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Development of the Danish LRAIC model
for fixed networks
Fixed LRAIC Model – 3rd Consultation Document
1 September 2020
Excellence in Business
2020© Axon Partners Group 1
Contents
Contents .............................................................................................................. 1
1. Introduction ................................................................................................... 2
2. The consultation process .................................................................................. 3
2.1. Description of the files submitted to consultation .......................................... 3
2.2. Procedure for clarifications ......................................................................... 4
2.3. Procedure to submit answers ...................................................................... 5
3. Key aspects relevant for the 3rd draft model ....................................................... 6
3.1. TDC’s model ............................................................................................. 6
3.1.1 Copper services ............................................................................................................... 6
3.1.2 Fibre services................................................................................................................... 9
3.1.3 Coax services ................................................................................................................. 12
3.2. Norlys’ model ......................................................................................... 14
3.2.1 Norlys’ fibre services ..................................................................................................... 14
3.2.2 Norlys’ coax services ..................................................................................................... 18
4. Questions for the 3rd consultation round ........................................................... 19
2020© Axon Partners Group 2
1. Introduction
Since 2003, the DBA has annually regulated the wholesale prices for several fixed-network
services through a Long Run Average Incremental Cost (LRAIC) model. As presented in
the Model Reference Paper (hereinafter, ‘the MRP’) from October 20191, the relevant
changes that occurred in the fixed Danish market since the last major update of the model
in 2013, merited a new update of the fixed LRAIC model (hereinafter, ‘the model’) to make
sure it is representative of the current situation and can fulfil DBA’s regulatory needs.
In 3 February 2020, DBA launched a 1st consultation round with the industry. This
consultation round aimed at providing stakeholders in the Danish fixed telecoms market
an opportunity to comment and advice on the draft version of the model developed by the
DBA with the support of Axon Partners Group (hereinafter, ‘Axon’), with the final objective
of maximising its representativeness and accuracy. With a similar objective, DBA launched
a 2nd consultation process in 4th May 2020.
The feedback from the industry for the 1st and 2nd consultations has been collected and
implemented into the 3rd draft model. DBA is now launching a final consultation round with
the industry with similar objectives - allowing stakeholders to review, comment and advice
on DBA’s model.
The 3rd draft model submitted to consultation builds upon the 2nd draft model, which was
developed following the methodological principles laid out in the MRP from October 2019.
DBA is specially interested in gathering feedback on the reasonability and
representativeness of the model’s inputs, calculations, and outcomes.
DBA invites stakeholders to participate in this consultation process following the indications
presented in the following section.
1 Link: https://erhvervsstyrelsen.dk/sites/default/files/2019-10/Final%20MRP.pdf
2020© Axon Partners Group 3
2. The consultation process
This section describes the consultation process, including:
Description of the files submitted to consultation
Procedure to submit answers
2.1. Description of the files submitted to consultation
The following files are shared with stakeholders as part of this second consultation round:
Consultation Document (this document): After a description of the consultation
process and the main changes implemented in to the 3rd draft model, it presents the
questions that stakeholders are expected to answer.
• The file provided is named 'Fixed LRAIC model – 3rd consultation document.pdf'.
Annex 1 – LRAIC Excel Model: This excel file contains the cost model (including its
inputs, calculations, and outputs/results). This model is responsible for calculating the
network assets, the cost base and the service-level costs based on the inputs it has
been filled in with.
Similarly as in the 2nd consultation round, all stakeholders have been provided with the
anonymised versions of TDC’s and Norlys’ cost models:
• TDC’s anonymised cost model: File named ‘Fixed LRAIC model – 3rd draft LRAIC
Excel model (TDC – Public).xlsb’.
• Norlys’ anonymised cost model (including PON and PTP fibre access): File named
‘Fixed LRAIC model – 3rd draft LRAIC Excel model (Norlys – Public).xlsb’.
As in previous consultation processes, for the sake of preserving the confidentiality of
the data provided by the modelled operators, the confidential inputs have been
anonymised by multiplying them by a random factor between ±30% in these versions.
Anonymised inputs have been marked in a different colour in the model.
Additionally, TDC and Norlys have been provided the confidential version of their own
models, particularly:
• TDC’s confidential cost model (provided only to TDC): File named ‘Fixed LRAIC
model – 3rd draft LRAIC Excel model (TDC – Internal).xlsb’.
