Process and Principles for Interconnection rates calculation by Werner Neu Arusha, 15 to 17 April 2002 Slide 0 Agenda What are Switched Interconnection Services? What should be regulated? How to set Prices Unbundling & Number Portability Slide 1 What is interconnection? (1) n n Very Very generally, generally, interconnection interconnection allows allows that that people people at at two two different different places places anywhere anywhere in in the the world world can can communicate communicate with with each each other other –– across across many many different different networks networks n n Assures Assures the the any-to-any any-to-any principle principle in in telecommunications telecommunications n n In In aa national national market market being being opened opened to to competition, competition, interconnection interconnection with with existing existing networks networks is is aa necessary necessary condition condition for for newly newly entering entering operators operators to to succeed succeed Slide 2 Basic Services n n Principal Principal services services ð ð Call Call termination termination // Call Call origination origination // Terminating Terminating access access ð ð Transit Transit services services ð ð Mobile Mobile termination termination n n Ancillary Ancillary services: services: ð ð Access Access to to Directory Directory services services ð ð Access Access to to Emergency Emergency services services ð ð Billing Billing services services Slide 3 Call Termination Termination Retail payment 0228/700-1234 Interconnection payment OLO, IC-Partner Incumbent Point of Interconnect 0228/700-1234 Handover of the call close to the destination Slide 4 Call Origination (Carrier Selection) Origination Interconnection payment 01070 0228 ... Incumbent OLO, IC-Partner Retail payment Handover of the call close to the origin Slide 5 Carrier Selection & Call Termination 01070 0228/700-1234 ... Incumbent OLO, IC-Partner Incumbent OLO 2 0228/700-1234 Slide 6 Transit Services pure transit IC-Partner 1 Incumbent IC-Partner 2 transit + termination ("cascade service") Slide 7 Fixed to Mobile and Mobile to Fixed Retail price 48 cents/ min Fixed Retail Price 34 cents/ min Mobile Mobile termination rate 38 cents/ min Mobile Fix termination rate 6 cents/ min Fixed Note: All prices shown are indicative only Generally, mobile termination rates are above fixed termination rates Slide 8 Other Interconnection Services n n Emergency Emergency Calls Calls n n Number Number Translation Translation Services Services (e.g. (e.g. Freephone, Freephone, Shared Shared Cost, Cost, Premium Premium Rate, Rate, Personal Personal Number) Number) 0800 0700 0900 n n Internet Internet Access Access n n International International Interconnection Interconnection n n Mobile Mobile Termination Termination n n Third Third Party Party Billing Billing Slide 9 Agenda What are Switched Interconnection Services? What should be regulated? How to set Prices Unbundling & Number Portability Slide 10 Numerous Regulatory Issues arise when ensuring the shared Use of Resources, the most controversial one being Pricing Shared Use of Resources Interconnection Unbundling Local Loop • P.o.I. • product scope • I. billing • pricing • IC at local level • cost standards • I. routing. .... • role of negotiations • role of regulator Other License obligations • degree • co-location • site sharing • air conditioning • fault repair, ventilation • information requests • .... • number portability • 3rd party billing • payment collection • carrier pre-selection • tariff rebalancing •.... Slide 11 www.detecon.de Which Services to be Regulated? n n General General rule: rule: Only Only those those services services shall shall be be regulated regulated which which constitute constitute an an „essential „essential facility“ facility“ n n Essential Essential facilities facilities are are basically basically characterised characterised by by the the following: following: n n They They are are essential essential for for the the interconnecting interconnecting party party to to provide provide their their services services and and n n they they can can not not be be provided provided by by any any party party besides besides the the owner owner of of the the essential essential facility facility under under reasonable reasonable terms terms (within (within reasonable reasonable time, time, under under reasonable reasonable costs). costs). Termination Termination services services generally generally qualify qualify as as such such services services Slide 12 Guidelines for Negotiations n n In In general, general, interconnection interconnection agreements agreements between between operators operators without without SMP SMP should should be be freely freely negotiable negotiable n n Nevertheless, Nevertheless, itit is is necessary necessary to to define define general general guidelines guidelines as as the the public public interest interest is is concerned concerned in in any any case case Slide 13 Guidelines for Negotiations: Interconnection Agreement n n Each Each interconnection interconnection agreement agreement shall shall contain contain mutual mutual obligations obligations and and responsibilities