The Broadcasting Services Amendment (Online Services) Bill 1999Comments from Kirrily Robert Morgan Jaffit Benno Rice on behalf of Netizen Pty Ltd (ACN 086 373 417) http://netizen.com.au/Main issues:1. This bill will not achieve its stated purpose of preventing children from seeing pornography or other unnacceptable material on the Internet2. The cost of implementing this bill as written would be prohibitive3. The implementation of filtering as outlined in the bill is technically infeasible, and will not be feasible any time soonDetailed points:1. This bill won't stop pornPornography and other content which would be restricted under this billis available by many means both online and off. Not only will this billnot stop children from seeing unsuitable material, but it will be LESSeffective in doing so than methods already available: parentalsupervision, and end-user filtering software such as "Net Nanny" whichruns on the user's own PC.2. Too few resources, too many web pagesThe Australian Broadcasting Association (ABA) and the Office of Filmand Literature Classification have insufficient resources to classifyeven a small proportion of the Internet's content. With hundreds ofmillions of web sites currently online, and approximately doublingannually, there is absolutely no way that the procedures outlined in thebill could be used to filter inappropriate content.If any attempt to censor content following the methods outlined within the bill was actually made, it would require the ABA and OFLC to spend inordinate amounts of money ($4000 per rating times 100,000,000 websites in the first year alone).3. Internet Content is not only web pagesThe bill fails to address the major issue of exactly what constitutes"Internet Content". Internet content is not the same as television,film or computer game content; it includes everything from static webpages to discussion groups, personal email, real-time "streaming" audioand video, real-time chat, and more. The bill, as written, would haveto apply to all these media, and most of them simply cannot be filteredor classified due to their ephemeral nature.In addition, the system of 'blocking' referred to in the bill would result in all live (chat, video etc) uncensored internet media being blocked, due to the potential for unnaceptable language.4. Stricter classifications than necessaryAccording to paragraphs 10 and 11 of the bill, all Internet Contentwould be classified as if it were a film or computer game. Theclassification of films and computer games is stricter than for printedmedia, and far stricter than for written material which has artistic orother merit. If web pages were classified as computer games, pageswhich contain "sexually explicit language" or "depictions whichencourage the use of tobacco or alcohol" would be censored. Thiscould include sites such as Carlton United Breweries, for example.5. Technological and procedural impossibilitiesInternet Service Providers would be forced to install hardware andsoftware of enormous capabilities in order to filter content asrecommended in the bill. The cost of this is estimated at over amillion dollars even for a small to medium sized ISP -- high enough tosend most of them out of business. Those that remain will need to haveextra staff available at all times (including weekends) to deal withtake-down orders from the ABA; failure to do so could result in hugefines on a daily basis.6. Australia: internet leaderAustralia currently holds a position as one of the foremost countries indeveloping and encouraging Internet services and commerce. If thebill's censorship measures were enforced, Australian Internet serviceswould all but cease, and Australia would become a disconnected "ghetto"in an increasingly connected world.7. Effect on business and the communityThis bill would result in many small to medium Internet ServiceProviders (ISPs) going out of business. Subsequently, many companiesand individuals will be unable to communicate via the Internet. Thosethat do will be unable to employ minors as staff, in case they witnessunsuitable Internet content. Schools and universities will have tosignificantly restrict their Internet connectivity. ISPs in rural areas will be particularly hard hit. As they are often the sole means ofInternet connectivity in their area, country businesses, families andschools will be left without Internet access.