ࡱ> U@ 5bjbj &R F JJJ4hj$H>"ϳϳϳϳϳϳ$Iܳ"ܳG6&4<2 @E9d;BGTH94BLNM<<bMW=r3;$uGuG.7dKI7  Telstras Undertaking for Domestic PSTN Originating and Terminating Access, Unconditioned Local Loop Service and Local Carriage Service Discussion Paper March 2003 Preface Telstra Corporation Limited (Telstra) lodged access undertakings (the undertakings) with the Australian Competition and Consumer Commission (the Commission) on 9 January 2003. The undertakings specify certain terms and conditions upon which Telstra undertakes to meet its standard access obligations to supply domestic PSTN originating and terminating access service (the domestic PSTN O/T service), unconditioned local loop service (the ULLS) and local carriage service (the LCS). Under Part XIC of the Trade Practices Act 1974 (the Act), the Commission must accept or reject the undertakings. The process the Commission will follow to assess the undertakings will be open and public, allowing parties to express their views and provide relevant information to the Commission. In this regard, the Commission seeks submissions on the undertaking by no later than 4 weeks from the date upon which Telstra makes certain relevant information reasonably available for industry assessment, being information that is contained in Telstras confidential submission in support of its undertakings. This would include information on the PIE II model being used by Telstra to determine the costs of providing core services. The Commission understands that Telstra is currently negotiating reasonable terms upon which to make this confidential information available. The Commission will notify on its web site when this confidential information has been made reasonably available by Telstra, and of the resulting closing date for submissions. The Commission will consider these submissions in deciding whether to accept or reject the undertakings. Parties wishing to obtain confidential information referred to in this paper should contact Bill Gallagher of Telstra on (02) 9298 5597. The Commission published Telstras 9 January 2003 supporting statement to the undertakings on 17 January 2003 and is now formally publishing the undertakings themselves together with this issues paper for the information of interested parties. Other material on Telstras PIE II model and related documentation, including Telstras submission in support of the methodology used for deriving prices proposed in its undertaking, dated 13 February 2003 (and the public version of that submission dated 21 February 2004), is also being made available. Copies of all relevant papers, with the exception of confidential data, are available on the Commissions web site  HYPERLINK "http://www.accc.gov.au" www.accc.gov.au. Please forward written submissions to: Chris Pattas Senior Director Australian Competition and Consumer Commission GPO Box 520J MELBOURNE VIC 3000 Ph: (03) 9290 1858 Fax: (03) 9663 3699 e-mail: chris.pattas@accc.gov.au Any queries on this issues paper should be directed to Igor Popovic (e-mail:  HYPERLINK "mailto:igor.popovic@accc.gov.au" igor.popovic@accc.gov.au, tel: 03 9290 1920 in the first instance. Introduction Part XIC of the Act establishes a regime for governing access to certain services in the telecommunications industry. Under Part XIC, providers of an active declared service (access providers) have an obligation to supply that service. Telstra lodged access undertakings specifying the price-related terms and conditions, and limited non-price terms, upon which it undertakes to meet its standard access obligations to supply domestic PSTN originating and terminating access service (the domestic PSTN O/T service), unconditioned local loop service (the ULLS) and local carriage service (the LCS) (referred to collectively as the services the subject of the undertakings or the undertaking Services). The Commission declared the domestic PSTN O/T service in July 1997. The declared domestic PSTN O/T services are, in general, provided by means of a fixed-line network. They are used as inputs by service providers primarily to supply long-distance, fixed-to-mobile and mobile-to-fixed calls to end-users in Australia. They can also be used by other network operators to interconnect with Telstras fixed network. Telstra has previously lodged two separate undertakings to the Commission in respect of the domestic PSTN O/T service, in 1997 and 1999 respectively. Both undertakings were rejected by the Commission on the basis that it was not satisfied that the price or non-price terms and conditions were reasonable. A number of access disputes were also notified to the Commission in respect of this service between 1998 and 2000, and in particular, the Commission made three final arbitration determinations in 2000. Two of these determinations were subsequently appealed by Telstra to the Australian Competition Tribunal but the proceedings were withdrawn in 2002 following a commercial agreement being reached by the parties to the relevant access disputes. The ULLS involves the use of unconditioned cable, primarily copper pairs, between end-users and a telephone exchange, where the unconditioned cable terminates. The Commission declared the ULLS in August 1999. Following declaration of the ULLS, four access disputes have been notified to the Commission in relation to the supply of the service by Telstra. All these notifications were eventually withdrawn by November 2001, after the Commission had made draft final determinations in relation to the three remaining disputes, but prior to the Commission issuing any final determinations. In March 2002, the Commission released its Final Report on the pricing of ULLS. This report incorporated the work developed through the finalisation of the ULLS arbitrations and the Commissions pricing consideration. The Commissions decision to finalise and release its earlier ULLS draft pricing discussion paper was intended to provide similar information to the market place about ULLS pricing as would have been accomplished by the publication of its final ULLS arbitration determinations. The LCS is a service for local call resale. That is, for the carriage of telephone calls from customer equipment at an end-users premises to separately located customer equipment of an end-user in the same standard zone. After holding a public inquiry, the Commission declared the LCS in August 1999. Following the declaration of the service, nine access disputes were notified to the Commission in relation to Telstras supply of the LCS. All of these disputes were resolved by commercial negotiation, and there have been no further arbitration disputes in relation to the LCS. The Commission released a revised final report on LCS pricing in April 2002, which discussed the Commissions pricing methodology and included indicative prices determined in accordance with it. As in the case of the ULLS, the purpose of this report was to inform industry, government and other interested parties on the principles and indicative prices that are likely to guide the Commission when arbitrating an access dispute or assessing an undertaking in relation to pricing for the LCS. Telstra 2003 undertakings Telstra lodged a set of access undertakings with the Commission on 9 January 2003 specifying the price-related terms and conditions upon which Telstra undertakes to meet its standard access obligations to supply the PSTN O/T access service, the ULLS and the LCS. Specifically the undertakings include: Service descriptions; Price lists specifying Telstras proposed charges for the undertaking Services; and Limited non-price terms and conditions on which the undertaking Services are to be supplied. The undertakings cover the 2002/03 to 2004/05 financial year periods and propose the following headline rates: 1.7 cents per minute for PSTN O/T access; 14.5 cents per call for LCS; and $20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4 for the ULLS. The Commission must consider each of the undertakings that Telstra lodged on 9 January 2003 and decide to accept or reject them. The purpose of this discussion paper is to: inform parties of the matters the Commission must take into consideration in making the decision to accept or reject an undertaking; specify a number of issues the Commission would particularly like addressed in submissions; and outline the process the Commission will follow in assessing the undertakings. The role of undertakings and Legislative criteria for the assessment of undertakings Under Part XIC of the Act, the Commission may declare carriage services and related services to be declared services. Carriers and carriage service providers who provide declared services are required to comply with standard access obligations (SAOs) in relation to those services. The SAOs facilitate the supply of declared services by access providers to access seekers, in order that access seekers can provide carriage services and/or content services. Section 152AY(2) of the Act (detailed below) specifies the way the terms and conditions upon which the access provider must comply with the SAOs are determined: The carrier or carriage service provider must comply with the obligations: (a) on such terms and conditions as are agreed between the following parties: (i) the carrier or carriage service provider, as the case requires; (ii) the access seeker; or (b) failing agreement: (i) if an access undertaking given by the carrier or carriage