According to the terms of the contract concluded with SVP, this company, together with Grant Thornton & Associados, SROC, Lda.1, having concluded the field work, and on the basis of the information collected and the assessment carried out in the meantime, prepared a preliminary report which was submitted to PTC for comments. The latter was requested to present new USNC estimates for the financial period under consideration, so as to reflect the recommendations set out by the auditor, although the referred recommendations had not yet been validated by ICP-ANACOM.
On 19.02.2013, PTC submitted its comments to SVP's preliminary report and new USNC estimates for the 2007-2009 financial period, referring that corrections identified by SVP had been made and recommendations put forward had been followed, apart from the one concerning the treatment of one-off installation costs (and respective revenues) for the calculation of USNC of unprofitable customers.
Subsequently to the submission by PTC of comments and of new USNC estimates, SVP concluded its audit and submitted the respective final report, taking into account the referred comments to the preliminary version of the report and the impact estimate drawn up, which includes, inter alia, the description of the work carried out and conclusions and recommendations resulting from the methodological revision and audit work, deemed by auditors to be appropriate.
SVP highlights that the audit work takes as input the cost accounting system (CAS) data presented by PTC for 2007, 2008 and 2090, and that any amendments to the CAS, required due to ongoing audits to the CAS, which are likely to alter the results of services, are not taken into account.
SVP concluded that "in general, results and calculations revised by PTC comply with principles, criteria and conditions laid down in ANACOM's determinations, and data, assumptions and calculations used are adequate enough". However, three aspects were excluded from the referred conclusion, which were qualified as "minor issues with negligible impact on results", and concerned "unit access cost per line" for residential customers, the calculation of "number of access lines" and input data for public pay-phones (which are analysed below) and a situation which is deemed to have a material impact on results, concerning the treatment of one-off costs and revenues for unprofitable customers living in profitable areas. Nevertheless, as regards this situation, which is assessed below, without prejudice to considerations presented by SVP in the audit report, the company agrees that "in general, PTC's approach is not contrary to determinations issued by ANACOM".
Table 1 shows the USNC results for 2007-2009 presented originally by PTC on 28.11.2011, as well as figures recalculated by PTC on 19.02.2013, following SVP's preliminary report, integrating already the impact of ICP-ANACOM's determination of 12.10.2012.
|
|
2007 |
2008 |
2009 |
Three-Year Total |
||||||||
|
Ori |
Recal |
Δ |
Ori |
Recal |
Δ |
Ori |
Recal |
Δ |
Ori |
Recal |
Δ |
|
|
Lost revenue of |
7,7 |
10,4 |
36% |
6,8 |
9,1 |
33% |
6,1 |
8,1 |
31% |
20,6 |
27,6 |
34% |
|
Lost revenue of |
43,0 |
33,7 |
-22% |
23,0 |
19,3 |
-16% |
46,0 |
31,5 |
-31% |
112,0 |
84,6 |
-24% |
|
Lost revenue of |
3,8 |
6,4 |
67% |
2,9 |
8,1 |
178% |
3,3 |
8,9 |
166% |
10,1 |
23,4 |
132% |
|
Total lost revenue |
54,5 |
50,6 |
-7% |
32,7 |
36,5 |
12% |
55,5 |
48,5 |
-13% |
142,7 |
135,6 |
-5% |
|
Avoidable costs of |
10,6 |
13,6 |
29% |
8,4 |
10,7 |
28% |
7,9 |
9,9 |
25% |
26,9 |
34,2 |
27% |
|
Avoidable costs of |
56,4 |
43,9 |
-22% |
30,6 |
25,7 |
-16% |
60,1 |
41,7 |
-31% |
147,2 |
111,4 |
-24% |
|
Avoidable costs of |
7,3 |
11,1 |
51% |
5,8 |
12,3 |
114% |
6,5 |
13,7 |
110% |
19,6 |
37,1 |
89% |
|
Revenues not |
16,2 |
15,2 |
-6% |
14,3 |
14,3 |
0% |
12,9 |
12,9 |
0% |
43,5 |
42,5 |
-2% |
|
Total avoidable |
90,5 |
83,8 |
-7% |
59,1 |
63,1 |
7% |
87,5 |
78,3 |
-11% |
237,2 |
225,2 |
-5% |
|
Total USNC of |
2,9 |
3,2 |
10% |
1,6 |
1,7 |
5% |
1,8 |
1,8 |
2% |
6,2 |
6,6 |
6% |
|
Total USNC of |
13,4 |
10,2 |
-24% |
7,6 |
6,4 |
-16% |
14,2 |
10,2 |
-28% |
35,2 |
26,8 |
-24% |
|
Total USNC of |
3,5 |
4,6 |
33% |
2,8 |
4,2 |
48% |
3,2 |
4,9 |
53% |
9,5 |
13,7 |
44% |
|
Discounts provided |
16,2 |
15,2 |
-6% |
14,3 |
14,3 |
0% |
12,9 |
12,9 |
0% |
43,5 |
42,5 |
-2% |
|
Total USNC before |
36,0 |
33,2 |
-8% |
26,4 |
26,6 |
1% |
32,1 |
29,8 |
-7% |
94,5 |
89,6 |
-5% |
|
Indirect benefits |
7,8 |
7,1 |
-9% |
4,3 |
4,4 |
2% |
2,7 |
4,7 |
73% |
14,9 |
16,2 |
9% |
|
Total USNC after |
28,2 |
26,1 |
-7% |
22,0 |
22,2 |
0% |
29,4 |
25,2 |
-14% |
79,6 |
73,5 |
-8% |
Source: PTC and ICP-ANACOM calculations. Figures in million euro.
As can be seen from the table above, as a result of the audit, USNC estimates for the 2007-2009 presented originally by PTC were altered to reflect the effect of the application of the concept of "unusually high access costs" developed in the meantime by ICP-ANACOM, as well as several corrections, and decreased by around 8%, which in absolute terms corresponds to -6.1 million euro. It is also noted that for the three-year period under consideration, figures originally calculated by PTC concerning lost revenue, the discount applied to retired persons and pensioners and overall indirect benefits were overstated and the figure for avoidable costs was understated.
1 Henceforth, only SVP will be referred to, given that it was this company that concluded the audit service contract with ICP-ANACOM.
