Anacom Determination Regarding the Interconnection Prices for Leased Lines Interconnection Services and for Interconnection Components
On 26 March 2004, PT Comunicações submitted to ANACOM a proposal to reformulate the leased lines interconnection services and the interconnection components offer conditions associated with the lines supplied by another operator. In the same proposal, PT Comunicações submitted their reasoning for the services proposed prices.
The model proposed by PT Comunicações for the provision of those services is as follows:
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After the evaluation of PT Comunicações proposal, ANACOM thinks that the same, as far as prices are concerned, is not compatible with the cost orientation principle, since:
(a) PT Comunicações considers that some of the time spent with the execution of the services (namely as to cable installation) and the contracting costs (namely as to the installation of split ducts) are excessive for purposes of cost evaluation; and
(b) PT Comunicações is overestimating the cost for the space occupied by the DDFs.
In addition, in order to avoid subjectivity in the estimate of cable length, a tariff according to cable length should be adopted.
Also in a letter dated 31 March 2004, PT Comunicações informed to have adapted and published the Reference Interconnection Offer, in compliance with the Determination of the Board of Directors of ANACOM of 16 March 2004.
In view of the changes made, should an operator choose to supply interconnection circuits using third party means, and provided that this third operator is collocated, PT Comunicações does not accept that the interconnection point is located in the space for the co-installation already hired by this third operator. Besides, this issue was also raised by OniTelecom and Novis, which requested ANACOM intervention.
ANACOM considers that this fact introduced inefficiency and constitutes an unjustified restriction to an offer that should be unlimited.
By determination of 29 April 2004, the Board of Directors of ANACOM decided to hear the interested parties as to the draft determination, whereby the received comments, the respective analysis and the reasoning being included in the “Prior Hearing Report of ANACOM draft determination regarding the prices for the leased lines interconnection services and for interconnection components”, which is integral part of this determination.
In view of the expected increase in the demand of this type of lines and in line with the comments received in the previous hearing, ANACOM deems important to extend this offer to the 155 Mbps circuits, whereby PT Comunicações should present, for that purpose, a duly reasoned price proposal.
Taking into account the detailed reasoning submitted in the “Prior Hearing Report” that is integral part of the case, the Board of Directors of ANACOM, within the scope of its duties foreseen in subsections b) and f) of paragraph no. 1 of article 6 and pursuant to article 9 of the Statutes, approved by Decree-Law no. 309/2001, of 7 December, taking into account the regulation objectives foreseen in article 5 of Law no. 5/2004, of 10 February, namely the promotion of competition in the offer of electronic communications services and the defence of the citizens’ interests, and pursuant to subsection f) of paragraph no. 2 of article 122 of Law no. 5/2004, of 10 February and subsections b) and g) of article 9 of the Statutes, decides as follows:
1. PT Comunicações should change, within 10 days, the Reference Interconnection Offer so as to introduce the following changes:
| Maximum price of the common components service for traffic interconnection circuit and for leased lines interconnection | Price |
|---|---|
| Installation of a support component for 21 pairs of coaxial cables | € (410+22.50d1) |
| Monthly fee of a support component for 21 pairs of cables | € 5.75 |
d1: length of the 21 pairs of coaxial cables (in meters)
| Maximum price of internal extension for traffic interconnection circuit | |
| Installation | Monthly fee |
| € (72.4+1.40d2) | € 0.30 |
d2: length of the pair of coaxial cables (in meters)
| Maximum prices of the internal extension and access to the PTC leased line network for interconnection of leased lines | ||
| Debits | Installation | Monthly fee |
| 64 Kbps (N=1) | € [N x(133,80 + 0,10d2) + 59] | € 0.70 |
| 128 Kbps (N=2) | € 1.30 | |
| 192 Kbps (N=3) | € 1.90 | |
| 256 Kbps (N=4) | € 2.45 | |
| 384 Kbps (N=6) | € 3.65 | |
| 512 Kbps (N=8) | € 4.80 | |
| 768 Kbps (N=12) | € 7.15 | |
| 1024 Kbps (N=16) | € 9.50 | |
| 1536 Kbps (N=24) | € 14.20 | |
| 2 Mbps e 34 Mbps1 | € (72.4+1.40d2) | € 0.30 |
d2: length of the pair of coaxial cables (in meters)
The prices hereby set out will have to be applied on the date on which the service provision begins.
PTC will also have to include the forms in the RIO and define the appropriate deadlines for the provision of the considered services.
PTC shall submit, within 20 days, a duly reasoned price proposal for the offer of circuits with 155 Mbps bandwidth.
2. PT Comunicações should change the Reference Interconnection Offer so as to allow the operators interconnected with this company to be able to hire third parties for the establishment of interconnection circuits and, for this purpose, those third parties should be able to use the respective co-installation spaces thereto.
3. This offer applies to the interconnection circuits and to the leased lines interconnection service provided by operators to end users and at wholesale level.
