Structural Separation Undertaking

Telstra’s Structural Separation Undertaking (SSU) commits Telstra to structurally separate.  The SSU sets out the various measures which Telstra will put in place to provide for equivalence and transparency in the supply of regulated fixed network services to its wholesale customers and the supply of comparable services to its retail customers, prior to transition to the nbnTM network.

Commitment to equivalence

The SSU contains a series of new, binding interim equivalence and transparency commitments that apply to regulated services provided over Telstra’s copper network until at least 1 July 2018. Telstra believes these interim equivalence and transparency commitments offer substantial and practical improvements in areas of previous industry concern.

The SSU fulfills two roles:
  • It commits Telstra to structural separation by 1 July 2018 - through the progressive disconnection of fixed voice and broadband services from Telstra’s copper and HFC networks, while the nbn™ is being rolled out; and

  • It sets out the various measures which Telstra will put in place to provide for equivalence and transparency in the supply of regulated fixed network services to its wholesale customers and the supply of comparable services to its retail customers during the transition to the nbn.
What it means for wholesale customers

A level playing field
Equivalence on price, information, operational quality and systems and processes for regulated services aims at a fair and level playing field for all customers during the transition to the nbn.

 

Improved transparency and equivalence on price
Improved transparency of Telstra’s costs in supplying fixed network services, allowing a comparison between the Internal Wholesale Price and the External Wholesale Price.


Measurable service delivery and quality
There are enhanced requirements concerning operational quality and delivery standards for regulated services, and reliability of Telstra Wholesale business support systems. These standards will be backed by automatic service rebates for wholesale customers who sign the SLA Rebate Deed. Telstra Wholesale customers may request a copy of the SLA Rebate Deed from their Telstra Wholesale Account Manager or Business Operations Manager.


Quick resolution of disputes
Wholesale customer complaints regarding non-price equivalence matters for regulated fixed network services, or matters concerning TEBA queuing, will be resolved quickly through the new, fast track Accelerated Investigation Process. If that does not provide a satisfactory outcome, the matter can be escalated to the new Independent Telecommunications Adjudicator.

 

Information security
Wholesale customers can be assured that their confidential information is protected through more detailed internal ‘ring-fencing’ and extensive measures to maintain separate retail, wholesale and network services business units.

 

Rate Card

Under the SSU, Telstra has committed to publishing and maintaining a Rate Card with Reference Prices for each of the Reference Services set out below:

  • Fixed Line Services (WLR, LCS, OTA, ULL, LSS);
  • MTAS;
  • DTCS;
  • Wholesale ADSL;
  • TEBA charges; and
  • any future declared service.

Where the ACCC has set a regulated price for a Reference Service under an access determination or a binding rule of conduct then that price will become the Reference Price for that service and the Rate Card will reflect those prices.

The initial Rate Card will set out the standard commercial charges applicable to ULLS, LSS, DTCS and Wholesale DSL services as well as the regulated rates.  We anticipate moving the commercial charges for other Reference Services into the Rate Card over time.

The Rate Card is structured in two parts:

  • Part A sets out the Reference Prices (and is the rate card for SSU purposes) and;
  • Part B sets out the commercial charges. For those Reference Services where we have not yet moved the commercial charges to the Rate Card, the service schedule and the OCT will continue to set out the commercial charges.

 

Rate Card Updates

Each time we update the Rate Card, we will publish it on this website page and on our Telstra Wholesale Customer Portal (TWCP) to keep our customers inform. In addition, whilst the standard commercial charges for certain Reference Services now sit outside of the Service Schedule, we will still need (as under current standard service schedules) to give our customers at least two months notice of a new or varied commercial charge for that change to be effective.

 

Wholesale ADSL Election Process

For Wholesale ADSL only, notwithstanding that wholesale customers have a current commercial agreement in place, customers may at any time within a 3 month window following 7 May 2012 elect to acquire Wholesale ADSL at the applicable Reference Prices set out in the Rate Card. If wholesale customers make an election, they will need to vary their agreement with Telstra Wholesale. Once that variation has been agreed and executed, any such election will take effect from the commencement of the next billing cycle after the date of election, that applies under the customer’s existing wholesale contract.

 

Disputes & Complaints

The SSU provides additional dispute mechanisms to wholesale customers for resolving disputes and complaints, including Telstra’s Accelerated Investigation Process for Equivalence Complaints.