2020© Axon Partners Group 4
• Norlys’ confidential cost model (provided only to Norlys): File named ’Fixed LRAIC
model – 3rd draft LRAIC Excel model (Norlys – Internal).xlsb’.
Annex 2 – LRAIC R Model: The R model is responsible for extracting several KPIs
mainly related to the dimensioning of the fixed access networks for the modelled
operator. Given the highly confidential and complex nature of the information included
in the R model, DBA is sharing a sample of the actual LRAIC R model, including
anonymised information on two random areas of Denmark. All relevant algorithms are
preserved in this version of the R model to allow stakeholders to review it in full.
• The file provided is named 'Fixed LRAIC model – 3rd draft R model (Sample).zip'.
Additionally, as in the 2nd consultation round, TDC and Norlys have been provided the
confidential version of their own models, particularly:
• TDC’s confidential R model (provided only to TDC): File named ‘Fixed LRAIC model
– 3rd draft R model (TDC – Internal).zip’.
• Norlys’ confidential R model (provided only to Norlys): File named ‘Fixed LRAIC
model – 3rd draft R model (Norlys – Internal).zip’.
Annex 3 – Excel model manual: This document introduces the general structure of
the Excel model, providing guidance on how to operate it for the first time. The manual
also explains the technical structure of the Excel model, the definition of its key inputs,
and the algorithms implemented to dimension the network, calculate its costs, and
allocate them to the final services.
The file provided is named 'Fixed LRAIC model – 3rd draft Excel model manual.pdf'.
Annex 4 – R model manual: This manual explains how to operate the R model as
well as its structure, providing detailed indications on the scripts included in the model
and the geographical calculations performed.
The file provided is 'Fixed LRAIC model – 3rd draft R model manual.pdf'.
2.2. Procedure for clarifications
We strongly recommend stakeholders taking part in this consultation process to analyse
all the materials provided along with this document. We expect that several potential
questions may already be clarified by going through these documents.
However, if there are still any questions or doubts about any of the aspects related to the
topics included in this document, we encourage each stakeholder to send a single set of
2020© Axon Partners Group 5
questions to DBA through the email addresses provided in section ‘2.3 Procedure to submit
answers’. Questions may be submitted within the first two weeks of the consultation
process (before Wednesday the 16th of September 2020).
Similarly to the 1st and 2nd consultation, DBA will hold a series of meetings with the industry
to clarify any questions that may arise during the review of the 3rd draft model. These
meetings will take place during the week of 21 September 2020.
2.3. Procedure to submit answers
This public consultation is conducted by DBA within the framework of its competences from
the Act.
Stakeholders are invited to submit their comments in reply to the relevant questions issued
in section ‘4 - Questions for the 3rd consultation round’ of this document.
The public consultation is launched on Tuesday 1 September 2020 and will end
on Tuesday 6 October 2020. Responses should be submitted in English and in
electronic form before the end of the public consultation.
Information that operators wish to be included in the final model (to be
presented to the industry in November 2020), shall be included along the
responses within the 6 October 2020 deadline.
The consultation responses from the industry may be published in full and outlining the
corporate name of the respondent by DBA. In case the responses contain confidential
information that should not be published, operators are responsible of reporting a separate
version of the document removing any information that shall be considered confidential
for publication.
Responses and questions should be submitted to the following email addresses:
[email protected] and [email protected].
Respondents are encouraged to support their statements and comments with any relevant
justifications, as DBA cannot accommodate suggestions without enough reasoning.
DBA will assume that if a stakeholder does not answer a specific question, the stakeholder
is accepting the approach presented to such question under this document.
2020© Axon Partners Group 6
3. Key aspects relevant for the 3rd draft model
The industry provided feedback in the 2nd consultation round that required a number of
changes and adjustments in the 3rd draft model. In turn, these changes have had an
impact in the results calculated in the cost model. The new results can be analysed in
worksheet ‘8A RESULTS SERV’ of the cost model. In the case of the “public” models, the
results of the confidential versions of the model are included in worksheet ‘3RD DRAFT
RESULTS’.
In the following subsections we present the results for the key services extracted from the
3rd draft model for TDC and Norlys. We include a comparison of these results against the
2nd draft model’s results, as well as the current wholesale regulated prices. Furthermore,
we detail the main drivers associated to the changes in the results observed between the
2nd and 3rd draft model.
