Several telcos criticised a proposal made by the Australian Competition and Consumer Commission, requiring them to submit the exact location data for up to ten million network termination devices all across the country. This opposition came in parallel with similar criticisms of plans to publish the CVC purchasing and overage amounts of each retail service provider.

Currently, the ACCC infrastructure record-keeping rules require only the broad geographic footprint of a fixed-line, fixed wireless, or mobile network to be reported to the regulator. However, the regulator proposed a new requirement on all fixed networks, fixed wireless, and satellite operators to file location data on end-user terminations.

In its defence, the ACCC said that it “considers that information on the location of the end users’ side of the customer access network is already present in carriers’ existing information systems and the additional requirement will require minimal additional burden on record keepers.”

But the telcos say otherwise, stating that the move would add “significant additional regulatory burden” since the operators will not typically hold details on end-user locations in a single central system. The telcos also noted that the information was “commercially and contractually sensitive”. This means that compiling it could be complicated as this meant that they have to approach their wholesale customers seeking relevant data.

Another argument made by the telcos was that the regulator did not make a compelling case for requiring the data. This same argument was echoed by the Australian Mobile Telecommunications Association in relation to the fixed wireless services offered by its members. 

According to Optus, there was “insufficient rationale” for capturing data of end-user equipment outside of the network of NBN Co. The telco also added that there will be privacy concerns associated with a move such as this.

In the same manner, Telstra warned of a “significant impost on reporting entities” for a measure that “would not produce meaningful information for the ACCC.”

Furthermore, TPG Telecom said the proposal was “extremely onerous” adding that “such representation of location information is not something TPG collates in the ordinary course of business. Furthermore, we would anticipate that the accuracy of such a data set would be difficult to verify. It is also not clear how the ACCC’s proposal would interface with privacy considerations.” Nevertheless, TPG Telecom added that there was a better argument for NBN Co to provide more location information “given it is a government-owned and mandated monopoly.”