To submit an Equivalence Complaint under the Accelerated Investigation Process


Equivalent Services

This list of Equivalent Services sets out the Regulated Service and the corresponding Equivalent Service(s) as required under Clause 9A of the SSU.

New or amended services

We will update this list if an eligible service becomes an active declared service (new declared service) or the ACCC amends the service description of an active declared service with the effect of increasing the scope of services that fall within the service description of that declared service (amended declared service). Within 90 days of such events, we will update this List of Equivalent Services to identify the Equivalent Service for the new declared service or the amended declared service.

List of Equivalent Services as at 7 May 2012

 

Regulated Service Equivalent Service(s)
Wholesale Line Rental Retail Line Rental
Domestic PSTN Originating Access Service The local exchange access component of the Basic Telephone Service
Domestic PSTN Terminating Access Service The local exchange access component of the Basic Telephone Service
Local Carriage Service The local calls component of the Basic Telephone Service
Domestic Transmission Capacity Service The carriage of communications between one point and another point on Telstra’s network via symmetric network interfaces on a permanent uncontended basis in connection with the supply of retail services.

The Equivalent Service will vary depending on the category of wholesale service being supplied in fulfilment of the DTCS service declaration. As a consequence, for this purpose the Equivalent Service for each such category of wholesale service:
  • will be the basic carriage component of the Telstra service that:
  1. is the same kind of service as that category of wholesale service;
  2. uses the same network interface as that category of wholesale service; and
  3.  has the same speed (or the closest lower speed) as that category of wholesale service;
  • but, for the avoidance of doubt, excludes any part of that service which comprises:
  1. any redundancy or route diversity features or functions;
  2. management services associated with that service; or
  3. any features or functions of that service which are an overlay to the basic carriage component of the Telstra service. 
     
Line Sharing Service The Layer 2 component of Telstra’s Retail ADSL Service
Wholesale ADSL Layer 2 Service The Layer 2 component of Telstra’s Retail ADSL Service
ULLS The continuous metallic twisted pair component of the following services between a Telstra local exchange MDF and the network boundary point at an end user premises:
  • Retail Line Rental;
  • the Layer 2 component of Telstra’s Retail ADSL Service.
TEBA The use of an Exchange Building Facility (or any External Interconnect Facility associated with that Exchange Building Facility) in connection with the supply of Equivalent Services . 
 


1This does not prevent or restrict Telstra from planning and managing capacity in its Exchange Building Facilities or External Interconnect Facilities in a manner that provides for dedicated areas to be allocated within an Exchange Building Facility or External Interconnect Facility (or any part of it) for use by TEBA customers separate from those areas allocated for use for other purposes, including in connection with the supply of Equivalent Service

 

Download the list of Equivalent Services here

 

Please note

This does not prevent or restrict Telstra from planning and managing capacity in its Exchange Building Facilities or External Interconnect Facilities in a manner that provides for dedicated areas to be allocated within an Exchange Building Facility or External Interconnect Facility (or any part of it) for use by TEBA customers separate from those areas allocated for use for other purposes, including in connection with the supply of Equivalent Services.

 

 


Equivalence Processes

Under the Structural Separation Undertaking, Telstra is required to publish for each Regulated Service and its Comparable Retail Service (Comparable Retail/Wholesale Process Descriptions) a detailed description of the following:

  1. the processes and systems used for Service Qualification;
  2. the processes and systems used for Service Activation and Provision; and
  3. the processes and systems used for rectification of Faults.

 

 

 

Product

Service Qualification Service Activation and Provisioning Fault Detection, Handling and Rectification
Basic Telephone Service  Not Applicable Basic Telephone Service Activation  Basic Telephone Service Assurance
Basic Telephone Service - Wholesale (PSTN OA, TA and LCS)) Not Applicable PSTN Activation  PSTN Assurance
ADSL Layer 2  ADSL Layer 2 Service Qualification ADSL Layer 2 Activation  ADSL Layer 2 Assurance
Megalink  Megalink Service Qualification Megalink Activation  Megalink Assurance
DCS  DCS Service Qualification DCS Activation  DCS Assurance
LSS  LSS Service Qualification LSS Activation  LSS Assurance
ULL  ULL Service Qualification VULL Activation
IULL Activation
e-VULL Activation
DULL Activation
TULL Activation
ULL Assurance
Exchange Based Diversion  Not Applicable  Exchange Based Diversion Activation  Not Applicable

Download the Equivalence Glossary here 

Quarterly Operational Equivalence Reports