3.1. TDC’s model
The subsections below outline the key results obtained in TDC’s 3rd draft model.
3.1.1 Copper services
The following chart presents the evolution of the 3rd draft model’s results for TDC’s copper
services:
2020© Axon Partners Group 7
Exhibit 3.1: Results of the 3rd draft model – TDC’s copper services [Source: DBA]
As can be extracted, there is a moderate evolution in the costs of the services compared
to the results obtained in the 2nd draft model. The differences observed between the
models can be explained by a series of changes implemented in the 3rd drat model, which
are illustrated below2:
2 The illustration presents the impact for the service “Raw copper at POI0”
875
972
1.028
1.109
839
904
1.033
1.079
823
932
1.095
1.172
-
200
400
600
800
1.000
1.200
1.400
Raw Copper Copper VULA Copper BSA - POI2 Copper BSA - POI3
DK
K/
lin
e/
year
Price decision (2020) 2nd draft model 3rd draft model
2020© Axon Partners Group 8
Exhibit 3.2: Impact of the changes implemented in the model for copper services [Source: DBA]
A high-level overview of the key changes presented in the image above is presented below:
Adjustments to R and Excel dimensioning: We have implemented a number of changes
to the R and Excel dimensioning based on the feedback received as part of the 2nd
consultation process. A log of the changes implemented in the Excel model is presented
in worksheet “CHANGELOG” of the 3rd draft Excel model, while for the R model, the log
of the changes is presented in Annex D of the R model manual.
Allocation of non-network overheads: We have adjusted the allocation of the non-
network overheads to services to follow an EPMU approach, based on the feedback
received as part of the 2nd consultation. Additionally, the inputs included for non-
network overheads have also been adjusted in the cost model, following the data
reported by TDC.
Changes in the unit costs of the network elements: We have adjusted the unit costs
for some network elements based on the new information and clarifications reported
by TDC. Figures have been updated in the model as reported by TDC, as long as i)
2020© Axon Partners Group 9
sufficient evidences have been provided and i) the figures were found reasonable
compared to data reported by other Danish operators.
Sharing with utilities: We have adjusted the percentage of costs borne by TDC in the
trenches shared with utilities from 50% to 60%. This change has been performed to
reflect that when trenches are shared with utilities, they tend to be larger and, thus,
more expensive.
3.1.2 Fibre services
The following chart presents the evolution of the 3rd draft model’s results for TDC’s fibre
services:
Exhibit 3.3: Results of the 3rd draft model – TDC’s fibre services [Source: DBA]
As can be extracted, there is an increase in the costs of the services compared to the
results obtained in the 2nd draft model. The differences observed between the models can
924
1.099
337
-
200
400
600
800
1.000
1.200
1.400
1.600
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Raw fibre (POI0)
4
1.2161.331
401
1.664
1.013
-
200
400
600
800
1.000
1.200
1.400
1.600
1.800
2.000
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Raw fibre (POI1)
1.284
1.580
409
2.156
1.435
-
500
1.000
1.500
2.000
2.500
2nd draft model(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Fibre BSA PON (POI2)
1.337
1.665
395
2.156
1.435
-
500
1.000
1.500
2.000
2.500
2nd draft model(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Fibre BSA PTP (POI2)
Model results NGA Risk premium (if kept at current level)
Price decision (2020) - DONG Price decision (2020) – Rest of the country
2020© Axon Partners Group 10
be explained by a series of changes implemented in the 3rd drat model, which are
illustrated below3:
Exhibit 3.4: Impact of the changes implemented in the model for fibre services [Source: DBA]
A high-level overview of the key changes presented in the image above is presented below:
Adjustments to R and Excel dimensioning: We have implemented a number of changes
to the R and Excel dimensioning based on the feedback received as part of the 2nd
consultation process. A log of the changes implemented in the Excel model is presented
in worksheet “CHANGELOG” of the 3rd draft Excel model, while for the R model, the log
of the changes is presented in Annex D of the R model manual.
Adjustment to the economic depreciation and demand: We have adjusted the
consideration of the trend of production factors and the treatment of OpEx outside of
3 The illustration presents the impact for the service “Raw fibre at POI1”
2020© Axon Partners Group 11
the modelling period, following the comments provided by the operators in the 2nd
consultation round:
• Production factors outside the modelling period (i.e. after 2038) are now scaled-
down following the same rate at which assets become fully depreciated.
