4. ICP-ANACOM's assessment of the audit results


Given the results of the audit conducted by AXON, which concluded that, with the exception of some deviations with respect to the data from the SCA and the data considered in the calculation of CLSU, the values re-submitted by PTC on 28.06.2013 are in accordance with the principles, criteria and conditions stipulated by ICP-ANACOM, it was deemed by ICP-ANACOM that the audit process did not give rise to any new situation as regards the re-submitted CLSU estimates presented by PTC.

It is noted that the aspects identified with respect to the reconciliation of traffic and revenue data correspond to a situation already reported in the previous audit report; the auditors maintained their view that this may have had the effect of undervaluing the final value of the CLSU, and they also stated that, notwithstanding the situations mentioned, the explanations given by the PTC on the matter, which also appear in the previous audit report, are acceptable as regards 2007-2009.

It is also noted that it was concluded by the auditors that ICP-ANACOM's stipulation of 20.06.2013 was correctly implemented by PTC.

Furthermore, note is made of the determinations imposed pursuant to the decision of 20.06.2013 as regards: (i) the annualisation of non-recurring costs/revenues related to installations, whose impact, in terms of reducing the value of the CLSU for the 2007-2009 period, was estimated at approximately 3.5 million euros, (ii) the correction of the number of access lines in the area model, which is indicated as having a negligible impact on the value of the CLSU, and (iii) alterations in the final results of the SCA, the impact of which had not been estimated, having a considerable effect on the final value of the CLSU, providing for an overall reduction in the 2007-2009 period of 6.7 million euros, i.e., to the order of 9 percent.

Finally, it is noted that, compared to the CLSU values originally notified by PTC (on 28.11.2011), there has been a total reduction of 12.8 million euros for the whole period, representing a decrease in the CLSU of 16 percent.

The following chapter presents the values of the CLSU and details the respective analysis.