Even as the 1989 legislation was passed, it was clear that further change was inevitable. The 1988 Statement and subsequent legislation forecast further policy reviews and structural changes. There was continuing industry pressure for further change, although the 1989 reforms had been welcome. Ambiguities in the legislation, particularly the delineation of reserved services, meant at least some change would be necessary. As the Minister said in 1989:
The Government's telecommunications policy did not become a `closed book' with the passage of the Telecommunications Act this year. We are fully aware that the rate of change in this industry is such that a continuing process of review and refinement will be required.[105]
The 1988 Statement foreshadowed reviews of several issues. Some would be undertaken by government or the Department. Others would be undertaken by the new regulator. And some changes would be implemented to timetables already set.
One of the important reasons the government did not introduce network competition in 1989 was the uncertainty about the cost of Telecom's CSOs and the fear that the introduction of network competition would jeopardise Telecom's ability to continue to fund those obligations through cross subsidies. The Statement, therefore, recommended that the Bureau of Transport and Communications Economics (BTCE) report on the costs and cross subsidies associated with Telecom's meeting its CSOs.
The BTCE's initial report went to the Minister in September 1989. Its initial costing of CSOs used the `avoidability approach' which measures `the additional resources required by Telecom to meet its CSOs'.[106] The resulting CSO cost was reportedly between $66 and $185 million.[107] Telecom rejected both the BTCE's costing methodology and resulting CSO costs, arguing for a `fully distributed cost' approach which `apportions the total cost incurred by Telecom between commercial and CSO services[108] and which would have put CSO costs at $640 million.[109] Minister Willis reportedly accepted the BTCE's costing methodology but disputed some of the figures used and proposed a higher CSO cost.[110]
By the end of the year, the BTCE's report on CSOs was released. Using `avoidability' costing, the BTCE estimated CSO costs as between $240 million and $295 million, depending on the figure used for the opportunity cost of capital.[111] The Minister accepted both the final BTCE figures and its costing methodology, and instructed Telecom to use the `avoidability approach' for its policies, strategies and costings for CSOs.
The BTCE report was criticised at the time for not properly defining CSOs before costing them and dealing with CSOs in purely economic terms, without examining the social policy implications of CSO terminology.[112] For others, the BTCE Report, with its relatively low cost for CSOs `took away one of the barriers' to competition', allowing the government to `look again at other market structures' for telecommunications.[113]
The policy Statement had recommended that, on its establishment, AUSTEL be required to report on the implications of licensing an additional cellular mobile telephone operator. The government went further, asking AUSTEL in August, 1989, to review both the implications of licensing an additional CMT operator and the best means of introducing Public Access Cordless Telecommunications Services (PACTS) into Australia. Submissions for both reviews were due by October, and the reports for the reviews expected by early 1990.[114]
There were two aspects to Telecom's monopoly over the attachment of customer equipment to its network: its right to permit (or not) the actual attachment of equipment and its monopoly over setting the technical standards with which equipment must comply.
As discussed earlier, regulations passed under the Trade Practices Act had exempted some of Telecom's areas of monopoly from trade practice action for a limited time. For PABX maintenance, the exemption would end on 1 January 1989 and for small business systems, on 1 July 1989. Legislation also continued Telecom's monopoly over the supply, installation and repair of the first telephone until 30 June 1991.[115]
The network boundary would move from the first telephone handset (provision and maintenance) to the first telephone socket or (for larger commercial premises) the building's main distribution frame (MDF) on 1 July 1989, effectively opening up the provision of customer cabling beyond the network boundary.
Telecom had developed a range of standards covering both equipment and customer cabling. DTC prepared a paper in October 1988, suggesting that existing technical standards be streamlined into fewer core regulatory standards identified as necessary to ensure network safety and integrity and inter-operability. The core standards for equipment and cabling were adopted as interim standards by AUSTEL by June 1989, pending review of the standards through AUSTEL's standards setting procedures.[116]
The 1988 Statement highlighted Telecom's importance to the telecommunications equipment manufacturing industry and recommended a review of Telecom's arrangements for using locally manufactured products, with new industry arrangements to be in place by the end of December 1988. Industry Development Arrangements were subsequently developed and adopted by government, coming into effect in January 1989.[117]
The scheme was points based, with points allocated based on the degree of Australian and New Zealand production, the amount spent on research and development and the extent to which the equipment was exported. Suppliers would qualify for authorisation to market their equipment in Australia and/or connect them to the network, based on a sufficient allocation of points.[118]
The 1989 legislation had addressed many telecommunications issues under debate. Competition had been introduced in equipment and cabling; the monopoly areas of the carriers had been defined, and an independent regulator created with a range of powers to both protect the carriers' monopoly rights and assist competitors in the market. The reviews being undertaken and continuing industry pressure meant, however, that the 1989 structure would continue to change.
