A. Responses received
AR TELECOM
AR TELECOM, stating that it is broadly in agreement with the approach proposed by ICP-ANACOM, considers it essential for a reasonable time-frame to be established for the designation of the next universal service provider (USP), given that the DD refers that the methodology for calculating CLSU - custos líquidos do serviço universal (net costs of the universal service) is to be applied until the USP designated following a tendering procedure starts the service provision.
As regards the CLSU financing issue, AR TELECOM supports the option of compensation through public funding; nevertheless, it believes that, where this is not possible, in the light of the ongoing crisis in the country, a possible distribution of costs among the remaining operators should mainly take into account the activity’s operational revenues or results, and not only the mere turnover.
CABOVISÃO
CABOVISÃO raised doubts on the reason why ICP-ANACOM failed to draw immediate conclusions from the Judgment of the Court of Justice of the European Union (CJEU), of 7.10.2010, which declared that the Portuguese Republic infringed the European Union (EU) Law on the matter of USP designation, for the purposes of these DD.
CABOVISÃO considers that, as in its opinion the USP designation in Portugal is not valid under EU Law, before moving on to an analysis of possible net costs of the provision of the universal service (US), the procedure laid down in article 95 of the ECL should be launched, so as to enable other operators to show their ability to provide the service in a more efficient/less expensive manner, in compliance with the process imposed by law.
In this context, an alternative to US financing could be considered, such as, for example, the provision of direct support to citizens who use this service, instead of imposing obligations on companies that operate in the market.
CABOVISÃO refers that it is legitimate to hear PTC only within the scope of a public consultation, as a result of the conviction of the Portuguese State as regards the designation of PTC as US provider.
The company is also of the opinion that ICP-ANACOM should first make sure that the USP complies with its obligations in an economically-efficient manner, deeming that the technological evolution should render that operator subject to lower costs. Should this situation not occur, other operators, which in this operator’s opinion were illegally excluded from the possibility of providing the US, should not be unduly burdened with this fact.
CABOVISÃO refers that even after the tender for USP designation has been carried out, it would be unthinkable for other operators to compensate the value of costs without questioning and verifying such value. In this context, it would be necessary even then to debate whether criteria for calculating costs are reasonable.
The company refers that it does not accept the amount of information which is deemed to be confidential in the process, fact which in its opinion says much about what it deems to be a lack of transparency, forcing operators to comment, approve and bear costs they are not aware of nor control. It thus requests of ICP-ANACOM that it makes available all appropriate costs/benefits data at its disposal, so as to enable operators to assess the matter in a full and informed manner.
ONITELECOM
ONITELECOM finds that, overall, the DD show the regulator’s concern with fairness in the sector and with accuracy in the calculation of CLSU. However, ONITELECOM believes that some subjects remain to be clarified which must be safeguarded, in order to ensure an effective probity in the calculation and financial allocation of costs related to the US provision.
ONITELECOM hopes that the regulator distributes CLSU among the major operators, whose total market share reaches 80% to 90%, thus maintaining the rationale of the notion of non-existence of unfair burden.
ONITELECOM considers also that several sectors of economy, namely the financial sector, should contribute to CLSU, from a minimum base of the respective EBITDA 1.
Lastly, the company refers that it is essential for the regulator to hold a consultation on the various options on US financing modalities.
OPTIMUS
OPTIMUS welcomes ICP-ANACOM’s decision to allow the market to discuss the methodology for calculating CLSU and the definition of unfair burden, as this will contribute to increase the legal certainty related to the legal and regulatory framework of the provision of electronic communications networks and services in Portugal, in general, and specifically of the US provision.
Without prejudice to agreeing with some of the proposals put forward by ICP-ANACOM, OPTIMUS states upfront that the company does not accept others, namely with some aspects in the scope of the definition of unfair burden, which will considered in the assessment of specific comments.
As regards the assessment of unfair burden after a tendering procedure, OPTIMUS disagrees with the approach proposed by ICP-ANACOM. It is of the opinion, in this matter, that the mentioned article 95 lists a set of alternatives, and does not impose the value indicated in the tender to be the automatic value to be compensated. It also refers that this situation has not occurred in any Member State where a USP designation tender has been held, referring the example of the designation of France Telecom.