responsibilities to to protect protect interests interests of of users users n n Each Each operator operator should should be be required required to to negotiate negotiate in in good good faith: faith: ð ð no no intentional intentional misleading misleading ð ð no no coercion coercion into into making making an an agreement agreement ð ð no no intentional intentional obstruction obstruction Slide 14 Rights of the Regulator n n right right to to intervene intervene in in negotiations negotiations on on its its own own initiative initiative or or on on request request by by either either party party n n right right to to set set time time limits limits for for negotiations negotiations n n right right to to inspect inspect agreements agreements in in the the sphere sphere of of the the public public telecommunications telecommunications network network (PTN) (PTN) n n right right to to require require aa PTN PTN operator operator to to provide provide interconnection interconnection to to its its facilities facilities Slide 15 Guidelines for Negotiations of SMP Operators (1) n n The The SMP SMP operators operators should should be be obliged obliged to to ð ð meet meet all all reasonable reasonable requests requests for for access access to to its its network network ð ð adhere adhere to to the the principle principle of of non-discrimination non-discrimination ð ð make make available available the the agreements agreements concluded concluded to to the the MCI MCI and and on on request request to to interested interested parties parties (except (except confidential confidential parts) parts) ð ð publish publish aa standard standard interconnect interconnect offer offer Slide 16 Guidelines for Negotiations of SMP Operators (2) n n Components Components of of aa standard standard interconnect interconnect offer offer ð ð Call Call termination termination (local, (local, single-tandem, single-tandem, inter-tandem) inter-tandem) ð ð Transit Transit calls calls (single, (single, inter-tandem) inter-tandem) ð ð International International outgoing outgoing calls calls ð ð Physical Physical collocation collocation interconnect interconnect and and handover handover ð ð Customer-sited Customer-sited interconnect interconnect and and handover handover ð ð Ancillary Ancillary and and advanced advanced services, services, e.g. e.g. ð ð Operator Operator assistance assistance ð ð Directory Directory services services ð ð Emergency Emergency services services ð ð Billing Billing services services Slide 17 Reference Interconnection Offer (RIO) by Major Network Operator n n The The obligation obligation to to publish publish their their interconnection interconnection offer offer or or to to make make aa reference reference interconnection interconnection offer offer (RIO) (RIO) can can help help to to prevent prevent the the incumbent incumbent from from playing playing off off one one competitor competitor against against another. another. n n For For example, example, according according to to the the Annual Annual ITU ITU Telecommunication Telecommunication Regulatory Regulatory Survey, Survey, about about 50 50 countries countries make make interconnection interconnection agreements agreements publicly publicly available, available, such such as as Canada, Canada, over over the the internet. internet. n n Some Some mechanism mechanism should should be be in in place place to to protect protect commercial commercial confidential confidential information information in in interconnection interconnection agreements, agreements, (e.g. (e.g. confidential confidential annexes annexes can can be be separated separated out). out). Slide 18 Transparency and Information Required n n The The availability availability of of points points of of interconnection interconnection should should be be indicated indicated in in the the Reference Reference Interconnect Interconnect Agreement Agreement to to be be published published by by the the Incumbent. Incumbent. n n Regulator Regulator should should ensure ensure that that interconnection interconnection is is available available and and that that all all necessary necessary information information is is furnished furnished by by the the operator, operator, e.g. e.g. n n POI POI location location with with exchange exchange type type and and address, address, n n description description of of network network facilities facilities to to be be interconnected, interconnected, n n specific specific capacity capacity and and traffic traffic volume volume requirements, requirements, n n definition definition which which party party has has to to provide provide which which facility, facility, n n other other technical technical specifications, specifications, e.g. e.g. calling calling line line identification identification specifications specifications n n Information Information should should also also include include signalling signalling interconnection, interconnection, e.g. e.g. type type of of standard, standard, point point codes, codes, use use of of leased leased lines, lines, diagram diagram of of signalling signalling interconnection interconnection architecture architecture Slide 19 Points of Interconnection (POIs) at