One of the continuing issues for industry was the restrictions on private network operators. Private network capacity could only be used by the `person supplying the service' or persons `all of whom have a common interest with each other'.[119] Private network operators could not `sell or otherwise dispose of' spare network capacity to other than a carrier.[120]
In July 1989, the Minister asked AUSTEL to review arrangements for joint use of private network capacity. AUSTEL's report, released in February 1990, recommended expanding those eligible for `common interest' status and thus able to share in private network capacity.[121] The suggested reforms were implemented as part of the November 1990 policy reforms.
The AUSTEL common interest report did not deal with the resale issue. It did however, report on continuing industry pressure for resale of spare capacity and implied that the resale restrictions should be reviewed.[122]
For industry, the restrictions on private networks were still too tight; the common interest test `did not provide real benefits' and it was `obvious' that the restrictions meant a large waste of capacity; megalinks had been constructed by corporations and they could not sell the spare capacity.[123]
Another difficulty was with the term `only'. Many services provided by Telecom included functions which would fit the reserved service definition, but included other functions as well. The issue was whether the whole service would be treated as a reserved service because some of its functions were reserved, whether the whole service would be open to competition because it included some functions which were open to competition or whether the service would be considered a partially reserved service - only those functions of the service fitting within the reserved service definition would be protected from competition.[126]
Section 36 of the Act added another difficulty. It included a declaration of policy that carriers' exclusive rights extend to the provision of, inter alia, public switched data andvideo services and text services. Those services can extend beyond the services implied by the reserved services definition, yet were intended to be reserved services. Did the government intend that section 36 should override the words in sections 52 and 53.
Telecommunications services provided by radiocommunications were another difficulty.[127] Private Networks can be supplied by both lines and radiocommunications, or a combination of both. If lines were used, the installation and use of the network was covered by telecommunications legislation. If networks also used spectrum, it was difficult to determine where the carrier reserved service ended and competition was permitted.
An added difficulty with defining the reserved service boundary was that both AUSTEL and government could affect the way the boundary was drawn.[128] As Telecom's former Managing Director said:
It was our view inside Telecom that regulation based on technology was unsustainable; that regulation build on artificial service barriers was unsustainable; and that a number of opportunistic players were going to continue to put pressure on the Government to be involved. [129]
The 1988 Statement made it clear that there would be a review of the structural relationship of the three carriers once the major reforms were bedded down. What the review would cover and when it would be held, however, were left open.
While the review was forecast, it was not expected to be undertaken so quickly. The reason for the timing of the review, most commentators agree, was AUSSAT.[130]
It was more significant as a catalyst for change. It was the fact that AUSSAT was there, facing a very large and bleak financial future. That was one of the pressures on government to make the changes when it did and why the Gareth Evans' model lasted as short a time as it did.[131]
By 1989, AUSSAT's financial position was coming under close and worried government scrutiny. In May 1989 the government announced it was doubling AUSSAT's authorised capital, from $100 to $200 million to ease AUSSAT's debt burden.[132] As one commentator observed, the grant of additional equity to AUSSAT `focussed caucus' mind' on AUSSAT's financial situation and raised questions as to whether the Government would keep funding AUSSAT.[133]
On December 6, AUSSAT's Annual Report was released. It showed AUSSAT had a debt to equity ratio of 22 to 1. AUSSAT Managing Director Graham Gosewinkel blamed government policy and said unless there was a change in that policy, `AUSSAT was likely to be in difficulties for the next three years'.[134]
In December, CIRCIT researcher Dr Sam Paltridge released a paper detailing the depth of AUSSAT's financial crisis. Total revenue had fallen short of projections in the first three years by $93 million. AUSSAT's accumulated loss from 1983-1988, before anticipated future tax benefits were taken into account, was more than $107 million. Paltridge warned it was `now clear that AUSSAT is not going to generate the profits necessary to pay for the current system let alone finance the second generation of satellites over the next four years.... Even if AUSSAT can maintain revenue increases in line with past trends, the accumulated shortfall between actual and projected revenues in 1993 will be in the order of $330 million'.[135]
Opening the conference where Paltridge's paper was presented, Minister Willis called AUSSAT's debt to equity ratio of 22 to 1 `frightening' and said AUSSAT's performance `gives rise to real concern about the future.'[136] The government's response was ROSA.