Thus, invoking paragraph 4 of article 99 of ECL, OPTIMUS considers that the value indicated in the tender should be regarded as the maximum ceiling for the value to be compensated, the assessment of unfair burden, and where appropriate, the calculation of the effective CLSU, being also required. According to OPTIMUS, it should not be ruled out that some entities may present values that exceed the respective costs but which are nonetheless lower than those presented by other bodies, owners of networks which are less comprehensive in geographical terms, especially in the more remote areas.
In this context where the range of operators contributing to the CLSU financing largely exceeds that of possible tenderers, OPTIMUS suggests that the designated USP is made subject to the obligation to prove regularly that it has incurred in unfair burdens that could be compensated, and that the regulator imposes audits to verify and accept the nature of such burdens.
PTC
PTC, recalling its condition of USP under a concession contract, the historical background, and the fact that it never received any compensation, to which it deems to be entitled for services provided since 1995, welcomes the fact that ICP-ANACOM has given some steps towards the adoption of decisions on CLSU. Notwithstanding, it considers that the DD propose concept and methodology approaches which must be reviewed, referring that there is a lack of preliminary enquiries which taint, or may taint, some of the conclusions reached by ICP-ANACOM.
PTC refers, however, that many of the methodological options put forward, especially those which are amendments to prior positions, do not comply with legal requirements, nor do they take into consideration the national reality. They also have the pernicious effect of decreasing considerably the amount of compensation to which PTC considers to be entitled for the CLSU incurred so far.
PTC believes also that the regulator’s role should not be to ascertain that the CLSU do not exceed a given threshold, or that such costs fall within the ranges in line with per capita values of other countries, but to establish a methodology and a definition of unfair burden which take into consideration the relevant aspects of the national reality.
PTC feels that it should not suffer loss due to the difficulties arising from the fact that the issue is many years overdue, on account of obligations laid down in the ECL and of time-limits self-imposed by the regulator. It is also of the opinion that such difficulties should not be used as an excuse not to compensate the company for the years for which that compensation is due, or to decrease the amount of compensation.
Likewise, it takes the view that, although it wishes the CLSU financing process to reach an end, the urgency related to proceedings against the Portuguese State should not adversely affect the transparency and grounds for the CLSU process, which requires, in some matters, a more in-depth analysis.
PTC describes the various steps in the scope of the access to the administrative process, declaring that it does not accept the regulator’s explanations on the elements kept as confidential, which are deemed to be relevant for the assessment of the matter, and that the failure to being given access to such elements is a violation of its procedural rights which shall be discussed in the appropriate occasion.
PTC considers that the DD represent the culmination of a long process during which it put a great deal of effort and adopted several initiatives to determine the methodology for calculating CLSU. For the purpose, the company presents an extensive historic reference, namely on the various determinations adopted by ICP-ANACOM, as well as on letters submitted by the company, to highlight the delays of the regulator. It also stresses the positions taken by some members of the Management Board (MB) of ICP-ANACOM on the need to finalize positions on CLSU, at the time of the 2007 decision on "Retired People and Pensioners" which significantly increased its costs.
PTC specifically mentions the regulator’s internal memos (submitted to the MB between April and August 2009), which, following guidelines of the MB of ICP-ANACOM, were in its view subject to deep or even radical changes, further stating that it fails to understand what it refers to be "vague minutes", requesting of this Authority that these issues are clarified.
PTC concludes by referring that these DD were only submitted for public consultation 9 months after it supplied the information requested, 2 and a half years after the expiry of the deadline to which ICP-ANACOM committed in the determination of 30.02.2008, almost 4 years after the regulator’s Chairman acknowledged ICP-ANACOM’s added responsibilities to quickly settle the question of universal service financing and around 7 years after the entry into force of ECL, which imposes on ICP-ANACOM the obligation to define the notion of unfair burden and the calculation of CLSU.
Relatively to the definition of unfair burden, PTC stresses the need, in its opinion, to differentiate between the regime prior to the ECL (Decree-Law number 458/99) and the one which came into force with this law, as otherwise a retroactive and illegal application of this law would be at stake. It highlights also its view on the judgement of the CJEU and contests the DD approach in terms which are described in more detail in the specific comments.