• Assets generate OpEx costs outside the modelling period (i.e. after 2038), to
ensure that the economic depreciation has a comprehensive view of the entire
economic modelling period.
These considerations are explained in section regarding economic depreciation of the
2nd consultation report.
Furthermore, we have updated the demand for fibre services based on the new data
reported by TDC. The new demand has an impact on the patterns employed in the
economic depreciation to recover the costs of the network.
Allocation of non-network overheads: We have adjusted the allocation of the non-
network overheads to services to follow an EPMU approach, based on the feedback
received as part of the 2nd consultation. The inputs included for non-network overheads
have also been adjusted in the cost model, following the data reported by TDC.
Changes in the unit costs of the network elements: We have adjusted the unit costs
for some network elements based on the new data reported by TDC. Figures have been
updated in the model as reported by TDC, as long as i) sufficient evidences have been
provided and i) the figures were found reasonable compared to data reported by other
Danish operators.
Overlap with coax networks: We have adjusted the fibre rollout algorithm so that it
avoids covering i) homes that have fibre from alternative operators (feature existing
in the 2nd draft model) and ii) homes that have coax, from either TDC or other
alternative operators (new feature in the 3rd draft model). However, to ensure the
deployment remains efficient, the model considers that whenever a road section is dug
out for both, fibre and coax networks4, the same trench can be shared between fibre
and coax networks.
Installation costs: The model now considers that the NTP installation (including drilling)
are included in the recurrent fee of the fibre services. The inputs for the unit costs of
4 This adjustment is limited only to the part of the coax network that is deployed with fibre (i.e. between the
CMC and the CO).
2020© Axon Partners Group 12
this new network element have been extracted from the cost of the equivalent ancillary
service.
Sharing with utilities: We have adjusted the percentage of costs borne by TDC in the
trenches shared with utilities from 50% to 60%. This change has been performed to
reflect that when trenches are shared with utilities, they tend to be larger and, thus,
more expensive.
Regulated areas: The model now includes an option to extract the results measured
only in the regulated areas, according to the draft market analysis decision published
by DBA.
3.1.3 Coax services
The following chart presents the evolution of the 3rd draft model’s results for TDC’s coax
services:
Exhibit 3.5: Results of the 3rd draft model – TDC’s coax services [Source: DBA]
743
866
914
822
1.044
1.124
644
866
946
0
200
400
600
800
1.000
1.200
Coax BSA (access only) Coax BSA (POI2) Coax BSA (POI3)
DK
K /
lin
e /
mo
nth
2nd draft model 3rd draft model (national) 3rd draft model (regulated areas)
2020© Axon Partners Group 13
As can be extracted, there is an increase in the costs of the services compared to the
results obtained in the 2nd draft model. The differences observed between the models can
be explained by a series of changes implemented in the 3rd drat model, which are
illustrated below5:
Exhibit 3.6: Impact of the changes implemented in the model for coax services [Source: DBA]
A high-level overview of the key changes presented in the image above is presented below:
Adjustments to R and Excel dimensioning: We have implemented a number of changes
to the R and Excel dimensioning based on the feedback received as part of the 2nd
consultation process. A log of the changes implemented in the Excel model is presented
in worksheet “CHANGELOG” of the 3rd draft Excel model, while for the R model, the log
of the changes is presented in Annex D of the R model manual.
5 The illustration presents the impact for the service “Coax BSA at POI2 (excluding traffic costs)”
2020© Axon Partners Group 14
Adjustment to the economic depreciation: We have adjusted the consideration of the
trend of production factors and the treatment of OpEx outside of the modelling period,
following the comments provided by the operators in the 2nd consultation round:
• Production factors outside the modelling period (i.e. after 2038) are now scaled-
down following the same rate at which assets become fully depreciated.
• Assets generate OpEx costs outside the modelling period (i.e. after 2038), to
ensure that the economic depreciation has a comprehensive view of the entire
economic modelling period.
These considerations are explained in section regarding economic depreciation
included in the 2nd consultation report.