On December 6, the Minister announced the review of structural arrangements would be brought forward. The review would be conducted by the DTC and report to government by 30 June 1990.[137] The issues to be addressed by the Review included:
For the next six months, the carriers, industry, consumer organisations and others made submissions to the review which were, with few exceptions, made publicly available. The DTC ROSA team also `talked to the main players' although there was no formal consultative process.[139]
AUSTEL's reports on mobile telephony (CMT and PACTS), released in April 1990, also impacted on the review. The CMT report recommended that three operators be licensed, one of which would be issued to Telecom's MobileNet. The PACTS Report recommended that the three operators licensed to provide CMT also be licensed to provide PACTS as well. However, other PACTS operators would be allowed to operate under a class licensing system in competition with the three CMT operators. The licensing arrangements for CMT and PACTS providers were to be in place by December 1990.[140]
Most of the major submissions focussed on two inter-related issues: whether further competition should be introduced and, if so, the parameters of that competition; and the structural arrangements between the three carriers or, put more crudely, how to solve the AUSSAT problem.
The introduction of more competition was almost a foregone conclusion. After being re-elected in March, Prime Minister Hawke reportedly wrote to the then Minister for Transport and Communications Kim Beazley, arguing for more competition in telecommunications. Where and how more competition would be introduced was left open.[141]
There were some obvious areas for liberalisation. AUSTEL had recommended opening up the mobiles market. AUSSAT had argued in its annual report for removal of restrictions on its ability to compete in service provision. Industry was lobbying for opening resale to competition. Whether the government would go beyond those reforms and introduce competition in providing basic services and infrastructure was open for debate.
The major telecommunications unions argued against further liberalisation or competition in the industry. Their submission discussed overseas experience with competition, particularly in the provision of basic telephony, and concluded that more competition would not further the government's policy objectives of universal service.[142]
Consumer and public interest groups argued for `limited competition'.[143] The Consumers' Telecommunications Network (CTN) foresaw more competition in both private networks and value added services and argued for appropriate regulatory measures to mitigate against the possibility of network by-pass. The Communications Law Centre (CLC) also argued for some opening of competition: limited competition in mobile telephony, open competition in the VAS market, open competition in the provision of the first phone handset and permitting resale of private network capacity.[144]
The monopoly on provision of basic telephone infrastructure and service should, however, be maintained. As the CLC argued, the `efficiency value of a competitive trunk infrastructure would be minimal, since the areas of Telecom's operations requiring the greatest improvements are not the efficiency of carriage, but are rather local access, the quality of service, and general customer assistance'.[145]
Although not in total agreement, most industry groups argued for more competition beyond opening up resale and the mobile market. AUSSAT should be allowed to compete with Telecom and OTC in providing local and international services using any appropriate technology.[146] ATUG went further, arguing for the removal of all barriers to entry in the provision of all domestic and international networks and services and the introduction of pro-competitive safeguards.[147] Infrastructure competition would not jeopardise Telecom's provision of community service obligations as the cost of meeting the obligations `has now been shown to be far less than claimed over the years by Telecom....'[148]
The carriers had divergent views on whether and how further competition should be introduced. AUSSAT argued it should be permitted to provide `the full range of services, including public switched telephone service, `serve all destinations and utilise all technologies'. Competition should be allowed in mobile telephone and resale of private network capacity should be allowed. However, the provision of basic telephony infrastructure and services should be `reserved to (two or more) licensed competing carriers'.[149]
OTC argued for competition `across the full range of telecommunications services and facilities', but over a `sequenced' transition period, based on `the industry's capacity to adjust, the underlying dynamics of technology and the demands of the market.[150] After the transition period, there would be open competition, subject to safeguards to minimise `potential abuse of market power by foreign monopolists'.[151]
Telecom might have been expected to argued for retention of its monopoly on, at the least, provision of infrastructure and basic services To the surprise of some, it argued instead for managed change. The worst option, in Telecom's view, was the `default option of gradual network competition creep through a succession of regulatory decisions taken on a stand-alone basis'.