Any Technically Feasible Point n n General General rule: rule: incumbent incumbent shall shall permit permit interconnection interconnection at at any any technically technically feasible feasible point point :: local local switching switching level level (local (local interconnection), interconnection), tandem tandem switching switching level level (single (single tandem tandem interconnection) interconnection) and and trunk trunk connection connection (double (double tandem tandem interconnection) interconnection) n n France: France: competitors competitors required required to to establish establish aa POI POI in in each each of of the the country’s country’s 18 18 local local government government jurisdictions. jurisdictions. n n Spain Spain non-facility non-facility based based competitors competitors have have to to maintain maintain aa POI POI in in each each of of the the 52 52 provinces provinces in in which which they they originate originate traffic. traffic. n n In In Germany, Germany, competitors competitors must must open open aa new new POI POI once once their their traffic traffic at at any any existing existing POI POI exceeds exceeds aa certain certain capacity capacity threshold threshold (48,8 (48,8 Erlang) Erlang) Slide 20 Requirements for Geographic Roll-Out of POIs n n Some Some interconnection interconnection regimes regimes require require minimum minimum number number of of points points of of interconnect, interconnect, e.g. e.g. ð ð to to receive receive aa licence licence ð ð to to be be able able to to offer offer country-wide country-wide services services ð ð to to fulfill fulfill requirements requirements of of network network integrity integrity of of the the incumbent's incumbent's network network n n The The number number of of POI POI determines determines the the cost cost structure structure ð ð low low number number of of POI POI => => low low set-up set-up costs costs (for (for own own network), network), in in average average high high per-minute per-minute charges charges ð ð high high number number of of POI POI => => higher higher set-up set-up costs costs (for (for own own network, network, leased leased lines, lines, etc.), etc.), decreasing decreasing average average per-minute per-minute charges charges Slide 21 When Shall the Regulator Step in? n n Some Some countries countries favoured favoured aa policy policy of of industry industry negotiations negotiations of of interconnection interconnection agreements, agreements, operators operators may may seek seek dispute dispute regulations, regulations, ifif negotiations negotiations fail. fail. n n Growing Growing consensus: consensus: advance advance regulatory regulatory guidelines guidelines better better suited suited to to establish establish the the proper proper environment environment for for interconnection. interconnection. n n International International experiences: experiences: lack lack of of advance advance regulatory regulatory guidelines guidelines hinders hinders development development of of competition, competition, delaying delaying the the introduction introduction of of competition. competition. n n In In many many countries countries interconnect interconnect terms terms and and conditions conditions and and charges charges with with SMP SMP are are subject subject to to ex-ante ex-ante regulation regulation (approval (approval or or establishment establishment by by the the Regulator) Regulator) n n Otherwise Otherwise dominant dominant operators operators may may be be tempted tempted to to set set charges charges and and conditions conditions which which are are disadvantageous disadvantageous n n Ex-ante Ex-ante regulation regulation of of charges charges for for operators operators with with SMP SMP reduces reduces time time to to reach reach aa fair fair agreement. agreement. Slide 22 Guidelines for Dispute Resolution n n When When no no agreement agreement on on interconnection interconnection is is brought brought about, about, either either party party may may appeal appeal to to the the MCI MCI for for dispute dispute resolution. resolution. n n The The MCI MCI has has the the right right to to refuse refuse when when none none of of the the operators operators has has SMP. SMP. n n In In any any other other case case the the Regulator Regulator shall shall decide decide on on the the dispute dispute within within aa period period of of eight eight weeks. weeks. This This period period may may be be extended extended by by aa maximum maximum of of four four weeks. weeks. n n The The Regulator Regulator shall shall n n take take into into consideration consideration the the interests interests of of the the users users and and the the entrepreneurial entrepreneurial freedom freedom of of the the operators operators to to configure configure their their networks networks n n decide decide on on the the basis basis of of public public oral oral proceedings proceedings n n give give the the parties parties concerned concerned and and business business circles circles affected affected the the opportunity opportunity to to state state their their case case Slide 23 Guidelines for Dispute Resolution (2) n n The The decision