What is Structural Separation Undertaking (SSU)?
On 28 February 2012, the Australian Competition and Consumer Commission (ACCC) accepted Telstra’s Structural Separation Undertaking (SSU) and draft Migration Plan. The SSU commenced operation on 6 March 2012, while the Migration Plan took effect from 7 March 2012.
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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.
Commitment to equivalenceThe 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.
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.
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);
- 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 UpdatesEach 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.
- Download the latest Rate Card here (PDF, 1 MB)
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
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:
|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:
|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 (PDF, 109 KB)
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.
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:
- the processes and systems used for Service Qualification;
- the processes and systems used for Service Activation and Provision; and
- 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|
|DTCS||DTCS Service Qualification||DTCS Activation||DTCS Assurance|
|LSS||LSS Service Qualification||LSS Activation||LSS Assurance|
|ULL||ULL Service Qualification||VULL Activation
|Exchange Based Diversion||Not Applicable||Exchange Based Diversion Activation||Not Applicable|
- Download the Equivalence Glossary here (PDF, 85 KB)
Quarterly Operational Equivalence Reports
We set out below a link to our Quarterly Operational Equivalence Reports produced under the SSU for the provision and fault rectification of regulated services. Telstra will publish a copy of each Quarterly report within 5 business days of it being provided to the Australian Competition & Consumer Commission and the Independent Telecommunications Adjudicator. You can access the Operational Equivalence Reports via the links below.
- Operational Equivalence Report - November 2016 (PDF, 540 KB)
- Operational Equivalence Report - June 2016 (PDF, 539 KB)
- Operational Equivalence Report - March 2016 (PDF, 552 KB)
- Operational Equivalence Report - December 2015 (PDF, 540 KB)
- Operational Equivalence Report - September 2015 (PDF, 390 KB)
- Operational Equivalence Report - June 2015 (PDF, 459 KB)
- Operational Equivalence Report - March 2015 (PDF, 446 KB)
- Operational Equivalence Report - December 2014 (PDF, 454 KB)
- Operational Equivalence Report - September 2014 (PDF, 393 KB)
- Operational Equivalence Report - August 2014 (PDF, 482 KB)
- Operational Equivalence Report - March 2014 (PDF, 510 KB)
- Operational Equivalence Report - December 2013 (PDF, 465 KB)
- Operational Equivalence Report - September 2014 (PDF, 229 KB)
- Operational Equivalence Report - June 2013 (PDF, 498 KB)
- Operational Equivalence Report - March 2013 (PDF, 568 KB)
- Operational Equivalence Report - December 2012 (PDF, 443 KB)
- Operational Equivalence Report - September 2012 (PDF, 424 KB)