With the results of the mobile inquiry out, liberalisation of common interest groups recommended and the real possibility of a further review of resale of private network capacity, there would have been, in Telecom's eyes, `effective network competition without the real thing'. So the view was taken it was better to go for real competition and `get the safeguards with it'; it was the `only way to flesh out the seriousness of the decisions' being made and ensure safeguards would be put in place.[152]
Without spelling out where more competition would be introduced, it was clear from both of Telecom's submissions that it envisaged the introduction of network competition.[153] What Telecom's February submission argued for were `key conditions' to allow it to effectively compete in a more competitive market place, including commercial access to capital markets, access to new opportunities, commercial determination of interconnect arrangements, less industry-specific regulation, the ability of operate commercially and the ability to address current cost/price distortions.[154]
The other major issue address by most of the major submissions was the structural arrangements between the three carriers or, more crudely, how to solve the AUSSAT financial problem within the framework of a more competitive environment.
Consistent with its arguments for a limited competition model, the Communications Law Centre argued for the merger of Telecom and AUSSAT, leaving an independent OTC to compete with the new organisation in the VAS and private networks markets and possibly mobile telephony while retaining its exclusive right to provide international services.[155] The CTN submission reviewed possible structural options, finally favouring the merger of all three carriers into a `megacom' with monopoly over the public switched telephone network.[156]
Given the union's position on competition, not surprisingly they argued for the merger of Telecom and OTC, after which the new organisation would `acquire' AUSSAT, `on condition it could wind up the company and withdraw from AUSSAT's contractual obligations'. If that were not possible, AUSSAT should not be merged with the new company.[157] In any case, none of the organisations should be privatised.
In the negotiations leading up to the government's final decision on structural changes, the unions also developed a fall back position: the merger of Telecom and OTC facing competition from AUSSAT. As explained, the unions `wanted to be sure the competitor got a liability - AUSSAT - not an asset - OTC'. If OTC were made the basis of competition with Telecom, the new competitor would gain 100% of OTC's overseas traffic. With AUSSAT as a basis for a new entrant, the competitor would have to win all of its customers.[158]
Industry's pro-competitive position was reflected in its submission on structural arrangements. Both the AIIA and ATUG submissions argued against the merger of the three carriers as anti-competitive.[159] AIIA would have `solved' the AUSSAT problem through allowing it to compete more fully and permitting private investment in the company.[160] ATUG went further. It argued for not only for privatising AUSSAT, but for structurally separating Telecom into three subsidiary companies for a five year period or until privatised. OTC's current restrictions would remain, again for five years or until privatised.[161]
Not surprisingly, AUSSAT argued to remain an independent company which should be privatised `immediately the change in industry structure' was in place.[162] As predictably, OTC argued against merging with Telecom. To `solve' the AUSSAT problem OTC argued instead for its merger with AUSSAT, arguing AUSSAT was not viable as a satellite-only carrier but that the merger of the two would allow rationalisation of shared capacity and facilities.[163]
Telecom also argued that AUSSAT `cannot continue in its current form and under current constraints.[164] After reviewing the structural options. Telecom concluded that a megacom accompanied by external competition' was the best structural solution.[165] Within Telecom, however, there was doubt that its preferred option would be adopted and a second choice option was developed; the merger of Telecom/OTC competing with a privatised AUSSAT (as the basis of a new competitor).[166]
In the end, DTC's report to government in June listed several competitive models, ranging from full and open competition among multiple carriers to maintenance of the current monopoly structures. In reviewing the models, various issues were canvassed including continuation of the first phone monopoly, resale of private network capacity, provision and funding of social obligations, pricing issues and control, and regulatory changes necessary with different competitive models.[167]
Once DTC's ROSA report went to government, it was up to Cabinet to determine the final shape of further telecommunications reform. And the debate within Cabinet became a surprisingly public one. Both Minister Beazley's Cabinet submission and Treasurer Keating's alternative views were published in the press.
