and Consumer Commission.
The appropriate equivalence obligation for the company and the services it offers, and how this would operate in practice.
The nature of ownership restrictions applied to private sector investors to protect the Government’s equivalence objective for the wholesale-only network.
Arrangements for the Government to sell its stake in the network.
Any other rights and obligations to be conferred on the company.
Interested parties are also welcome to provide their views on other aspects of the legislative framework for the company.
Submissions received will be provided to the Lead Advisor to the National Broadband Network Implementation Study.
Written submissions should be provided by 5:00 pm (AEST) Thursday 30 July 2009, and can be forwarded by email to nbnlegislation@dbcde.gov.au. Submissions may be made publicly available online.
Avid readers of this blog will know that I've addressed many of these already here. As a more formal submission this will require more depth and more alternatives to be considered. But unusually it looks like there is no discussion paper - none, nada, zippo. That could mean one of three things;
* the Government is determined to get the best thoughts available and so has resisted framing the discussion, or
* the Government has found it all too hard to frame a discussion paper, or
* they were expecting the lead advisor to frame the consultation paper but have realised they need to get on with it before they arrive.
Can anyone explain the ambivalence of the reference to the lead adviser? Why did they need to mention that the submission would be provided to the adviser? Did we think they wouldn't, why wouldn't a submission be provided to the lead adviser? What about any non-lead advisers the Government might appoint?
And exactly why did the request need to wait till now? What has changed since the Blue Book was published?
I have been known to be openly critical of the Department of Broadband, Communications and the Digital Economy for a very long time now. I'm sure there are very good reasons in their public service culture of why they give the impression of being unable to engage with the subject matter.
Or maybe it is just me - over recent times I've experienced people in both the private and public sector whose aproach to life is to take the boss's instruction and implement it. Pity is that they don't really understand the boss's instruction or the boss didn't know enough to instruct the right thing. From my earliest days in the workforce I learnt to ask clarifying questions of instructions. No one else seems to - so rubbish piles on rubbish.
I think I forgot to take my pills.....
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