service provider is in operation and specifies terms and conditions about a particular matter on such terms and conditions relating to that matter as are set out in the undertaking; or (ii) if an access undertaking given by the carrier or carriage service provider is in operation, but the undertaking does not specify terms and conditions about a particular matter on such terms and conditions relating to that matter as are determined by the Commission under Division 8 (which deals with arbitration of disputes about access); or (iii) if there is no such undertaking on such terms and conditions as are determined by the Commission under Division 8 (which deals with arbitration of disputes about access). Legislative criteria Section 152BV of the Act sets out the obligations of the Commission in assessing an undertaking. (1) This section applies if: (a) an ordinary access undertaking is given to the Commission by a carrier or a carriage service provider; and (b) the undertaking does not adopt a set of model terms and conditions set out in an approved telecommunications access code. (2) The Commission must not accept the undertaking unless: (a) the Commission has: (i) published the undertaking and invited people to make submissions to the Commission on the undertaking; and (ii) considered any submissions that were received within the time limit specified by the Commission when it published the undertaking; and (b) the Commission is satisfied that the undertaking is consistent with the standard access obligations that are applicable to the carrier or provider; and (c) if the undertaking deals with a price or a method of ascertaining a price the Commission is satisfied that the undertaking is consistent with any Ministerial pricing determination; and (d) the Commission is satisfied that the terms and conditions specified in the undertaking are reasonable; and (e) the expiry time of the undertaking occurs within 3 years after the date on which the undertaking comes into operation. Published the undertaking and invited people to make submissions The Commission published Telstras 9 January 2003 supporting statement to the undertakings on the Commissions web site on 17 January 2003 and the undertakings themselves as part of the release of this issues paper and is now inviting parties to make submissions on the undertakings. A copy of the undertaking is available on the Commissions web site  HYPERLINK "http://www.accc.gov.au" www.accc.gov.au. The Commission invites submissions on any aspect of the undertaking. Considered any submissions that were received within the time limit specified by the Commission when it published the undertaking The time limit specified by the Commission for the receipt of submissions on the undertaking is 4 weeks from the date upon which Telstra makes certain relevant information reasonably available for industry assessment, being: (a) information that the Commission has previously requested Telstra to supply but which has not been provided to date; and (b) information that is contained in Telstras confidential submission in support of its undertakings dated 13 February 2003. The Commission has set the consultation period on this basis to better ensure that interested parties will be in a position to assess the undertakings and make submissions on them. The Commission will publish a notice on its web site confirming when Telstra has made this further information reasonably available for the purposes of determining when this time limit expires. Parties are required to provide any submissions that they intend to make to the Commission by no later than that date. As discussed later, parties are encouraged to provide their submissions at the earliest possible opportunity. Consistency with standard access obligations The SAOs are set out in s.152AR of the Act. Subject to class or individual exemptions made by the Commission, a carrier or carriage service provider must comply with the SAOs in regard to declared services it supplies either to itself or to other persons. In particular, s.152AR requires access providers to, among other things: supply an active declared service if requested to do so by a service provider (subject to certain limitations) and to take all reasonable steps to ensure that the technical and operational quality of the active declared service supplied to the service provider is equivalent to that which the access provider provides to itself; permit the interconnection of the facilities an access provider either owns, controls or is responsible for, with the facilities of a service provider for the purpose of enabling the service provider to be supplied with active declared services; take all reasonable steps to ensure that the technical and operational quality and timing of the interconnection is equivalent to that which the access provider provides to itself and is compliant with any technical standards in force under section 384 of the Telecommunications Act 1997; and provide billing information (if requested by the service provider) at certain intervals and in a certain manner and form. The Commission will assess whether the undertakings, including the service descriptions, are consistent with the SAOs. Consistency with Ministerial pricing determination Division 6 of Part XIC provides that the Minister can make a written determination setting out principles dealing with price or a method of ascertaining price relating to the SAOs. Section 152CI(1) of the Act provides that if a provision of an access undertaking is inconsistent with any Ministerial pricing determination, the provision will have no effect to the extent of the inconsistency. The Minister has not made a pricing determination under Part XIC to date. Terms and conditions are reasonable An important part of the access regime is the terms and conditions of access (including the price or a method for ascertaining the price). Under Part XIC of the Act, the Commission cannot accept an undertaking unless it is satisfied that the terms and conditions specified are reasonable. In determining whether terms and conditions are reasonable, regard must be had to the following matters: whether the terms and conditions promote the long term interests of end-users (the LTIE); the legitimate business interests of the carrier or carriage service provider concerned, and the carriers or carriage service providers investment in facilities used to supply the declared service concerned; the interests of persons who have rights to use the declared service concerned; the direct costs of providing access to the declared service concerned; the operational and technical requirements necessary for the safe and reliable operation of a carriage service, a telecommunications network or a facility; and the economically efficient operation of a carriage service, a telecommunications network or a facility. This does not, by implication, limit the matters to which regard may be had. In considering whether the terms of an access undertaking promote the LTIE, the Commission must consider the achievement of the following objectives: promoting competition in markets for telecommunications services; achieving any-to-any connectivity in relation to carriage services that involve communication between end-users; and, encouraging the economically efficient use of, and the economically efficient investment in, the infrastructure by which telecommunications services are supplied. Expiry Date and Term From the terms of the undertakings, the expiry date of each undertaking cannot be more than one year from the date upon which it comes into operation. Collectively, the undertakings cover the period from no earlier than 1 July 2002 until no later than 30 June 2005. However, the undertakings are of no effect in respect of the period that precedes any acceptance by the Commission, and may be withdrawn by Telstra before their expiry date. As such, it is improbable that the undertakings that have been provided in respect of the 2002-03 financial year will have any operation. Commissions Process for Assessing the Undertaking The process the Commission will follow to assess the undertakings will be as open and public as practicable allowing parties to express their views on the undertakings, provide relevant information to assist the Commission and allow comment on preliminary views formed by the Commission and its analysis of the undertakings. The Commission intends to adopt the following process in assessing Telstras undertakings. Stage 1: Publish the undertaking and seek submissions As stated above, the Commission has published the undertakings and is making them available to all parties. This discussion paper aims to inform parties of the matters the Commission must take into consideration in assessing the undertaking and the issues which the Commission would particularly like addressed in submissions. This discussion paper is available on the Commissions web site  HYPERLINK "http://www.accc.gov.au" www.accc.gov.au. As discussed previously, the closing date for submissions in stage 1 will depend upon when Telstra is able to make further information reasonably available to interested parties. The Commission will publish a notice on its web site advising when this has occurred and the resulting closing date for submissions. In particular, the time limit specified by the Commission for the receipt of submissions on the undertaking is 4 weeks from