Beazley's submission argued for the introduction of `across-the-board competition in both the domestic and international market network', although, initially, competition would be restricted to a carrier duopoly for provision of basic infrastructure. Full and open competition was rejected as a `high risk approach to securing effective broadly based competition'. An oligopoly based on the three carriers was also considered `high risk' because AUSSAT `may not prove to be a viable carrier when competing against both Telecom and OTC. Adopting a duopoly structure would allow a new competitor to `strive for market share' on a `relatively stable and predictable basis' and the duplication of infrastructure would be minimised. Further, the government could more easily manage issues of social obligations and industry policy.[168] The submission did not make a recommendation on allowing resale of private network capacity, saying that the matter would be referred to AUSTEL for investigation.
The duopoly model Beazley argued for was the merger of Telecom and OTC, with the second carrier based on a privatised AUSSAT The rationale for his choice was that merging the two would combine their `resources and financial strengths' without AUSSAT's debts. The merged entity would create a `strong national carrier' to allow `full and vigorous competition across the network'. A new competitor, based on AUSSAT, could take advantage of AUSSAT's infrastructure and customer base and, happily for the government, `responsibility for AUSSAT's debts would be assumed by the purchaser rather than the government'.[169]
The `Beazley model' was not universally accepted within Cabinet. Treasurer Keating argued for full network competition.[170] He rejected the Beazley model as a `step backwards' to a `less competitive, more entrenched structure'. The only way a `megacom business' could be contemplated was if `all parts of the megacom business be capable of being contested in an open market'. Full resale of private network capacity should be introduced and any merged entity should be structurally separated based on its activities: local, STD and international services, VAS and mobile services.[171] The structural model finally argued for by Keating was the merger of AUSSAT and OTC, competing with Telecom.
In September, Cabinet adopted the Beazley model.[172] The government still, however, faced the problem that the ALP Party Platform would not have permitted the structural changes adopted by Cabinet. Later in September, therefore, the ALP held a special national conference on the issue. In the conference, major unions continued to argue for no change to the current structure, but were also arguing for the Beazley model. They were `unhappy with a competitive model' but, if there must be a competitive model, they were `not unhappy with model they got'.[173]
The ALP changed its platform at the special conference to accommodate the proposed structural arrangements, but only in exchange for guaranteed safeguards both on the merged Telecom/OTC and on consumer protection issues.[174] Telecom/OTC would not be privatised and `maximum possible ownership' in the telecommunications industry would be maintained. All government imposed constraints on Telecom `which limit its ability to respond effectively to competition and do not serve the broader national interest' would be removed. The regulatory regime should discourage `unnecessary duplication of infrastructure, wasteful diversion of resources and `cream skimming'. And the competitor's cost to interconnect into Telecom/OTC's network should `at least' cover both the cost of Telecom/OTC meeting their social obligations and the capital costs of allowing that access. As a further consumer protection measure, any price rebalancing would be subject to price controls.[175]
In the end, the Beazley model was the basis for the November Policy Statement and legislation. But the model also reflected concerns expressed by the ALP Special Resolution and the myriad inputs on necessary consumer and competitive safeguards argued for in ROSA submissions.
[105] Minister for Transport and Communications, 1989.p. 9. Telecom's then Managing Director Mel Ward is also quoted as saying "His [Evans] model was never expected to be a long term model. There may have been other rhetoric ... but his model was never considered to be one which would last forever'. In Ward's view, the 1988 changes were part of the `graceful change' process towards a more competitive environment. Ward, 1992, p. 47.
[106] Bureau of Transport and Communications Economics, 1989, p. 16. For full discussion of BTCE's costing procedure, see especially Chapter 5.
[107] Australian Financial Review 27 November 1989.
[108] BTCE, 1989 P. 16.
[109] Australian Financial Review 8 November 1989.
[110] Ibid.
[111] BTCE, 1989, p. 84
[112] Communications Law Centre , Objectives and Definitions for CSOs, August, 1990. See also P. White, Community Service Obligations and the Future of Telecommunications, Commissions for the Future, June 1990.
[113] Interview T. Shaw.
[114] AUSTEL, 1900,b p. 8 and AUSTEL 1990c, p 8.
[115] Section 47 Telecommunications Act 1989.
[116] Grantly Brown, `Regulation of the Equipment and Cabling Markets', Armstrong, 1990, pp 142-3.
[117] R Kelly, Minister for Telecommunications and Aviation Support, Notification of Policy [to AUSTEL] 1 December, 1989.
