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The ACCC has issued a discussion paper inviting comment from industry stakeholders and consumers in relation to Telstra's structural separation undertaking and draft migration plan.

The ACCC is considering whether to accept a structural separation undertaking and approve a draft migration plan submitted by Telstra. If the undertaking and plan are accepted and approved respectively, various protections would be provided from competition laws to facilitate the structural separation.

The ACCC has expressed the preliminary view is that Telstra's undertaking cannot be accepted in its current form and that important changes are required.

Telstra submitted the undertaking on 29 July and the draft migration plan on 24 August.

The ACCC has indicated that it does not intend to issue a draft decision prior to finalising its decisions in relation to the undertaking and draft migration plan.  It had encouraged interested parties to make submissions in response to its discussion paper by no later than 5 pm on Tuesday 27 September 2011.