the date upon which Telstra makes certain relevant information reasonably available for industry assessment, being: (a) information that the Commission has previously requested Telstra to supply but which has not been provided to date; and (b) information that is contained in Telstras confidential submission in support of its undertakings dated 13 February 2003. The Commission has set the consultation period on this basis to better ensure that interested parties will be in a position to assess the undertakings and make submissions on them. While the Commission will, as required, have regard for all submissions that are made to it on or before the closing date for submissions, the Commission strongly encourages all interested parties to make their submissions as soon as they are in a position to do so. In particular, the Commission requests that should a party intend to make a submission on any matter not addressed in this issues paper, it notify the Commission of its intentions as soon as possible. The Commission also encourages parties to make their submissions in a way that facilitates the efficient assessment of its various contentions, including the verification of any facts or data upon which those contentions are based. In this regard, parties are encouraged to restrict confidentiality claims to a minimum and to establish appropriate confidentiality regimes for the disclosure of any information that is claimed to be confidential to interested parties or to others to allow their critical assessment. Accordingly, the Commission would recommend that should it be the case that a party intends to provide confidential material in support of a submission, that it now put in place pro forma documentation to facilitate the prompt disclosure of that information to appropriate third parties. Should the Commission not be in a position to efficiently assess a partys contentions, including by receiving the results of independent critical assessments of them, it will be necessarily constrained in the weight to which it will be able to attach to those contentions. This will particularly be the case where conflicting material is before the Commission that has been critically assessed. Stage 2: Publish draft assessment and seek further submissions Following its analysis of the undertakings and the submissions of interested parties, the Commission intends to publish the findings of its initial analysis and its draft decision within a reasonable period after submissions close. The Commission will invite further submissions on its draft decision for a specified period, which will likely be considerably shorter than this initial period. The Commission would expect that these submissions would be responsive to the draft decision, and would not expect a party to raise any further issues that were not addressed in the submissions that the party made during Stage 1 as discussed above. Parties are advised that, due to the statutory imposed timetable within which the Commission must make its decision, the period within which these responsive submissions will be able to be made will be comparatively brief. Stage 3: Publish final assessment Taking into account the submissions, the Commission will form a view on whether to accept or reject the undertakings and publish the reasons for its decision. The Commission will have a clearer idea of this timeframe once the period of this initial consultation has been determined. Time limit for final assessment The Telecommunications Competition Act 2002 has introduced a time limit for the Commissions assessment of undertakings. While the Commission would intend to make its decision as soon as is practicable for it to do so, the Commission must in any event make a decision within 6 months. If it does not do so, it is deemed to have accepted the undertaking. However, the Commission is able to extend its decision-making period for up to 3 months at a time provided it gives a reason for doing so. In addition if the Commission requests further information in relation to the undertaking, the time taken for the Commission to receive the information is excluded from the 6 month period. Similarly, the consultation period specified by the Commission is excluded from this timeframe. Model terms and conditions of core services It should be noted that, concurrent to the process of assessment of the undertakings specified above, the Commission will continue to develop its model terms and conditions, including prices for these core services pursuant to Section 152AQB of the Act. As both processes address the issue of access pricing for the same set of core services, it is expected that there will be considerable overlap in the range of issues examined. Accordingly, the Commission would intend to rely on information that it receives in the course of its development of model terms and conditions or in its assessment of the undertakings in either project the extent that the information is relevant to that other project. Confidentiality The Commission is aware of the need to protect certain Telstra information. Therefore the Commission is not opposed to parties who wish to have access to such confidential information signing confidentiality undertakings. However, the Commission believes that these confidentiality undertakings should enable the relevant party to view all information supplied by Telstra to the Commission in these proceedings. Should Telstra choose not supply any confidential information to parties who wish to have access to it, the Commission's policy is that such information will generally not carry the same weight as information that is available for scrutiny by all sides of an issue or debate. Submission(s) in support of the undertakings In assessing whether the undertakings terms and conditions are reasonable, the Commission will consider whether the prices are based on the efficient forward-looking costs of the respective undertaking services. The Commissions Access Pricing Principles discuss the relationship between the reasonableness criteria set out in section 152AH of the Act and efficient forward-looking costs. In support of its submission, Telstra has developed a revised economic model, known as PIE II. Based on the model, Telstra argues that the efficient network costs of the undertaking Services are: ServiceEFFICIENT NETWORK COSTS2002/032003/042004/05PSTN O/T access3.02 per call end minute2.37 per call end minute2.02 per call end minuteLCS17.51 per call 17.51 per call 17.51 per call ULLS - for RSS connected services$44.71 per service per month$43.73 per service per month$43.72 per service per monthIn addition to the above stated costs, Telstra claims that long run efficient costs include non-network costs incurred by a supplier of the undertaking Services (such as wholesale billing, marketing and administration costs), and that these must be added to the costs set out in the above Table. Non-network or indirect (higher-level organisational) costs have been previously accounted for by both the Commission and Telstra in their costing of these services through the use of mark-ups on network costs. However, it appears that Telstra now contends that efficient costs include other non-network costs in addition to those previously considered by the Commission. Telstra has not as yet supplied the detailed items under this cost nor its quantum, nor its justification for claiming additional indirect costs. The Commission is interested in the industry views on the costs claimed above. The Commission also seeks any industry views on the quantum of any non-network costs claimed by Telstra. Claimed costs and charges Telstra notes that its claimed costs are higher than the prices currently prevailing for the undertaking Services. It believes that an immediate shift to prices based on those claimed costs would have short term adverse impact on access seekers, but delaying the shift would have a long term impact on Telstra and would promote inefficiency. Therefore Telstra proposes a different set of prices, which are nearly half the claimed costs in the first period (for PSTN O/T services). Telstra contends that its proposed prices are within the upper end of the range of prices that are prevailing in the market, and believes its proposed prices provide a transition to efficient cost based prices over the long term thus striking a balance between short term commercial impacts on access seekers and longer term imperative of efficiency. The proposed prices (excluding GST) are: ServiceUNDERTAKING PRICES2002/032003/042004/05PSTN O/T accesson average 1.7 per call end minuteon average 1.7 per call end minuteon average 1.7 per call end minuteLCS14.5 per call 14.5 per call 14.5 per call ULLS - for a RSS connected service$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4.$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4.