Google Australia Level 18, Tower 1 Darling Park 201 Sussex Street Sydney NSW 2000
Tel: 02 9374-4000 Fax: 02 9374-4001 www.google.com.au
The Manager Education and Telephone Content Section Australian Telecommunications and Media Authority firstname.lastname@example.org
Google welcomes the opportunity to comment on ACMA’s Draft Restricted Access Systems Declaration 2007 as attached to the ACMA Consultation Paper released 26 October 2007 (RAS Declaration).
Google thanks ACMA again for extending the time for lodgment of this submission and appreciates the opportunity to provide detailed comments upon the draft RAS Declaration prior to its finalization.
The structure of this submission is as follows:
an Executive Summary of Google’s recommendations;
an outline of Google’s structure and services;
some suggestions for improvements of the RAS Declaration.
Google notes that ACMA will make the declaration to facilitate implementation of Schedule 7 – Content Services of the Broadcasting Services Act 1992 (BSA) and in particular clause 14 – restricted access system of Schedule 7. Google has fundamental concerns with the drafting of key provisions of Schedule 7 which ACMA will be required to administer. However, Google’s comments in this submission are limited to the manner of exercise of discretions by ACMA in respect of the RAS Declaration.
Although Google does not believe that Schedule 7 currently applies to Google’s services, Google is making this submission as it wishes to ensure that the regulation is workable for the industry generally and continues to encourage content product innovation and usage, and also to ensure that Google would be able to ensure appropriate compliance with content regulation in Australia to the extent that any of its services become subject to these regulations.