decision of of the the Regulator Regulator has has to to be be substantiated substantiated and and published. published. n n The The Regulator Regulator may may backdate backdate any any determination determination to to remove remove an an incentive incentive for for delaying delaying tactics. tactics. n n The The operators operators shall shall comply comply with with the the decision decision of of the the Regulator Regulator within within aa period period not not exceeding exceeding aa predetermined predetermined period period (e.g. (e.g. 12 12 weeks). weeks). n n The The operators operators may may take take case case to to aa court court of of appeal appeal within within aa period period not not exceeding exceeding aa predetermined predetermined period period (e.g. (e.g. 44 weeks). weeks). Such Such appeal appeal shall shall not not have have suspensory suspensory effect. effect. Slide 24 Agenda What are Switched Interconnection Services? What should be regulated? How to set Prices Unbundling & Number Portability Slide 25 Methods of Determining Interconnection Charges n n Cost Cost based based ð ð Long Long Run Run Incremental Incremental Cost Cost Accounting Accounting Method Method (LRIC) (LRIC) ð ð Fully Fully Distributed Distributed Cost Cost accounting accounting methodology methodology (FDC) (FDC) n n Others Others ð ð Revenue Revenue Sharing Sharing ð ð Bill Bill and and keep keep ð ð Retail Retail minus minus ð ð Benchmarking Benchmarking Slide 26 Pricing of Interconnection - Two part structure - Transit 0800 0900 0700 Interconnect Link Interconnect Services Slide 27 Pricing of Interconnection Services - Determined by network structure international gateway tandem switching level local switching level concentrator Slide 28 Pricing of Interconnection Services - Element based charging (EBC) n n Definition Definition of of Service Service by by network network elements elements ð ð local local interconnection interconnection ð ð single single tandem tandem interconnection interconnection ð ð double double tandem tandem interconnection interconnection Slide 29 Pricing Interconnection Network Services : Based on costs from a bottom-up model Identify fundamental cost drivers of networks •coverage (geographical extent of the network) network’s capapacity to handle • traffic Cost of network components • physical items of equipment • directly related operational / maintenance costs • customers Annuitisation of costs • purchase value • cost of capital • price trend • asset life Allocation of component costs to network services • map network elements to network services via routing table • divide annualised costs by volume Cost of particular product Mark ups • operational costs • product / supply costs • common costs • externalities • customers • incoming minutes • outgoing minutes (onnet / off-net) • etc...... Slide 30 www.detecon.de Pricing Interconnection Networks Services : Determining the costs of network components number of physical units of all network elements (concentrators, local switches, single and double tandem switches, transmission links) capital and operating costs of network elements (installation etc.) capacity of network elements (busy hour erlangs, call attempts etc.) unit costs of every network element (dividing costs by traffic) Slide 31 Pricing Interconnection Network Services : Pros and cons of bottom-up LRIC models + - n suited for modelling forwardlooking (long run) costs n different views about efficient network n lack of transparency and difficult to implement n arbitrary as to determination of essential input parameters n variety of forecasting and modelling assumptions (equipment design utilisations, future asset prices, future voice and data volumes) leads to high uncertainty about results è sensitivity analyses demonstrate that, depending on the data for structural parameters, prices may vary significantly n reflects complex linkages n offers a rather detailed view of (hypothetical efficient) cost structures n no dependency on cost calculation system of the company subject to regulation n most effective when existing network structure is considered to be inefficient Slide 32 www.detecon.de Pricing Interconnection Network Services : Based on costs from a top-down model Traditional business structure is based on functional area (sales and marketing, planning, operation etc.) Product cost data not available from normal accounts systems (which is cost centre based) Need to allocate accounts-based data fully to products and services After allocation, costs are contained in 1) products, 2) network elements, 3) related functions and 4) other functions Slide 33 Top-Down Models: Implementing a suitable cost accounting system Objective Ø to follow the basic principles of cost orientation and transparency Ø to prevent discriminatory behaviour such as cross-subsidisation Requirements to dominant operator Ø keep separate accounts of § telecommunication activities and other activities § regulated and un-regulated activities § each activity that is subject to regulation Ø allocate costs, capital employed and revenue in accordance with principle of (direct or indirect) cost causation (i.e. ABC) (at least 90%) Ø clearly identify