$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4. Whilst Telstra noted its reasons for proposing these prices in contrast to its claimed costs, the Commission is also interested in the methodology it used in arriving at these prices from the claimed costs. The Commission is also interested in industry views on the reasonableness of proposed prices, the price paths over the three periods, as well as the nature of the closure of the gap between the prices and claimed network cost. The Commission seeks the views of industry parties on how the proposed prices compare to those currently agreed prices. In particular, the Commission is interested in parties views on whether the proposed prices fall within the upper end of the range of prices currently prevailing in the market? PSTN issues Disaggregated PSTN rates The proposed price of the PSTN O/T access is 1.7 per call end minute. The disaggregated prices in the undertakings are: 2002/03 CCA CategoryIntra CCA flagfall Charge (Cents per successful Call)Intra CCA conveyance Charge (Cents per conversation Minute)CBD1.87060.7459Metro1.84930.8630Provincial1.97041.0987Rural3.33294.67102003/04 CCA CategoryIntra CCA flagfall Charge (Cents per successful Call)Intra CCA conveyance Charge (Cents per conversation Minute)CBD1.96990.7458Metro1.95360.8615Provincial2.06231.0603Rural3.29834.12442004/05 CCA CategoryIntra CCA flagfall Charge (Cents per successful Call)Intra CCA conveyance Charge (Cents per conversation Minute)CBD2.03900.7604Metro2.02110.8749Provincial2.13001.0741Rural3.36544.1359 The Commission invites comments on the level and the trend of PSTN rates over the three periods and on the proposed structure between flagfall and conveyance charges. Further, the Commission notes that there is a general upward trend in the disaggregated PSTN prices (i.e. all flagfall and per minute rates increase between 2003/04 and 2004/05) while the headline price remains at 1.7 per minute. This may be because the average call length is assumed to increase over those periods. The Commission invites comment on this implied assumption. Customer Access Network (CAN) contribution Telstra has noted that after the removal of the contribution to PSTN CAN costs to account for any access or other (unfunded) deficit, the PSTN O/T access price is 0.7971 per call end minute. Further information from Telstra indicates that the costs of call conveyance are at a similar level. This implies that the remainder of the PSTN cost is due to what Telstra calls the unrecovered PSTN CAN cost (UPCC). The unrecovered PSTN CAN cost contribution is made up of the access deficit contribution (ADC), as previously defined by the Commission, plus a local call surcharge. The local call surcharge refers to the component of the UPCC that aims to recover the part of the access deficit (AD) attributed to local calls, that Telstra claims it cannot recover due to restrictions on the price of local calls. The Commission notes that the call conveyance cost claimed by Telstra appears close to the call conveyance cost derived by the Commission through adjustments made to the previous periods n/e/r/a model estimates. The main difference between Telstras current estimates of efficient costs and the estimates that would be derived from an application of the Commissions previous position appears to be the level of contribution to PSTN CAN costs, in particular the inclusion of a local call surcharge in Telstras claimed costs. Also, the main difference between Telstras current pricing proposal and the Commissions previous position appears to be the size of the ADC. These matters will need to be examined more closely during the assessment process. The Commission invites comments on levels of Telstras claimed conveyance costs, access deficit contribution, and local call contribution. Parties are reminded that many of these issues are also raised in the Commission ADC paper, The Need for an ADC for PSTN Access Service Pricing, Discussion paper, February 2003. To the extent parties have already made submissions to this paper, they can cross-reference their further submissions appropriately. ADC related issues In its supporting submissions for the undertaking, Telstra contends that the costs that need to be recovered from the PSTN and undertaking Services include PSTN CAN costs, which should be allocated between PSTN access services and other services which use the CAN. Telstra contends that the scale of any unrecovered PSTN CAN costs (UPCC) should be calculated using the following formula: PSTN CAN costs Plus retail costs attributable to PSTN CAN services Less maximum subscription revenue which could be earned by Telstra Less USO revenue attributable to the PSTN received by Telstra Telstras methodology for calculating retail PSTN CAN costs, maximum subscription revenue and USO revenue is detailed in sections F14, F15 and F16 and Annexure K and L of Telstras submission. Telstra states that any UPCC should then be allocated to all PSTN services on an equal basis except those that are unable to recover the full extent of these costs due to regulatory constraints. In this regard, Telstra submits that due to price caps on local calls, local calls and the LCS can only recover up to $17.51c per call refer to section F17. Thus, Telstra allocates the UPCC to those calls up to this cap and then allocates the remaining UPCC equally across the other PSTN services. Telstra states that the UPCC is allocated to PSTN and undertaking Services call ends and call minutes on a 100:0 basis when calculating PSTN cost, and on a 50:50 basis when calculating the PSTN undertaking price. The Commission previous position on the issue of the AD and ADC is discussed in its recent paper: The Need for an ADC for PSTN Access Service Pricing, Discussion paper, February 2003. As a part of the undertaking process, the Commission is interested in industry views on both Telstras claimed methodology of calculating the PSTN CAN costs not recovered through Retail PSTN charges or Universal Service Obligation (USO) revenue, and on the issues raised in the Commissions ADC paper*. In particular, the Commission invites industry comment on: calculation of retail PSTN CAN revenue (i.e. maximum possible subscription revenue versus actual subscription revenue) calculation of applicable USO revenue recovery of efficient PSTN CAN costs, not recoverable out of revenues from local calls and LCS, through the PSTN O/T charge level of unrecovered PSTN CAN costs and their allocation between calls and call end minutes * to the extent that parties have addressed these matters in response to the ԭs ADC paper they can make reference to that in their submissions. ULLS issues ULLS efficient network costs and prices PeriodTelstras proposed efficient network costs for ULLS for RSS connected servicesTelstras proposed undertaking prices for ULLS for RSS connected services2002/03$44.71 per service per month$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4.2003/04$43.73 per service per month$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4.2004/05$43.72 per service per month$20.00 per service per month in Band 1 and $40.00 per service per month in Bands 2, 3 and 4.Telstras proposed efficient ULLS costs consist of a network cost component as well as a contribution to ULLS specific costs. These two components are detailed in the below table. Periodnetwork costs for ULLS for RSS connected services (geographic average)ULLS specific costs for ULLS for RSS connected services (per month charge)proposed efficient costs for ULLS for RSS connected services (geographic average)2002/03$26.04$18.67$44.71 per service per month2003/04$25.06$18.67$43.73 per service per month2004/05$25.05$18.67$43.72 per service per monthThe network cost component of the proposed efficient ULLS costs are calculated by using the PIE II model under a TSLRIC methodology which is outlined in section (G) of the document Telstras Submission in Relation to the Methodology used for Deriving Prices Proposed in its Undertakings dated 9 January 2003 (the submission or Telstras submission). In addition, Telstras proposed efficient ULLS network costs are presented on a geographically de-averaged basis in Section H of the submission. The Commission has previously used a modified version of the TSLRIC (n/e/r/a) model that was used to assess Telstras second undertaking for PSTN O/T access services for calculating the efficient network costs of supplying the ULLS. ULLS specific costs Telstras methodology for calculating ULLS specific costs is outlined in Annexure M of its submission. This approach yields a ULLS specific cost of $18.67 per SIO per month for each of the three periods of the Undertaking. In the Commissions previous pricing considerations for, ULLS specific costs have comprised the following cost categories: IT system development and operational costs; ULLS connection group costs; wholesale management costs; and indirect costs. A key variable in the derivation of an appropriate charge for the recovery of ULLS specific costs on a per SIO basis is the determination of demand for the ULLS. Previously, the Commission has used ADSL demand as the key driver for estimating ULLS demand. However, the Commission notes that ADSL can currently be provided via the means of line sharing technology as well as the Flexstream wholesale product. Telstras ULLS demand estimates for the periods of the Undertaking are outlined in Annexure N. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology for calculating the efficient network costs of providing the ULLS and the proposed ULLS undertaking prices. