The joint Comms Alliance AMTA submission says: "There is now a widespread recognition by service providers that performance across the sector must be improved, and a stronger desire to take action to achieve this'¦[However] The associations' members believe that the industry itself is best-placed to deliver these improvements."
The submission adds: "There is widespread recognition, nonetheless, that if the industry participants cannot improve their performance within a co-regulatory framework, the result will invariably be the imposition of further direct telecommunications-specific regulation," but says this is "a development that will not necessarily benefit consumers or providers."
The submission is not, however clear on what general initiative, or initiatives, the industry players as a whole should take to: "improve their performance within a co-regulatory framework." It opts instead for better metrics to better understand the extent and nature of complaints, and targeted responses to identified problems.
It says: "Irrespective of the interpretation of statistics, industry has acknowledged that there are problems in areas of customer management. However, the Associations contend that the current metrics and information available about the root cause of complaints are limited in [their] usefulness in actually helping industry understand and address the issues.
"Notwithstanding that the TIO's function, scope and ongoing role is likely to be considered in the upcoming Federal Government review of regulation in a Converged Digital Environment, industry considers that it would be valuable to continue discussions with the Ombudsman that aim to identify more relevant metrics that can better assist industry identify and address customer service issues."
The submission also suggests that "discussions be facilitated between the industry, TIO, the ACMA and other relevant stakeholders to identify individual issues and design effective, efficient and targeted solutions."
If market failure is identified as the cause of a particular problem, the submission says a regulatory solution might be the appropriate outcome. However," in the majority of cases, industry considers that issues will be more appropriately and efficiently resolved by individual providers seeking to retain customers and compete on customer service issues in a way that is tailored to their individual business model."
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