[118] For full description of the IDA scheme, see G. Brown, Op. Cit., pp 147-161.
[119] Section 4 Telecommunications Act 1989.
[120] Section 72(a) Telecommunications Act 1989.
[121] AUSTEL, 1990d, p. 3.
[122] Ibid, p. 18.
[123] Interview Wally Rothwell, Executive Director ATUG.
[124] Sections 52 and 53 Telecommunications Act 1989.
[125] See Peter Leonard, `Value Added Services; Boundary Issues and the Class Licence, Armstrong, 1990, p. 108.
[126] For discussion of the issue, see Ibid, pp 108-109.
[127] Interview Chris Cheah, formerly with the Telecommunications Policy Division, DTC.
[128] AUSTEL's functions under the Act included protecting the carriers' monopoly area, yet the Act also allowed the government to pass regulations which could determine whether services were reserved to the carriers.
[129] Mel Ward Interviewed, Australian Communications, July 1992, p. 48.
[130] Interview T. Shaw, J. Saunderson, J. Smith, W. Rothwell.
[131] Ward interview, Op. Cit., p. 48.
[132] Australian Communications December/January 1990/91, p. 8.
[133] Interview C. Cheah.
[134] Australian Financial Review, 7 December, 1989.
[135] S. Paltridge, 1989, p. 8.
[136] Quoted in Communications Update No. 52, February 1990, p. 3.
[137] Australian Financial Review, 7 December, 1989.
[138] For full terms of reference, see Communications Update, No 52, February 1990, p. 5.
[139] Interview T. Shaw.
[140] AUSTEL, 1990b p. 8 and AUSTEL 1990c p. 8.
[141] Interview J. Saunderson.
[142] Australian Telecommunications Employees Association (ATEA)/Australian Telephone & Phonogram Officers Association (ATPOA), February, 1990, Chapters 2 and 4.
[143] Consumers' Telecommunications Network, (CTN) July 1990, paras 3.1-3.2. and Communications Law Centre (CLC), June 1990, Chapter 4.
[144] CLC 1990 p. 5.
[145] Ibid. p. 10.
[146] Australian Information Industry Association, February 1990, pp 1-2, 22-23.
[147] Australian Telecommunications Users Group (ATUG) February 1990. See pp vii to xii for ATUG recommendations.
[148] Ibid p. vi, referring to the BTCE Report, 1989.
[149] AUSSAT, February 1990, pp 2-3.
[150] OTC Limited, February 1990, p. 1.
[151] For discussion of Phase 3, see Ibid, pp 18-20.
[152] Interview J. Smith. See also Ward 1992, p 48. `Telecom found itself facing a de facto fully competitive world, while it was still being treated as a monopoly. Now the primary aim was to be able to say: Let the competition come, but in a way that allows the national carrier ... to operate in a commercial mode.'
[153] Telecom Australia, February 1990a, p. 15 and Telecom Australia, June 1990b, pp 10-13,
[154] Telecom Australia, 1990a p. 11.
[155] Communications Law Centre 1990 p. 20.
[156] CTN 1990 p. 20.
[157] ATEA/ATPOA 1990, pp iii-v, and pp 6-20.
[158] Interview J. Saunderson.
[159] AIIA 1990 pp 18-20. ATUG 1990, p. 47.
[160] AIIA 1990 pp 20-21.
[161] ATUG 1990 pp 47-48.
[162] AUSSAT 1990, p. 27.
[163] OTC Limited 1990, p. 3 and Attachment 1, p. 3.
[164] Telecom Australia, 1990b, p. 16.
[165] Ibid, p. 23.
[166] Interview J. Smith.
[167] Interview T. Shaw. The DTC report to government on ROSA was never made public.
[168] `Beazley's Megacom Submission', Australian Financial Review, August 14, 1990.
[169] Ibid.
[170] `McEwenism at its Very Worst' (transcript of Treasury briefing paper outlining Keating's position to be considered by the Structural Adjustment Committee of Cabinet) Australian Financial Review, August 16, 1990.
[171] Ibid.
[172] Australian Financial Review, September 11, 1990.
[173] Interview J. Saunderson.
[174] Australian Financial Review, September, 1990.
[175] Ibid. See also Australian Labor Party, Special National Conference Resolution: Telecommunications, September, 1990.