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology for calculating ULLS specific costs. What method should be utilised for forecasting ULLS demand? The Commission is interested in the views of industry on their demand estimates with respect to the ULLS. How should ULLS specific costs be recovered (as fixed charge or on a per month basis)? The Commission also seeks comment on the Telstra contention that the proposed ULLS prices are at the upper end of currently negotiated rates. Averaging of ULLS prices in Band 2, 3 and 4 Telstra notes that the retail price of basic access is uniform across all geographic regions while the cost of the infrastructure used to provide basic access, the PSTN CAN, varies significantly across regions. Telstra contends that this means ULLS access seekers have an incentive to acquire ULLS in low cost areas, such as CBD areas, while having little incentive to acquire ULLS in high costs geographic areas i.e., rural. Telstra argues that this factor inhibits its ability to recover costs of its investment in the PSTN, leading to increased levels of unrecovered PSTN CAN costs. This appears to be the underlying rationale for Telstras contention that the price of ULLS should be averaged across what was previously defined as Band 2, 3 and 4 geographic areas. Telstra states that this is likely to lead to more competitive prices for services in rural areas. However, Telstra argues that the averaging of the ULLS costs should not apply to Band 1 areas as this will provide an incentive for potentially inefficient by-pass by access seekers in low cost areas through investment in infrastructure. The Commission has previously determined that access prices for the ULLS should be set on a geographically de-averaged basis. The Commission believed this approach was appropriate for the ULLS as: it is consistent with the Commissions standard approach to determining access pricing principles; it would lead to greater investment efficiency; it would generate less cream skimming; and there may be other technologies that are more suitable in rural and remote areas - access prices set on a geographically averaged basis may deter efficient investment in these alternative technologies in these areas. With respect to Telstras claims that de averaging of ULLS prices across geographic regions constrains its ability to recover its contended unrecovered PSTN CAN costs, it should be noted that the Commission in it previous considerations has not been persuaded that an access deficit contribution is appropriate in the pricing of the ULLS. The Commission seeks the views of interested parties on the appropriateness of averaging ULLS prices for Bands 2, 3 and 4. What will be the effect on the long-term interest of end users of such a pricing structure in terms of its effects on competition for services which are delivered using the ULLS, and the efficient investment in and use of infrastructure? Will such a pricing structure encourage access seekers to take up the ULLS in high cost (i.e. rural) areas? What are the likely effects in metropolitan (band 2) areas. General PSTN and ULLS issues TSLRIC for PSTN and ULLS Telstra appears to endorse a TSLRIC based methodology for estimating the long run efficient costs of supplying the undertaking Services, although it also notes that the PIE II model is a total element long run incremental cost (TELRIC) model. The Commission determined in its July 1997 access pricing principles paper that pricing based on total service long-run incremental cost (TSLRIC) to recover the efficient costs of a forward-looking network would generally satisfy the relevant criteria, including the reasonableness criteria under s. 152AH of Part XIC of the Act. The Commission has used a TSLRIC methodology for calculation of PSTN O/T and ULLS access services in its previous pricing considerations. The concept of TSLRIC can be understood by breaking it up into its components: Total service refers to it being the cost of production of an entire service (or a production element) not to the cost of a particular unit. However, with respect to carriage services it is usually expressed on a per-minute or per-line basis by dividing the annual total service cost by the number of minutes carried or, alternatively, by the number of services in operation. Long run refers to it being a long-run cost concept in contrast to a short-run one. In the short run the amount of at least one factor of production (usually capital equipment) is fixed, while in the long run all factors of production can be varied. Incremental cost means that it is a form of marginal cost, although not the more familiar marginal cost of the change in cost incurred through a change in the amount of output produced. (This is discussed further below.) It is also an attributable cost concept as it refers only to those costs that can be attributed to the production of the service. However, in the case of the PSTN and the ULLS, it is produced using production elements shared with customer access lines and ISDN, and these costs are rolled-in and shared over all lines on a fully-distributed cost basis. In practice TSLRIC is usually defined to include a contribution to organisation level costs (TSLRIC+). Given these attributes TSLRIC can be defined as the total cost (on an annual basis) the firm would avoid in the long run if it ceased to provide the service as a whole. The TSLRIC of supplying a service can alternatively be expressed as the sum of the operating and maintenance costs, and the capital costs that the firm incurs in providing the service as a whole. Operating costs are the continuing operational costs of providing the service, including the labour and materials costs that are causally related to the provision of the service. Capital costs comprise the cost of capital (i.e., the opportunity cost of debt and equity used to finance the firm) and depreciation (i.e., the decline in economic value of assets) of capital that is specific to the production of the service. The Commission seeks the views of interested parties on the appropriateness of using TSLRIC to calculate the efficient costs of supplying the PSTN O/T and ULLS access services. TSLRIC vs. TELRIC As noted above, although Telstra appears to accept a TSLRIC approach for estimating the long run efficient costs of supplying the undertaking Services, it describes PIE II as a TELRIC model. TELRIC refers to a term coined by the Federal Communications Commission (FCC) to describe its version of TSLRIC methodology. The differentiation between the two methodologies is premised on the FCCs contention that the incumbents offerings to be priced using TSLRIC methodology will generally be network elements rather than telecommunications services. In the FCCs view, TELRIC-based pricing of discrete network elements or facilities (eg local loops) is likely to be much more economically rational than TSLRIC-based pricing of conventional services (eg. local exchange services, long distance services). Separate telecommunications services are provided over shared network facilities, the costs of which may be joint or common with respect to some services. On the other hand, the network elements, as defined by FCC, mostly correspond to distinct network facilities. Therefore, the amount of joint and common costs that need to be allocated is likely to be much smaller under TELRIC as opposed to TSLRIC approach. Since it is difficult for regulators to determine an economically optimal allocation of any joint and common costs, the FCC believes that pricing elements rather than services is more reliable from the standpoint of economic efficiency. Under the TELRIC methodology, the incumbents prices for interconnection and unbundled network elements recover the forward-looking costs directly attributable to the specific element as well as a reasonable allocation of forward-looking common costs. In this case, the directly attributable forward-looking costs include the incremental costs of facilities and operations dedicated to the element. They include investment costs, expenses related to the primary facility used to provide the element, and incremental costs of shared facilities and operations. The latter must be attributed to the specific elements. Broadly, the TELRIC of an element consists of three components: the depreciation costs, operating (and maintenance) costs, and the appropriate risk-adjusted cost of capital. The Commission seeks the views of interested parties on the whether a TSLRIC or TELRIC model is appropriate for the purpose of calculating the efficient costs of supplying the PSTN O/T and ULLS access services. What do interested parties define to be the differences between these two approaches? Are such differences considered significant either in conceptual or practical terms? PIE II This section discusses the issues arising in the modelling of the PSTN and ULLS. In particular, it discusses Telstras reliance on and use of the PIE II model to derive costs of the PSTN and ULLS. While the details of the model and a number of inputs to it are confidential to Telstra, they will be available to parties signing appropriate confidentiality undertakings. The Commission therefore seeks comment on the following issues, noting that the consultation period will not expire until a period following when a reasonable opportunity has been given to all parties to access the model and the confidential information that it contains. The infrastructure used to provide PSTN OTA and ULLS Telstras PIE II model applies a scorched node approach to model the efficient costs of supplying PSTN O/T and ULLS access services. Telstras assumptions in relation to the network infrastructure used in the PIE II model are detailed in Annexure A of its submission. The Commission is aware that a major