unattributable costs in a specific account Slide 34 Accounting Separation: Allocation of Costs Operating Costs Capital Costs Accounting entries Data Capture i.e. Depreciation Allocation Services Related Functions Network Components Allocating Costs of Other Functions Services Network Components Step 3 Step 2 Costs of functions not related to the provision of particular services: planning, personnel. Costs of functions necessary for the provision of services to the customer such as billing, maintenance and customer services Costs relating to the various components of transmission, switching and other network plant and systems Allocating Costs of Network Components Costs that can be directly identified with a particular (wholesale or resale) service Services Step 4 Step 1 Related Functions Network Components Allocating Costs of Related Functions Services Other Functions Allocating Costs of Services Businesses Slide 35 Top-Down Allocation of Costs product product specific specific costs: costs: i.e.billing i.e.billing all costs to be allocated operational costs support costs (i.e. PC ABC ABC analysis analysis Co fin st al po pr ols od uc to ts support costs) + network network element element costs costs + network model or routing table allocation sheet product volume data other(overhead) (overhead)costs costs other totalproduct product total costs costs product routing tables allocate via mark ups Slide 36 Activity Based Costing Principles are Fundamental to Any Top-Down Model The ABC-Model attributes resources to activities and finally to services Resources i.e personnel, building ResourceDriver Driver Resource i.e.numberofofman-hours man-hours i.e.number Activities i.e Billing ActivityDriver Driver Activity Objects i.e.number numberof ofbills bills i.e. i.e Local IC-Minute, residential customers è As to cost assignment the focus is on why and what consumes costs, rather than how to allocate costs that have already been occurred Slide 37 Interconnection Charges: Revenue Sharing n n Entrant Entrant pays pays incumbent incumbent share share of of his his revenues revenues as as compensation compensation n n Operated Operated in in countries countries with with limited limited competition competition or or protected protected monopolies, monopolies, e.g. e.g. Thailand, Thailand, Indonesia, Indonesia, China, China, Russia, Russia, Nigeria Nigeria before before privatisation. privatisation. ð ð ð ð ð ð easy easy to to implement; implement; No No further further cost cost studies studies have have to to be be made, made, payments payments can can easily easily be be calculated calculated on on the the basis basis of of call call records. records. Payments Payments are are not not connected connected to to the the costs, costs, no no indication indication whether whether the the incumbent incumbent is is overover- or or undercompensated. undercompensated. ð ð Worst Worst case: case: interconnect interconnect agreements agreements contains contains clauses clauses for for retail retail tariffs, tariffs, e.g. e.g. condition condition that that new new entrants entrants tariffs tariffs have have to to be be based based on on incumbents incumbents tariffs. tariffs. ð ð New New entrant entrant not not able able to to compete compete on on basis basis of of prices; prices; competition competition will will be be limited limited only only to to niche niche markets markets where where people people are are willing willing to to pay pay aa higher higher price, price, e.g. e.g. because because no no service service otherwise. otherwise. n n For For incumbent, incumbent, model model is is very very favourable: favourable: receives receives additional additional revenues revenues and and widens widens the the subscriber subscriber base base without without own own expenses. expenses. n n For For aa country country that that wants wants to to liberalise liberalise markets markets and and that that regards regards competition competition as as the the major major driver driver for for market market growth growth and and innovation, innovation, revenue revenue sharing sharing is is not not recommended. recommended. Slide 38 Interconnection Charges: Bill & Keep n n Simple Simple methodology: methodology: Operators Operators do do not not pay pay each each other other for for termination. termination. Bill Bill own own customers customers only only & & keeps keeps revenues. revenues. Each Each operator operator pays pays own own facilities. facilities. n n IfIf more more calls calls are are terminated terminated in in the the incumbent incumbent network, network, new new operators operators have have an an advantage advantage n n Approach Approach is is applied applied in in Canada, Canada, Mexico Mexico and and some some States States in in the the USA. USA. ð ð Simple Simple model; model; fits fits good good with with balanced balanced traffic traffic flows. flows. With With Unbalanced Unbalanced traffic traffic ð ð ð ð flows flows itit favours favours smaller smaller operators operators & & supports supports new new competitors. competitors. Recommended Recommended with with flat flat rate rate regimes regimes or or below-cost below-cost local local call call charges: