ACMA submission on wholesaler data usage

I've just made a submission to the Australian Communications and Media Authority regarding the 48 hour data usage reporting delay that mobile service wholesalers like Optus impose on their wholesale customers. This can lead to incredibly huge bills with no warning and no way to prevent the bill as part of the service.

The TCP ACMA bill shock provisions that came out of the RTC enquiry were supposed to prevent this, but left a huge loophole by permitting "up to" 48 hours delay in usage alerts and reporting. Optus, at least, appears to treat this as "at least 48 hours", failing to report usage until the 48 hour time. It was a limit, not a target, Optus.

The spend management alerts were supposed to be implemented by small providers by September 2014, but they have the same 48 hour exception:

Spend management

• Suppliers to send notification alerts of data, voice calls and SMS usage within included value plans no later than 48 hours after the customer has reached data usage and expenditure thresholds of 50, 85 and 100 per cent.
• Suppliers to include additional notification information about charges applying to included value plans when the customer has exceeded 100 per cent of data or expenditure usage

Industry players are seem to be using this to bypass the intent of the code, which was to provide "access to timely, accurate and comprehensible information about their service"

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Australian Bandwidth Pricing

I recently switched hosting of large files (12Mb or so PDFs) on my employer's website from the existing Australian host to one in the USA. Why? Because it's cheaper to send data from the USA to Australian users than it is to send it from within Australia..

About 100x cheaper, in this case, when comparing Anchor Networks per-Gb pricing to SimpleCDN's.

SimpleCDN doesn't have any Australian node(s). Data gets requested by their US nodes on first request, cached, and sent back to Australia. Yet they're incredibly, vastly cheaper than anything local I can find.

The root of the problem appears to be that Australian hosting providers charge all IP traffic as if it were to go via an international link. There's no provision made for peering or intra-national traffic at the majority of hosts. This may be an issue with the hosting provider its self, or it may be with their upstream bandwidth suppliers, but I don't care. Internet routing is designed to solve this sort of problem - thankyou BGP - and peering points exist for a reason.

It's actually way cheaper to store your data in the UK, Ireland, Germany, France, or pretty much anywhere except Australia even if your users are 100% Australian. Isn't that kind of sad?