issue in calculating an access price using a TSLRIC methodology is which network to model; the access providers network as it would look if it were optimised, or a pure forward-looking (potential new entrants hypothetical) network. The Commission has so far preferred to use the former approach. While the PIE II model does not seek to optimise the network above the nodes (i.e., it assumes switches are located as per Telstras current network), it appears to model the balance of the network on a pure forward-looking basis. This approach would appear to be similar to the Commissions n/e/r/a model, however, the parameters attributed to certain aspects of the model network (in particular the assumption that only 1 per cent of the PSTN CAN is deployed in new estate areas) and from the inclusion of a new network planning cost component, appears to take a more extreme view of this approach than what the Commission had previously done. In this respect, it should be noted that the Commission has not included a network planning cost in its previous pricing considerations in relation to the PSTN. In addition, the level of total PSTN CAN deployed in new estates has been estimated to be at 5 per cent. The Commission seeks the views of interested parties on the whether a scorched earth or scorched node approach to modelling is appropriate for the purpose of calculating the efficient costs of supplying the PSTN O/T and ULLS access services, and on whether Telstras model network is the result of a proper application of a scorched node approach. Further, the Commission seeks views on whether Telstras network as it would look if it were optimised, or a pure forward-looking network should be modelled. While the above considerations are important, it should be noted that in the Commissions limited sensitivity testing of the PIE II to date, the use of specific input variables appeared to have a significant impact on model outputs. Further, when the Commission applied its previous modelling inputs, the outcomes under PIE II were very similar to those given by its n/e/r/a model. This does not mean the choice of model is immaterial, but it does suggest that the focus in this exercise should be on the input assumptions that have been made by Telstra. Routing factors Telstra has determined routing factors based on its March 2000 study of traffic through each type of Telstra switch. The routing factors are set out in Annexure J. The Commission seeks industry view of the routing factors used in Telstras model. Customer locations, traffic volumes and number of access services Telstras approach to determining customer locations in the PIE II model is explained in Section F1 of its submission. Telstra states that it uses ex ante estimates for traffic volume and service volume data as inputs into the PIE II model. These issues are discussed in sections F1, F2 and Annexure D of Telstras submission. It should be noted that the traffic and access services volume information has been provided by Telstra to the Commission on a confidential basis and can not be disclosed to any third parties. The Commission has used ex ante traffic volume and service volume forecasts provided by Telstra in its previous pricing considerations. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology for deriving customer locations, traffic volumes and the number of access services. The Commission seeks the view of industry parties on their own estimates for traffic volumes and service volumes for the period of the Undertaking. The Commission is also interested in forecasts for interconnect traffic volume for the period of the Undertaking. That is, the Commission would welcome carriers estimates for PSTN traffic and services in operation across the whole market, and on the carriers estimates for its own carriage services that it intends to supply by way of the domestic PSTN O/T service or the ULLS. Provisioning rules Telstras provisioning rules are detailed in section F3 of its submission. It should be noted that these rules are presented in a different form from the Commissions previous approach of calculating an average per SIO figure for the distribution portion of the CAN. The Commission seeks the views of interested parties on the appropriateness of Telstras provisioning rules. Trench Sharing Telstras trench sharing assumptions utilised in the PIE II model are outlined in sections F4 and F5 of its submission. With regard to the issue of trench sharing, the Commissions previous pricing considerations have taken account of: sharing within a network; sharing between feeder and distribution networks; sharing between the customer access and conveyance networks. sharing with utilities in new estates; and sharing with other telecommunications carriers and Pay TV operators. In addition, the Commission has previously endorsed a cost sharing approach where the costs of the trench should be shared equally by dividing total costs by the number of parties utilising the trench. Telstras sharing approach appears to follow a leasing approach where rather than sharing costs with other parties using the trench, it incurs the costs but is able to recover a certain amount from those parties. The Commission seeks the views of interested parties on Telstras approach to trench sharing and assumptions in relation to the issues of: duct sharing within the Telstra network; trench and duct sharing with others; and open trenches (New Estates). Asset prices and lives Telstra has indicated that the prices of assets used are the most recent available prices paid by it. It has updated these for each of the years of the undertakings using the price trends set out in Annexure F of its submission (together with the reasons for doing so). The useful lives of these assets employed by PIE II are set out in Annexure G of Telstras submission. The Commission seeks the views of interested parties on current prices of assets, and appropriateness of the asset price trends and asset lives used by Telstra in its PIE II model. WACC and real options value The weighted average cost of capital (WACC) represents the return that would be reasonable for Telstra to earn on the capital employed in efficiently providing the undertaking Services. Telstras assumptions of WACC parameters and the WACC value are set out in section F8 of its submission. Further Telstra claims that the WACC ought to be adjusted to cover for the insurance costs of various asymmetric risks Telstra argues it faces. Whilst it believes that a percentage mark-up should be applied to the WACC, Telstra has currently set this mark-up at zero as it claims it faces complexities involved in quantifying these asymmetric risks. The Commission seeks the views of interested parties on the appropriateness of WACC (including WACC parameters) and real options value used by Telstra for the calculation of PSTN O/T and ULLS services. Grossing up for tax Annual capital costs are established using post-tax vanilla WACC (i.e. costs/revenue requirements are those after payment of corporate tax). However, the access price sought by Telstra is expressed in pre-tax terms. Therefore, the tax burden is proposed to be explicitly recognised. Telstras methodology for grossing up the capital costs for tax is set out in section F10 of its submission. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology of grossing up for tax. Operational and maintenance costs and network planning costs The PIE II model applies percentage mark-ups to capital cost for each asset category to determine the operational and maintenance costs and network planning costs. The percentages are set out in Annexure H of Telstras submission. Description of the derivation of the percentages is set out in Annexure I. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology for the calculation of operational and maintenance costs and any network planning costs. Indirect costs (organisational-level costs) Indirect costs (including indirect O&M costs) are defined by Telstra as those incurred by the corporate centre business unit. Indirect costs include expenses such as land, and buildings and are allocated across all business units and asset categories in each business unit. The mark-ups for indirect costs and the method of calculating these are set out in section F12, Annexure H, and Annexure I of Telstras submission. The Commission seeks the views of interested parties on the appropriateness of Telstras methodology for the calculation of indirect costs. LCS issues Telstra has determined its proposed LCS price of 14.5 cents in the undertakings with reference to its estimates of efficient network costs using its PIE II model. These cost estimates (excluding the UPCC) are shown in the table below. TELSTRAS ESTIMATES OF EFFICIENT NETWORK COSTS FOR LCS (EXCL. UPCC)*2002/032003/042004/0514.80 cents per call 14.27 cents per call 14.07 cents per call * Telstra notes that these network costs exclude billing, marketing and administration costs. In adding a UPCC to these network costs up to the maximum price that Telstra can charge for a local call under the retail price controls (less retail costs) Telstra claims the LCS cost for the three years 2002-03 to 2004-05 is actually 17.51 cents per call. This figure uses the Commissions estimate of Telstras retail costs of 2.49 cents where access seekers share the burden of the absorption of GST for standard local calls. Commissions LCS pricing