charges: cost cost based based tariffs tariffs would would imply imply IC IC charges charges above above retail retail tariffs tariffs With With Unbalanced Unbalanced traffic traffic flows flows disadvatage disadvatage for for operators operators with with higher higher traffic. traffic. Bill Bill and and keep keep does does not not reflect reflect the the cost cost of of interconnection. interconnection. n n Bill Bill and and keep keep is is aa simple simple and and easy easy to to implement implement instrument. instrument. Works Works best best with with similar similar traffic traffic flows flows & & cost cost structures. structures. n n Appropriate Appropriate to to promote promote competition competition ifif retail retail tariffs tariffs are are below below cost cost or or where where flat flat rate rate are are applied, applied, e.g. e.g. for for local local calls calls or or homogeneous homogeneous data data networks. networks. Slide 39 Interconnection Charges: Retail Minus n n IC IC rates rates == retail retail tariffs tariffs minus minus xx percent. percent. Discount Discount can can reflect reflect avoided avoided cost, cost, e.g. e.g. for for billing billing or or marketing. marketing. n n Retail Retail minus minus was was used used in in US US and and Japan Japan before1995. before1995. ð ð Comparably Comparably easy easy to to calculate. calculate. Ensures Ensures compensation compensation for for interconnection interconnection ð ð ð ð ð ð ensures ensures ability ability to to compete compete also also on on prices. prices. Calculation Calculation can can never never be be exact. exact. Danger Danger of of overover- or or undercompensation. undercompensation. IfIf retail retail tariffs tariffs are are below below cost cost incumbents incumbents will will be be under-compensated. under-compensated. Retail Retail plus plus approach approach is is even even worse: worse: the the same same estimation estimation problems problems and and negative negative effects effects for for competition. competition. n n Retail Retail minus minus can can serve serve as as aa quick quick proxy proxy ifif decisions decisions have have to to be be made made quickly quickly and and for for the the transition transition period period until until information information about about interconnection interconnection costs costs are are available. available. n n Retail Retail minus minus mechanism mechanism should should not not prevail prevail for for aa longer longer time time because because of of its its weakness weakness to to assess assess the the right right amount amount of of discount discount to to be be provided. provided. Slide 40 Interconnection Charges: Benchmarking n n Applied Applied in in some some member member states states of of the the EU, EU, e.g. e.g. in in Denmark. Denmark. n n European European Commission Commission has has undertaken undertaken research research on on tariffs tariffs for for interconnection interconnection and and defined defined „best „best practice“ practice“ of of the the best best three three countries. countries. n n Member Member states states are are requested requested to to near near their their interconnection interconnection tariffs tariffs to to the the best best practice practice benchmark. benchmark. n n Benchmarking Benchmarking can can deliver deliver aa range range of of tariffs tariffs within within which which interconnection interconnection charges charges should should be be set. set. n n Can Can also also be be used used to to cross-check cross-check results results from from cost cost based based tariff tariff calculation. calculation. n n Works Works well well in in environments environments where where interconnection interconnection charges charges are are sufficiently sufficiently comparable, comparable, e.g. e.g. where where network network and and charging charging structures structures are are sufficiently sufficiently homogeneous. homogeneous. n n The The problem problem of of benchmarks benchmarks is is that that the the respective respective costs costs of of services services have have to to be be comparable. comparable. Challenge Challenge is is to to make make information information comparable comparable and and to to account account for for differences differences n n They They can can also also deliver deliver targets targets from from best best practice practice countries countries or or “worst “worst practice” practice” examples, examples, Slide 41 Interconnection Charges: Benchmarking - IC tariffs in the European Union EU: Local Termination (per minute/peak rate) EU: Single Transit (per minute/peak rate) 0.025 € 0.025 € Luxembourg 0.020 € 0.015 € 0.015 € Finland Germany Belgium 0.010 € Denmark France 0.005 € - 0.020 € Greece Austria Luxembourg Germany Netherlands Portugal Italy Ireland Spain 0.010 € Austria Belgium Greece Italy Ireland Spain France Portugal Finland Netherlands Sweden Denmark Best Practice UK Sweden Best Practice UK 0.005 € - € € EU: Double Transit (per minute/peak rate) 0.035 € Finland 0.030 € Belgium 0.025 € France Austria 0.020 € Denmark 0.015 € Spain Greece Germany Italy Ireland Best Practice Portugal Luxembourg Netherlands Sweden UK 0.010 € 0.005 € - € Slide 42