As far as the calculation methodology is concerned, the company disagrees specifically with the use of historic costs, of successive iterations, of the so-called "plausibility criteria", of the classification of avoidable costs and of the exclusion of unprofitable customers for insufficiency of revenues. It also expresses certain misgivings about the elasticity factor in the case of costs associated to "Retired People and Pensioners" and about some aspects related to the assessment of indirect benefits, namely those related to reputation and brand, ubiquity, life-circle and regulation fees.
As regards the time-limit for sending the information, PTC does not agree with the 60-day deadline for submitting data on the preliminary calculation of CLSU, referring that it is not a proportional or reasonable deadline, given the level of detail and the extent of required information, and proposes as an alternative a 120-day period.
Relatively to audits, it refers that given the existing delays, specific launch and conclusion deadlines should be defined immediately, so as to avoid dragging out ICP-ANACOM’s final decision on CLSU. It further refers the need to establish a deadline also for audits to be carried out after CLSU information for the period from 2001 to 2003 is submitted.
RTP
RTP refers that it does not provide these services, and as such it has nothing to declare on the documents under consultation.
VODAFONE
VODAFONE welcomes the approval of the DD, considering that they contribute towards greater predictability and legal certainty, enabling an easier planning of the commercial and strategic planning of several market agents.
Notwithstanding, it refers that both what it deems to be an illegal designation of USP and an incorrect implementation of the legal framework on the nature and evolution of US, render any decision-making process on a possible CLSU financing by other companies impossible. According to VODAFONE, CLSU compensation, if any, should only by financed through public funds.
VODAFONE highlights what it deems to be essential facts to be considered in the scope of the ongoing procedures, as well as the main conclusions to be drawn.
It focuses first on what it considers to be an illegal USP designation which, according to VODAFONE, should influence the application of the methodology for calculating CLSU, in the scope of the determination of what may be considered an unfair burden and the steps taken to promote CLSU compensation.
VODAFONE refers that an appropriate USP designation is essential for numerous reasons that affect the results of the decisions under consideration, among which it stresses that it is not guaranteed that US obligations have been or are being complied with in an economically-efficient manner, and that it has not been demonstrated that, in Portugal, the US should be provided by a single company and that the USP designation should concern all services and all the areas of the country. In this respect, referring to some examples of other countries, it states that the option for several USP has the potential for increased and better competition, raising concerns about whether the "choice" of the incumbent for the sole Portuguese USP does not create distortions in the market and hinders the desired liberalization and evolution of the sector.
In the light of the above, VODAFONE expresses a deep worry, as it declares that it remains to be demonstrated that there would still be any CLSU to be considered if the USP had been chosen according to the legally established procedure. It refers also in this respect that in several countries with competitive market conditions, the designation of an USP is not required, and moreover, such designation does not imply any compensation for obligations relating to that provision.
The company highlights also what it considers to be an absence of procedures for reviewing US obligations, which should guarantee that obligations are provided while using the most efficient technology (which, if ignored, would lead to a failure to comply with the principle of technological neutrality), that they are of a current nature/scope and are applied to the different/new needs of the population, by reference to the evolution of the market and competition.
In this context, VODAFONE considers that the obligations on the provision of the fixed telephone service (FTS) should be removed from the US scope, given the development of mobile services, both in terms of the number of users and in terms of prices, which are lower that US charges.
The US scope should also exclude the provision of directories and of directory enquiry services, which are widely made available to the public and which are provided by most providers, as well as public pay-phones, as the need for this services is met via the universal access to the land mobile service (LMS).
After the referred obligations have terminated, persisting market failures should be identified, namely the provision of the service to customers in extremely remote areas, customers with disabilities or special needs and users with a low income, and specific measures should be considered, including the allocation of selective support, namely in the framework of social policies, to users with low income (for example through the granting of vouchers).
As regards US provisions, VODAFONE also refers that the concept of affordable price should only be used to avoid the exclusion of specific users for social or economic reasons, not in a general and indiscriminate manner.
VODAFONE considers that designating an USP and determining US obligations should only be required where there are obligations that are not naturally provided by the various operators in a competitive market framework.
In this scope, it is of the opinion that only net costs which do not exceed those which would result from the proper compliance with the law, as regards the use of the most efficient means, of the most appropriate services and the most current needs of potential US beneficiaries, should be considered. It adds that the determination of CLSU which exceed those which ideally would be incurred in case all legal preconditions on the matter were met, would not only benefit the USP unfairly, but it would also seriously harm the remaining operators and imply distortions in markets directly or indirectly connected.
