It has elaborated its position in a number of documents submitted to the ACCC in response to the ACCC's second discussion paper issued as part of the process of making a final access determination for the recently declared wholesale ADSL service.
The ACCC 'declared' the wholesale ADSL service in February and set interim prices.
Telstra main competitors disagree with Telstra on all these points. A number of Telstra's competitors lodged submissions last week by the ACCC's 24 August deadline, but Telstra managed only to submit an executive summary by that date. The ACCC has now released redacted (in some cases very heavily redacted) versions of Telstra's submissions, supported by a study Telstra commissioned from Frontier Economics.
This latter approach, the paper argues, "is unlikely to incorporate sufficient allowance for the costs of network congestion." It says" Telstra does have the flexibility under the telecommunications regulatory regime to manage ADSL congestion with its retail pricing structure, this flexibility needs to be reflected in wholesale prices to avoid distorting the competition."
Telstra also wants to be exempt from being required to provide regulated wholesale ADSL services from at least 289 exchanges, arguing that there is strong competition in these exchanges because other telcos have installed DSLAMs and are offering wholesale ADSL services.
This possibility has Telstra's competitors up in arms because of a long and tortuous history of exempting exchanges from wholesale services.
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