principles Issues surrounding the determination of a suitable price for the LCS have been dealt with extensively by the Commission in the development of pricing principles and indicative prices for this service. The Commissions most recent approach is detailed in the revised final report Local Carriage Service pricing principles and indicative prices released in April 2002. Possible approaches to projecting LCS prices forward are contained in the Commission discussion paper Future Access Pricing Approaches for PSTN, ULLS and LCS released in September 2002. Interested parties are invited to submit to the Commission on matters relating to the extent to which the LCS prices in the undertakings conform with the pricing methodologies detailed in these documents and the suitability of these pricing methodologies for assessing the LCS price in Telstras undertakings. A number of specific matters that the Commission is keen to explore further as part of the undertaking assessment process are detailed below. Determination of the LCS price A key principle followed by the Commission in relation to the LCS is the use of a retail minus retail cost methodology for determining the LCS price to be paid by access seekers. This is to ensure compatibility between the LCS price charged to access seekers and the prices that Telstra charges at a retail level, which need to be within the retail price controls faced by Telstra that prevent it from charging any more than 20 cents (or 22 cents including GST) for a retail local call. This recognises the possibility that the TSLRIC, including an access deficit contribution, of a local call may be greater than 20 cents per call. In applying the Commissions pricing approach, Telstra should be indifferent in supplying calls to access seekers for resale or to its own retail customers. In determining its LCS price the Commission has recognised that it has been the practice of access seekers to take over responsibility for billing retail customers for basic access (i.e. line rental). This is reflected in the undertakings, where the undertaking price is only available where access seekers purchase from Telstra retail basic access as specified in its HomeLine Part and BusinessLine Part retail offerings on the terms provided in Telstras Standard Form of Agreement. In view of this approach to the supply of the LCS, the Commission has previously taken the view that access seekers are entitled to receive a discount off this retail basic access price, preferably from the retail basic access price or if this is not done, as a further per call discount from the local call retail price. If Telstras proposed LCS undertaking price of 14.5 cents per call is referenced to the Commissions retail minus retail cost methodology, it can be implicitly assumed that total retail costs are 5.5 cents (i.e. the difference between 20 cents and 14.5 cents). This comprises retail costs for local calls of 2.49 cents, implying that the remaining 3.01 cents is a retail cost discount for basic access. By contrast, the Commissions equivalent for this basic access cost discount as detailed in its April 2002 pricing principles was is 4.95 cents. The Commission invites comment on Telstras method for determining the price of the LCS in view of the method proposed by the Commission given the retail price controls faced by Telstra. Comment is sought on the reasonableness of the undertaking price for LCS, particularly in light of the requirement to purchase from Telstra its HomeLine Part and BusinessLine Part retail offerings on the terms specified in Telstras Standard Form of Agreement in order to receive the undertaking price for LCS. Retail starting price In its use of the retail minus approach, the Commission has considered it appropriate to use Telstras unbundled retail local call service offerings as a basis for subtracting retail costs to determine suitable LCS prices. These unbundled offerings comprise the retail local call price for a given retail basic access charge. These contrast to Telstras bundled offerings which are the retail offerings for local calls and basic access conditional on preselection to Telstra for national long-distance, international and fixed to mobile calls. These unbundled rates have made reference to Telstras HomeLine Part and BusinessLine Part retail offerings. The Commission has recognised however, that Telstra could price squeeze its access competitors by increasing its unbundled local call prices relative to its bundled local call prices without any corresponding increases in the prices of other services in its bundled offerings. The Commission therefore indicated in its April 2002 pricing principles that it would monitor the market and revisit this approach if it believed there was evidence of a price squeeze. It notes that in a recent set of price changes, Telstra abolished the Neighbourhood call rate in its HomeLine and Business Line Part packages. The Commission has also expressed the view in its April 2002 pricing principles that it would expect the LCS price to change as Telstra made any changes to its unbundled offerings such as HomeLine Part or Business Line Part. It notes that there is no such provision in the undertakings. Is the LCS price proposed by Telstra of 14.5 cents low enough to alleviate any possible price squeeze between Telstras bundled and unbundled local call offerings? The Commission would be particularly interested in any imputation tests from access seekers to support any such claims. Does the fact that the undertakings have no provision for the LCS price to be changed should the prices of Telstras unbundled or bundled local call services offerings change pose a concern for access seekers? Are there alternative approaches to pricing the LCS that would help to avoid price squeezes occurring as Telstra changes its unbundled relative to its bundled retail local call service offerings? Calculation of retail costs In assessing the reasonableness of the LCS price in the undertakings it is the Commissions intention to make a new estimate of Telstras retail costs for local calls and basic access using Telstras 2001-02 Regulatory Accounting Framework (RAF) accounts. In accordance with past practice, the Commission is prepared to accept that certain adjustments to these accounts may be required to, among other things, reallocate costs between wholesale and retail functions. Interested parties are invited to make any comment on this approach to determining retail costs and issues surrounding adjustments to the RAF accounts. General issues Relationship of proposed undertakings with commercial settlements Telstra contends that the charges proposed in each of its undertakings reflect the prices that prevail at the upper end of the wholesale market. Telstra has previously stated that the undertakings propose a set of standard prices below which it is expected wholesale customers will negotiate discounts based on the value their business brings to Telstra. This would be based on such factors as volume commitments, credit management arrangements and other commercial benefits. The undertakings, however, do not provide any explicit reference to such factors or their impact on negotiated rates. This would mean that if the Commission were to accept the undertakings, and an access dispute was notified, the Commission could not make a determination that specified a price other than that expressly provided in the undertakings. In these circumstances, it would be unlikely that an access seeker could require Telstra to provide a discount to the access charge as its public statements have foreshadowed should it subsequently decide not to offer such discounts. The Commission seeks views on whether the undertakings should also make reference to the factors and circumstances that would allow for different prices from those which are proposed. The Commission is also interested in whether the lack of any information about such factors provides sufficient certainty for access seekers over time, particularly in reducing access disputation, which Telstra has claimed is a key reason for lodging these undertakings. Reasonableness of the non-price terms in the undertakings The Commission notes that Telstras undertakings cover only a very limited range of non-price terms and conditions. In this regard, the Commissions interprets the following clauses of the undertakings as effectively providing the non-price terms on which Telstra undertakes to supply the undertaking Services: clauses 3 and 5 of Attachment A to the domestic PSTN O/T service / LCS undertakings clauses 3 and 4 of Attachment C to the domestic PSTN O/T service / LCS undertakings clauses 3, 5 and 6 of Attachment A to the ULLS undertakings. Whilst the Act permits an access provider to give access undertakings that do not address all terms and conditions of supply, the Commission considers that assessing the reasonableness of such undertakings could prove more problematic. For instance, in assessing the reasonableness of the undertaking prices, it would appear that the Commission will have to make certain assumptions as to the prices that are likely to prevail for ancillary or incidental services (eg network conditioning or the Telstra Domestic Interconnection service), or in regards to the other terms on which the undertaking Services will be supplied. The undertakings also provide within the extended service descriptions details