A third fact referred by VODAFONE concerns US financing obligations. In this respect, the extremely significant weight which electronic communications service providers have been burdened with in the scope of their Information Society obligations should be mentioned, in the scope of fees for the activity performed and indirect contributions to the US (regulation fee), which are considered public for nature and scope purposes. ICP-ANACOM’ revenue arising from electronic communications are also highlighted.
It also refers the challenges faced today by providers, given the situation of economic crisis and the need to ensure the country’s technological evolution, with the long term evolution (LTE) 2 and next generation networks, the adoption and implementation of which entail high investments.
Lastly, in refers that the US has a public nature which, in the Portuguese case, is more paradigmatic, given the steps given so far, namely the option to "choose" the USP, this body’s shareholding structure, its competitive situation and its economic and financial position, which is deemed to be healthy, allowing it to make investments which would be too high for most of the remaining operators.
In this context, VODAFONE feels sure that, in the light of grounds laid down, its concerns will certainly be legally met, in case CLSU are compensated by distributing costs among other companies, all the more so when considering that these companies have not been given the opportunity to provide the US. In this respect, it highlights that US obligations are a source of legal disputes and infringement proceedings in the European Community, referring further that the CSU financing situation is the exception and not the rule at Community level.
Therefore, according to VODAFONE, CLSU financing should be borne by public funding, not only due to the US political nature, but also to avoid the potential creation of distortions at the level of market competition, which is demonstrated by a study by Plum Consulting attached to its response, and by public burdens (information society contributions and regulation fees) which already fall on operators.
The study submitted by VODAFONE is intended to identify the measures which are required to ensure that telecommunications services are affordable to all homes in Europe.
The study considers that a tariff is affordable where it allows families with lower incomes (last decile) to make the socially required use (up to 60 minutes and 1 GB of downloads per month) through a sustainable expense (up to 4% and 6% of the family budget, respectively for the telephone service and for that service plus the broadband service), and where it helps the family to control its expenditure in telecommunications services.
The study concludes that in Portugal there are prepaid tariffs provided by mobile operators which fit the referred description of affordable tariff and which entail lower costs and a better control of expenses given the fixed tariffs. The study ends by presenting several recommendations to ensure that telecommunications services remain affordable during the next five years, stressing the termination of the traditional US obligation and its replacement for the adoption of measures that ensure the geographical availability of prepaid mobile services, especially for mobile broadband.
ZON
ZON is of the opinion that the DD under consideration are positive initiatives of ICP-ANACOM which aim to clarify a set of matters before the launch of the tendering procedure for USP designation, which in its opinion are likely to occur in 2011.
In this context it considers that tenderers will be able to know a priori the framework on the unfair burden definition and methodology for calculating CLSU, allowing a thorough evaluation of conditions associated to their potential designation as USP.
ZON stresses also that the provision of US without a tender does not guarantee that such service is provided in the most efficient manner for the market, recalling in this regard the Judgement of the CJEU on the conviction of the Portuguese State. In this context, ZON takes the view that, pending the launch of the tendering procedure and subsequent US designation, any CLSU should not be borne by other electronic communications operators, but by ICP-ANACOM’s net budget results, and limited thereto.
B. ICP-ANACOM's view
Most bodies that responded to the public consultations welcome ICP-ANACOM’s initiative, given the need to implement the methodology for calculating CLSU and the definition of unfair burden. However, various complaints have been raised and some alterations to the presented conceptual approaches have been suggested, which shall be dealt with in the specific comments chapter.