Allocation of non-network overheads: We have adjusted the allocation of the non-
network overheads to services to follow an EPMU approach, based on the feedback
received as part of the 2nd consultation. The inputs included for non-network overheads
have also been adjusted in the cost model, following the data reported by TDC.
Changes in the unit costs of the network elements: We have adjusted the unit costs
for some network elements based on the new data reported by TDC. Figures have been
updated in the model as reported by TDC, as long as i) sufficient evidences have been
provided and i) the figures were found reasonable compared to data reported by other
Danish operators.
Sharing with utilities: We have adjusted the percentage of costs borne by TDC in the
trenches shared with utilities from 50% to 60%. This change has been performed to
reflect that when trenches are shared with utilities, they tend to be larger and, thus,
more expensive.
Allocation of ducts and cables: We have adjusted the allocation of some coax assets
(namely, ducts and coax cables) so that they are allocated to access services instead
of to broadband and TV services.
3.2. Norlys’ model
The subsections below outline the key results obtained in Norlys’ 3rd draft model.
3.2.1 Norlys’ fibre services
The following chart presents the evolution of the 3rd draft model’s results for Norlys’ fibre
services:
2020© Axon Partners Group 15
Exhibit 3.7: Results of the 3rd draft model – Norlys’ fibre services [Source: DBA]
As can be extracted, there is an increase in the costs of the services compared to the
results obtained in the 2nd draft model. The differences observed between the models can
be explained by a series of changes implemented in the 3rd drat model, which are
illustrated below6:
6 The illustration presents the impact for the service “Raw fibre at POI1”
Model results
1.380 1.407
410
-
200
400
600
800
1.000
1.200
1.400
1.600
1.800
2.000
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Raw fibre (POI0)
8
2.0451.896
523
-
500
1.000
1.500
2.000
2.500
3.000
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Raw fibre (POI1)
2.172 2.137
508
-
500
1.000
1.500
2.000
2.500
3.000
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Fibre BSA PON (POI2)
2.437 2.405
528
-
500
1.000
1.500
2.000
2.500
3.000
3.500
2nd draft model
(inc. risk premium)
3rd draft model
DK
K/
lin
e/
year
Fibre BSA PTP (POI2)
NGA Risk premium (if kept at current levels)
2020© Axon Partners Group 16
Exhibit 3.8: Impact of the changes implemented in Norlys’ model for fibre services [Source: DBA]
A high-level overview of the key changes presented in the image above is presented below:
Adjustments to R and Excel dimensioning, including coverage: We have implemented
a number of changes to the R and Excel dimensioning based on the feedback received
as part of the 2nd consultation process. A log of the changes implemented in the Excel
model is presented in worksheet “CHANGELOG” of the 3rd draft Excel model, while for
the R model, the log of the changes is presented in Annex D of the R model manual.
Adjustment to the economic depreciation and demand: We have adjusted the
consideration of the trend of production factors and the treatment of OpEx outside of
the modelling period, following the comments provided by the operators in the 2nd
consultation round:
• Production factors outside the modelling period (i.e. after 2038) are now scaled-
down following the same rate at which assets become fully depreciated.
2020© Axon Partners Group 17
• Assets generate OpEx costs outside the modelling period (i.e. after 2038), to
ensure that the economic depreciation has a comprehensive view of the entire
economic modelling period.
These considerations are explained in section regarding economic depreciation
included in the 2nd consultation report.
Furthermore, we have updated the demand for fibre services, based on the updated
coverage figures utilized in the 3rd draft model, which has an impact on the patterns
employed in the economic depreciation to recover the costs of the network.
Allocation of non-network overheads: We have adjusted the allocation of the non-
network overheads to services to follow an EPMU approach, based on the feedback
received as part of the 2nd consultation. The inputs included for non-network overheads
have also been adjusted in the cost model
Changes in the unit costs of the network elements: After careful analysis of the unit
cost data reported by Norlys as part of the different data request processes, we have
performed minor adjustments to the unit costs of some network elements in the model.
Installation costs: The model now considers that the NTP installation (including drilling)
are included in the recurrent fee of the fibre services. The inputs for the unit costs of
this new network element have been extracted from the cost of the equivalent ancillary
service.
Sharing with utilities: We have adjusted the percentage of costs borne by Norlys in the
trenches shared with utilities from 50% to 60%. This change has been performed to
reflect that when trenches are shared with utilities, they tend to be larger and, thus,
more expensive. Furthermore, in the case of Norlys, we have adjusted the percentage
of trenches shared with utilities to 20%. This aspect is presented in the section related
to the sharing with utilities included in the 2nd consultation report.