of the technical characteristics of the undertaking Services. Although these do not themselves comprise non-price terms on which Telstra undertakes to supply the services as declared by the Commission, they are indicative of the active declared services that Telstra could be expected to supply (to itself or others). In this regard, the undertakings generally adopt standards that are set out in industry codes or in Telstras manuals. Copies of these industry codes can be obtained from the following URLs: ULLS ACA registered Industry Code titled 'Unconditioned Local Loop Service - Network Deployment Rules';  HYPERLINK "http://www.aca.gov.au/codes/c559.pdf" http://www.aca.gov.au/codes/c559.pdf ACIF draft Industry Code titled 'Unconditioned Local Loop Service - Ordering, Provisioning and Customer Transfer", May 2000;  HYPERLINK "http://www.acif.org.au/OCRP_WC15___Ordering/files/DR_C569.pdf" http://www.acif.org.au/OCRP_WC15___Ordering/files/DR_C569.pdf ACIFIndustry Code titled 'Unconditioned Local Loop Service - Ordering, Provisioning and Customer Transfer';  HYPERLINK "http://www.acif.org.au/ACIF/files/C569_2001.pdf" http://www.acif.org.au/ACIF/files/C569_2001.pdf ACIF Industry Guideline titled 'Unconditioned Local Loop Service - Fault Management' dated May 2000; and,  HYPERLINK "http://www.acif.org.au/ACIF/files/G572_2001.pdf" http://www.acif.org.au/ACIF/files/G572_2001.pdf PSTN/LCS SFOA (PSTS section);  HYPERLINK "http://www.telstra.com.au/sfoa/docs/psts.doc" http://www.telstra.com.au/sfoa/docs/psts.doc ACIF G-500 Specification - Signalling System No 7 - Interconnect ISUP;  HYPERLINK "http://www.acif.org.au/ACIF/files/G500.pdf" http://www.acif.org.au/ACIF/files/G500.pdf ACA Preselection Code;  HYPERLINK "http://www.aca.gov.au/codes/c515b.pdf" http://www.aca.gov.au/codes/c515b.pdf ITU-T Recommendations G.703, G.704 and G-732 (Blue Book);  HYPERLINK "http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T%2DREC%2DG%2E703%2D200111%2DI" http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T%2DREC%2DG%2E703%2D200111%2DI;  HYPERLINK "http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T-REC-G.704-199810-I" http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T-REC-G.704-199810-I;  HYPERLINK "http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T-REC-G.732-198811-I" http://www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T-REC-G.732-198811-I ACIF G-502 Specification - Australian Network Performance Plan;  HYPERLINK "http://www.acif.org.au/ACIF/files/G502.pdf" http://www.acif.org.au/ACIF/files/G502.pdf Extracts from the Telstra Ordering and Provisioning Manual and POI Availability List can be obtained by contacting Bill Gallagher of Telstra on (02) 9298 5597. Since lodging the undertakings with the Commission, Telstra has proposed some amendments to the drafting of some of the clauses and has flagged that it may propose further such changes. The drafting amendments that have been proposed are footnoted on the face of the undertakings that will be published by the Commission. The Commission is making these proposed drafting amendments known now, and is inviting comment on them, so that should the Commission consider that it should not accept the undertakings as lodged, it could then have the benefit of interested parties views as to whether it should accept revised undertakings as per the Telstra proposed changes. Telstra has not withdrawn the undertakings as lodged. Accordingly, interested parties are encouraged to comment on the undertakings as lodged and on the drafting revisions that have been proposed. The Commission seeks industry views on the reasonableness of the limited non-price terms and conditions, and of the technical characteristics of the undertaking Services. The Commission seeks industry views on the approach that the Commission should adopt in assessing the reasonableness of the undertakings when all the terms and conditions of supply are not now known. The Commission notes that a number of non-price terms and conditions are contained in several ACIF technical and operational codes. The Commission seeks parties views on whether these codes should be considered in the assessment of the undertakings and whether they provide sufficiently detailed and exhaustive non-price terms and conditions. The Commission notes that certain of the external documents that contain the technical characteristics of the undertaking services have been defined as they exist from time to time, and not at the time at which the undertakings are accepted. The Commission seeks industry comment on the reasonableness of this approach. Competitive neutrality Telstra argues that the principle of competitive neutrality implies that charges set on the basis of efficient costs should be determined such that an access seeker would be no worse off building a new PSTN network than it would be purchasing the service from Telstra. In effect, Telstra appears to define competitive neutrality in terms of a build-buy decision. The Commission is interested in the industry view on this interpretation of competitive neutrality, or any alternative interpretation. Imputation tests Imputation tests can indicate whether access seekers are able to compete under certain access price structures. The Commission has already expressed interest in the imputation tests for the LCS. The Commission notes that in order to gain access to the various undertakings services access seekers may need to acquire necessary ancillary or incidental services, which will have associated charges in addition to the headline rates specified in the Undertakings. It is important that interested parties take account of these additional wholesale costs in undertaking any relevant imputation analysis. The Commission invites interested parties to submit imputation test for any and all services covered by the undertakings, under prices proposed by the undertakings. International comparisons and benchmarking Telstra presents a comparison of its undertaking prices with prices in other countries. It does so by removing the contribution to CAN costs from its undertaking price and from any price in other jurisdictions that contains a CAN cost contribution. The Commission is interested in any international comparison of the full undertaking prices with prices from other jurisdictions without the removal of any contributions to CAN costs.  ԭ, Pricing of unconditioned local loop services (ULLS) Final Report, May 2002.  Standard zone has the same meaning as in Part 4 of the Telecommunications (Consumer Protection and Service Standards) Act 1999.  ԭ, Local Carriage Service pricing principles and indicative prices Final Report (Revised), April 2002.  Refer to s.152AS and s.152AT of the Act. The Commission has not made any such exemptions to date.  Sub-section 152AH(1) of the Act.  Sub-section 152AH(2) of the Act.  Sub-section 152AB(2) of the Act.  See the revised section 152BU (5), (6) & (7).  ԭ, Access Pricing Principles Telecommunications, a guide, July 1997.  PIE refers to Telstras PSTN ingress and egress cost model.  Assuming that LCS can only bear costs up to 17.51c per call.  Assuming that LCS can only bear costs up to 17.51c per call.  Assuming that LCS can only bear costs up to 17.51c per call.  On the basis that the access seeker acquires basic access from Telstra at retail prices.  On the basis that the access seeker acquires basic access from Telstra at retail prices.  On the basis that the access seeker acquires basic access from Telstra at retail prices.  See: Telstras Submission in Support of its Undertakings dated 9 January, 9 January 2003, p. 6  See: ԭ, A report on the assessment of Telstras undertaking for the Domestic PSTN Originating and Terminating Access services, July 2000, pp. 24-26.  Refer to ԭ, Pricing of unconditioned local loop services (ULLS) Final Report, March 2002, p.30.  The issue of calculating ULLS specific costs is discussed in detail in ԭ, Pricing of unconditioned local loop services (ULLS) Final Report, March 2002, pp. 3945.  Line sharing refers to a situation where two separate carriers provide separate services over a single metallic pair (or line) allowing a combination of low-speed and high-speed services to be provided on a single line at the same time.  ԭ, Pricing of unconditioned local loop services (ULLS) Final Report, March 2002, pp 18-19.  See Telstras submission in Support of its Undertakings dated 9 January 2003 at pages 1-2 & Annexure A page 6. Available at:  HYPERLINK "http://www.accc.gov.au/telco/undertakings/lr174302.pdf" http://www.accc.gov.au/telco/undertakings/lr174302.pdf  ԭ, Access Pricing Principles Telecommunications a guide, July 1997  For the ULLS, the Commission has utilised a TSLRIC+ methodology which incorporates a contribution to indirect cost or organisational level costs, while TSLRIC++ has been used for the PSTN access service which incorporates both a contribution to organisational level costs and an ADC.  The words incremental and marginal are synonymous and are used interchangeably.  Refer to ԭ, Future Access Pricing Approaches for PSTN, ULLS and LCS, Discussion Paper, September 2002, p. 24.  See: ԭ, Local Carriage Service pricing principles and indicative prices, Final report (Revised), April 2002, p. 30.  See Telstra media release announcing it has lodged its core service undertakings with the ԭ, 4/2003, 9 January 2003.  Ibid. 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