Several issues have also been referred related to the process of USP designation and the Judgement of the CJEU which declared the infringement by the Portuguese State of provisions laid down in Directive 2002/22/EC on USP designation, as well as to the CLSU financing mechanism, on which ICP-ANACOM makes the following considerations:
- Issues in question - USP designation, promotion of CLSU compensation via a financing mechanisms and respective distribution of costs - are within the sphere of responsibilities of the Government, under respectively articles 99 and 97 of the ECL, thus ICP-ANACOM is not entitled to take decisions on such matters;
- Under the current legal framework, it is incumbent upon ICP-ANACOM, in this matter, to define the notion of unfair burden and to calculate CLSU, where the Authority takes the view that they may constitute an unfair burden (article 95 of ECL) and, under Decree-Law number 458/99, of 5 November, to promote the audit and approval of negative margins presented by the USP and their possible compensation, if any, and where justified, for the period before 2004. With the DD under discussion, ICP-ANACOM thus intends to comply with responsibilities assigned to it by law, and legally there is no framework to be considered, nor to draw conclusions from, as regards how the USP was designated or the respective consequences;
- In ICP-ANACOM's view, the referred matters are beyond its powers, and respondents that raised these issues, if they so wish, are certainly entitled to find answers in a different and appropriate fora;
- In this occasion it is clarified that ICP-ANACOM submitted the DD on the definition of unfair burden and methodology for calculating CLSU to the prior hearing of all providers of electronic communications networks and services, including PTC;
- As far as lateral issues are concerned, it is also important to stress that obligations referred by VODAFONE to be borne with the Information Society, regulation fees and several investments, namely next generation networks, are of no relevance to the determination of CLSU nor to the definition of unfair burden, having that company failed to give a valid causal link between such obligations and the matter under discussion.
As regards the concerns and suggestions put forward by CABOVISÃO, OPTIMUS, VODAFONE and ZON, on CLSU financing within the scope of the designation of a new USP, ICP-ANACOM clarifies that the CLSU calculation to be performed following the approval of the decision on the respective methodology will not necessarily have any implications in the identification of the financing proposed by the new USP(s), nor a similar methodology will have to be followed, in the light of paragraph 1b) of article 95.
Note that the provision under consideration provides for two different procedures for CLSU calculation, in which the first approaches CLSU calculation taking into account any additional market advantages for providers, and the second resorts to CLSU identified in the scope of a USP designation mechanism.
As soon as new USP(s) are designated, ICP-ANACOM intends to use the possibility conferred by article 95 of ECL, which corresponds to the second procedure referred to in the preceding paragraph, to consider the value proposed by entities designated as USP in the scope of the tender as the relevant instrument for determining CLSU. In any case, this is a question which will only be decided in the scope of the procedure for designation of the new USP(s).
Note in this respect the document of the Body of European Regulators for Electronic Communications (BEREC) on US 3, which underlines the rationale of using the value presented in the scope of a USP designation procedure as an unfair burden, without requiring that value to be validated:
"The issue is highly debatable, as it appears that the USD imposes verification requirements (i.e. concerning the accounts and/or other information serving as the basis for the calculation of the net cost) only in connection with the use of the net cost calculation method provided under Article 12(1) (a) and not in relation to the use of the method under Article 12(1) (b). Indeed, the second method, when it is based on a public tender procedure, inherently contains important guarantees of cost-effectiveness and objectivity by its competitive character. An ex post verification mechanism would introduce a degree of uncertainty for the candidates that risks undermining the attractiveness of the public tender with the effect of reduced participation of market players in such procedures.
Also, it would completely eliminate the benefit of reduced administrative costs, which is an important advantage of the method under Article 12(1) (b) over the method under Article 12(1) (a).
The downside of no ex post verification could be that when for other reasons there is limited competition in a public tender procedure, the net cost resulted from the tender entails a certain amount of risk of being inefficient. A definite solution to this dilemma would require a clarification of the USD provisions which should strike a balance between the identified risks, in an attempt to maximise the cost-effectiveness of the USO".
On the alleged failure to review US obligations referred by VODAFONE, although article 86 of ECL provides that "the scope of the universal service shall evolve in line with advances in technology, market developments and changes in user demand, which scope shall be modified where justified by such evolution", it is important to stress that the same ECL explicitly defines the minimum set of provisions which must integrate the US scope, namely including an explicit reference to the fixed nature of the service.
Notwithstanding the fact that its scope remained unchanged over the years during which the ECL has been in force, and previously under Decree-Law number 458/99 of 5 November, US obligations have been subject to several adjustments/reviews, namely as regards aspects related to price affordability, several US provisions, and provision of options or tariff packages different from those provided under normal commercial conditions, as far as FTS is concerned.
Moreover, in February 2008 a public consultation was launched on the procedure for USP designation 4, in the scope of which interested parties had the opportunity to provide their views, among other issues, on whether there were grounds for an USP designation and on minimum provisions which should integrate the US. It should be noted that, except for VODAFONE, all other respondents considered at the time that an USP should continue to exist for the minimum set of provisions which currently integrate the US.
