Ministry Comment and Recommendation
28. The Ministry also plans to develop a means of reliably benchmarking the price of data services to small to medium business. This is not possible at present because the necessary information is not available due to the high level of discounting off the so called standard list price.
29. In general New Zealand's relative performance in most categories is unsatisfactory and typically there is a very significant gap between New Zealand pricing performance and that of countries in the top half OECD performance.
30. Over time it is reasonable to expect New Zealand's performance to significantly improve. In particular, progress towards closing the gap between New Zealand's performance relative to the top half of OECD countries should be monitored and used as one of the bases for judging the effectiveness of the regulatory regime.
31. Should satisfactory progress not be made over a reasonable period of time, this along with other relevant considerations would provide a sounder basis for determining whether further regulatory measures should be considered.
32. The Ministry will shortly provide you with a report on the Commerce Commission's review of the wording of the proposed designated unbundled bitstream service (UBS). The report will recommend that you accept the Commission's UBS recommendation and move to implement it via an Order-in-Council. It is recommended that following implementation via an Order-in-Council you formally write to Telecom outlining your broadband performance measure expectations including related broadband service benchmarking issues such as making progress in closing the relative performance gap.
33. To assist in formulating and communicating your broadband service performance expectations to Telecom, the Ministry proposes to hold some preliminary discussions with Telecom.
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