Allocation of MSAN costs: Following the comments provided by the industry in the
consultation process, we have adjusted the allocation of the costs of the fibre MSAN
so that they are not allocated to raw fibre services.
Consideration of isolated homes: After a thorough review of the results of the topology
of Norlys’ network we identified that a relevant number of homes are located in very
isolated areas, especially in rural areas. Giving coverage to these isolated homes
involves that relevant deployments must be made by the operator for only a few
houses. Thus, in the 3rd draft model we have estimated that whenever these specific
2020© Axon Partners Group 18
deployments take place, the modelled operator would always aim to share the
deployment (digging costs) with the incumbent utility operator in the region.
Regulated areas: The model now includes an option to extract the results measured
only in the regulated areas, according to the draft market analysis decision published
by DBA.
3.2.2 Norlys’ coax services
One of the key changes for Norlys’ 3rd draft model is the modelling of coax networks. The
following chart presents the results obtained in the model for Norlys’ coax services:
Exhibit 3.9: Results of the 3rd draft model – Norlys’ coax services [Source: DBA]
1.025
1.377
1.559
1.159
1.511
1.693
-
200
400
600
800
1.000
1.200
1.400
1.600
1.800
Coax BSA (only access) Coax BSA (POI2) Coax BSA (POI3)
DK
K/
lin
e/
year
3rd draft model - National 3rd draft model - Regulated areas 10
2020© Axon Partners Group 19
4. Questions for the 3rd consultation round
This section provides a summary of the questions DBA expects stakeholders to answer.
They have been particularly tailored to each stakeholder, as the DBA acknowledges the
information available to them differs (i.e. some stakeholders have access to confidential
versions of the model and the others do not).
In the case that the stakeholder does not agree with the inputs, calculations or results
related to the questions presented, it shall justify its position providing supporting
information and references.
Modelled operators (TDC and Norlys)
Question 1: Do you agree with the demand considered in the Excel model?
Question 2: Do you agree with the coverage levels considered in the Excel model?
Question 3: Do you agree with the broadband traffic inputs considered to characterize
traffic requirements (i.e. broadband, multicast, etc.) in the Excel model?
Question 4: Do you agree with the results of the R model for the access networks and
their representativeness of your network KPIs?
Question 5: Do you agree with the fibre rollout algorithm implemented to determine the
coverage levels of the modelled operator?
Question 6: Do you agree with the results of the R model for the transmission networks
and their representativeness of your network KPIs?
Question 7: Do you agree with the unit costs and useful lives introduced in the worksheet
‘1F INP UNITARY COSTS’ of the Excel Model?
Question 8: Do you agree with the inputs and methodology followed for the treatment of
non-network overheads in the Excel model?
Question 9: Do you agree with the inputs considered for the sharing with utility networks
in the Excel model?
Question 10: Do you agree with the remaining inputs of the Excel model?
2020© Axon Partners Group 20
Question 11: Do you agree with the access and transmission network dimensioning
algorithms implemented in the Excel model?
Question 12: Do you agree that the number of network elements dimensioned by the
Excel model?
Question 13: Do you agree that the total cost base calculated by the Excel model?
Question 14: Do you agree with the routing factors matrix defined in the Excel model?
Question 15: Do you agree with the results of the wholesale access services produced by
the Excel model?
Question 16: Do you agree with the results of the wholesale bitstream services produced
by the Excel model?
Question 17: Do you agree with the results obtained for the ancillary services?
Other operators
Question 18: Do you agree, at a high level, with the inputs included in the Excel model?
Question 19: Do you agree with the methodology followed for the treatment of non-
network overheads in the Excel model?
Question 20: Do you agree with the access and transmission network dimensioning
algorithms implemented in the Excel model?
Question 21: Do you agree with the dimensioning algorithms/scripts implemented in the
R model?
Question 22: Do you agree with the routing factors matrix defined in the Excel model?
Question 23: Do you agree with the results of the wholesale access services produced by
the Excel model?
Question 24: Do you agree with the results of the wholesale bitstream services produced
by the Excel model?
Question 25: Do you agree with the results obtained for the ancillary services?
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