Meanwhile, on 23.03.2011, a public consultation procedure was also launched on the public pay-phones component of the universal service provision 5, the respective response deadline having expired on 20.04.2011.
In this respect also it should be stated that in most EU countries, the US scope is basically the same, and its review, just as in Portugal, has only recently become more acute, further to the publication of the new regulatory package.
Without prejudice to the above, it must be underlined that the procedure now under consideration does not focus on the US scope, or on the designation of a provider to guarantee it, which are issues which should be dealt with elsewhere.
ICP-ANACOM entirely rejects PTC’s allegations according to which underlying the methodology for calculating CLSU and the definition of unfair burden is a concern to reduce the amount of compensation to which PTC believes it is entitled.
ICP-ANACOM wishes to define a methodology and a notion of unfair burden according to criteria considered to be objective, transparent, proportional and reasonable, followed broadly by other regulators, and which are duly justified for reasons which do not relate at all with any indiscriminate reductions of CLSU values.
Relatively to the considerations of CLSU value per capita and possible range positions, as well as other considerations in internal memos, it should be referred that the analysis carried out by ICP-ANACOM’s services was subject to several approaches, which evolved over time, and which not only reflect the complexity of this matter, but also the degree of internal discussion and maturity which this issue deserved.
Accordingly, documents submitted to public consultation reflect the approach which was deemed to be the most appropriate in the scope of a DD, having been privileged the adoption of an objective notion of unfair burden and a concrete methodology for calculating CLSU.
At no time was ICP-ANACOM willing to impair the transparency and justification of the process, as stated by PTC, on account of its urgency. In fact, if this Authority had been mainly driven by the worry about urgency, a decision would already have been taken on the subject, to the detriment, if so, of its reasoning.
PTC’s statements on not accepting the regulator’s explanations on elements deemed to be confidential are quite surprising, given that a full copy of the whole process was delivered, with around 6600 pages, of which only two paragraphs and a footnote remained confidential, which are part of an internal memo of ICP-ANACOM related to the provision of advice to the Government, and a proposal for collaboration handed by a consultancy company to ICP-ANACOM which failed to be selected, which considered the matter to be confidential. Anyway, this subject has been replied to and dealt with in the appropriate fora.
As to CABOVISÃO’s statements on information considered to be confidential, ICP-ANACOM clarifies that in this process such data refers mainly to cost/benefit estimates presented by PTC which were not accepted by ICP-ANACOM, which do not affect in any way the discussion of the methodology for calculating CLSU and the discussion of the notion of unfair burden, therefore the Authority is of the opinion that it has no bearing on the assessment of the matter by interested parties.
As regards the 60-day time-limit for submitting data for CLSU preliminary calculation, deemed by PTC not to be proportional nor reasonable, given the detail and extent of requested information, ICP-ANACOM, in view of the arguments put forward, accepts an extension up to 90 days, which may extended by a maximum of 180 days, in case due justifications are presented and accepted. ICP-ANACOM agrees that there are advantages if this time limit coincides with the deadline for selecting the bodies which will carry out the audit of accounts and information provided by PTC for the purpose of CLSU calculation, and this will be taken into due account within the award process. Further to this award, the field work will take place, and ICP-ANACOM is not able to anticipate its date of conclusion, given the specificity of the work under consideration, which depends on the interaction to be established with the USP and the provision of information. In any case, after the work reaches an end, ICP-ANACOM expects to con
clude the auditing process of accounts and information provided by PTC within 180 days.
ICP-ANACOM will in due time consider the procedures, namely as far as schedule is concerned, for any audits deemed to be required, if and when PTC presents information on the application of the methodology for 2001 to 2003.
1 EBITDA stands for earnings before interests, depreciations and amortizations.
2 A new broadband wireless system resulting from the evolution of 2G and 3G systems, whose technical specifications were developed within 3GPP (3rd Generation Partnership Project).
3 Available at BEREC Report on Universal Service - reflections for the future, June 2010http://berec.europa.eu/doc/berec/bor_10_35_US.pdf.
4 Available at Procedure for the designation of the providers of the universal servicehttps://www.anacom.pt/render.jsp?contentId=661839.
5 Available at Consultation on public pay phone serviceshttps://www.anacom.pt/render.jsp?contentId=1079932.
