According to the methodology for calculation of CLSU, the calculation of costs associated to public payphones takes only into consideration unprofitable public payphones in profitable areas, given that costs associated to public payphones in unprofitable areas are integrated in the component of FTS access. Notwithstanding, in the scope of amendments to the establishment of 2014 CLSU, it was determined, as already referred in chapter 3.3, that in the scope of results of unprofitable areas, the FTS and PPP offers would be calculated in separate, as these costs must be autonomized. After components are calculated, the proportion of each in the net cost associated to unprofitable areas is then determined, this proportion being applied to broad results of the “area model” obtained in the calculation of unprofitable areas (costs up to 31.05.2014). Subsequently, a pro-rata is performed to determine PPP costs in unprofitable areas, taking into account the period up to which MEO was the PPP USP prior to the tender designation (08.04.2014). This issue was dealt with in chapter 3.3.
It is noted that the methodology used to determine CLSU of PPP is also based (just like the method used to obtain costs for the FTS) on the establishment of avoidable costs and lost revenues, unprofitable public payphones being deemed to be those the avoidable access costs of which exceed lost revenues.
It must be referred that in the scope of the decision on the methodology for calculating 2014 CLSU, ANACOM determined, as regards the public pay-phone model (costs of unprofitable PPP in profitable areas), that no alterations were required, whereby results obtained using that model should be fully allocated to that component.
AXON’s Audit Report
Auditors concluded, in the audit report, that the approach followed by MEO was consistent with the methodology determined by ANACOM, a conclusion which was restated in the audit to results resubmitted by MEO.
Notwithstanding, recommendations were made as regards the reconciliation of traffic and revenue volumes considered in the calculation of CLSU with values in the CAS, an issue which will be dealt with below in section 3.6.
In addition, AXON found a calculation error in the public payphone model. Auditors noted that MEO, in estimates presented on 30.10.2015, considered in the public payphone model a 12-month time frame, when a five-month period should have been considered. Auditors recommended the correction of this situation, and confirmed that it was corrected both in results resubmitted on 27.01.2016 and those conveyed on 06.05.2016.
MEO comments
In its comments to the audit report, MEO acknowledged the mistake identified by auditors at the level of the time frame considered, and mentioned that it rectified that situation in the calculation of CLSU for 2014 sent on 27.01.2016.
It identified in addition a mistake in the audit report at the level of the value concerning the margin of unprofitable public payphones in profitable areas in a paragraph of chapter 6.1. Overview of results.
Line taken by ANACOM
In the light of the conclusion presented by AXON on the consistency of the approach followed by MEO with the methodology defined by ANACOM, it is deemed that the process followed is in accordance with ANACOM’s determinations.
As regards the calculation mistake identified by auditors, estimates resubmitted by MEO reflect the implementation of the recommendation made by AXON to correct it, which auditors confirmed in the audit report, thus ANACOM takes the view that identified issues, in this context, have been overcome.
Lastly, in respect of the mistake identified by MEO in the audit report, it is clarified that the value in the paragraph concerned did not correspond to the value of the margin of unprofitable public payphones in profitable areas and, as such, AXON corrected this situation in the final report on 2014 CLSU.
