Sesión 6: La experiencia de Trinidad y Tobago
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The document discusses the development of a cost model by the Telecommunications Authority of Trinidad and Tobago (TATT) to regulate telecommunications rates. TATT developed key modeling principles in consultation with industry, such as using a top-down approach with current cost accounting and long-run average incremental costing. A cost model consultant was then hired to develop the model based on these principles. The process involved collecting cost, asset valuation, demand, and network data from operators, conducting a current cost asset revaluation study, and developing long-run incremental cost outputs and inputs.
Sesión 6: La experiencia de Trinidad y Tobago
- 1. Costing Methodologies and Model DevelopedCosting Methodologies and Model Developed by The Telecommunications Authority ofby The Telecommunications Authority of Trinidad and TobagoTrinidad and Tobago Developing a Cost Model for the Trinidad &Developing a Cost Model for the Trinidad & Tobago MarketTobago Market 66thth July 2010July 2010 Telecommunications Authority of Trinidad and TobagoTelecommunications Authority of Trinidad and Tobago Session 6 Regional Seminar on the economic and financial aspects of telecommunications Study Group 3 Regional Group for Latin America and Caribbean (SG3RG-LAC)
- 2. 2 Overview Background Rationale for a Cost Model Key Modeling Principles Considerations Approach adopted Model Development Process Issues and Challenges Questions and Answers
- 3. 3 Background TATT was established in 2004 to regulate the telecommunications and broadcasting sectors TATT began liberalising telecommunications markets in 2004: Flash-cut approach adopted Domestic fixed networks (including cable networks) and services Domestic mobile networks and services International network and services Technology neutral approach to licensing and regulation
- 4. 4 Background: Market Overview Network /Service Category Service provided Concessions granted Operators providing service International Facilities Only 2 2 Facilities and Services 9 9 Domestic Fixed Wired or Wireless Telephony 8 2 Internet 7 9 Subscription TV 8 6 Domestic Mobile All mobile services 2 2 Subscription TV (Cable) Broadcasting 8 8 Free to Air Broadcasting TV Radio 9 38 9 38
- 5. Rationale for a Cost Model Telecommunications Act and Regulations require that: all concessionaires establish interconnection rates on a cost basis as prescribed by TATT where commercial negotiations fail between concessionaires and a dispute is filed, TATT may set interconnection rates in accordance with an established cost methodology TATT may regulate rates for access to any facility (not including interconnection) in accordance with an established cost methodology
- 6. 6 Rationale for a Cost Model Detecting unfair cross-subsidies or anti-competitive pricing Setting interconnection rates Resolving interconnection disputes Setting rates for access Need for robust fixed and mobile cost models Calculation of access deficit/surplus of fixed network As TATT has increasingly liberalised the market the number of competition and regulatory issues has increased. An independent purpose-built (vs. off the shelf) cost model is necessary to inform TATT regulation. Setting rates for SMP operators
- 7. TATT’s Approach Model developed with participation of industry Outputs to be used when regulatory intervention is required Methodology (Key Modeling Principles) established in consultation with industry Consultants hired to develop model in accordance with methodology
- 8. 8 Overall Timeframes Model developed with participation of industry Results available and outputs to be used when regulatory intervention is required Methodology (Key Modeling Principles) established in consultation with industry Consultants hired to develop model in accordance with methodology Dec ‘06 – May ‘08 Oct ‘08 – April ‘09 April ‘09 – Sept ‘10 Oct ’10 onwards
- 10. Key Modeling Principles Cost accounting approach Modeling approach Depreciation method Current cost accounting (CCA) long run average incremental cost (LRAIC) Assets to be re-valued on a CCA basis Fully depreciated assets to be excluded Top down Tilted straight line Efficiency considerations Joint and common costs Rate of return on capital Cost Exclusions Asset Revaluation - Indexation preferred Efficiency adjustment within model Recover as equi-proportionate mark-up (EPMU) over incremental costs WACC applied to mean capital employed (MCE) Network externality No mark-up permitted The model will be used to estimate efficiently incurred costs for regulatory purposes TATT set out a number of modeling principles in its methodology:
- 11. Historical Cost Accounting (HCA) Current Cost Accounting (CCA) Strengths Strong Audit trail to existing audited accounts Ensures that operators recover their actual incurred costs Provides a proxy for economic costs Weaknesses Little relevance to investment decisions today Reflects operational inefficiencies Requires time and investment to complete a full re-evaluation of assets 11 Key Modeling Principles Considerations To ensure economically efficient investment decisions by potential market entrants If telecommunications services’ prices are set below current costs then inefficient entry will be encouraged and/or there will be insufficient investment in alternative infrastructure If telecommunications services are priced above current costs then there will be insufficient entry and/or over-investment in alternative infrastructure will be encouraged Cost Accounting Approach - CCA
- 12. 1212 Key Modeling Principles Considerations Cost Accounting Approach - LRAIC Using LRIC, prices are based on the costs avoided if an increment of output is no longer required – e.g. if an operator were no longer to provide a service The approach adopted by most regulators is known as Long Run Average Incremental Cost (LRAIC) or, synonymously, Total Service Long Run Incremental Cost (TSLRIC). LRAIC is attractive to regulators because it accounts for all the costs associated with an entire service (including fixed and common costs) as opposed to ‘pure’ LRIC which only assesses costs incremental to the service. LRAIC also allows costs to be determined without building complex cost-volume relationships for individual network assets. Fully Allocated Costs (FAC) Long Run Incremental Costs (LRIC) Strengths Can be used with either HCA or CCA Based on reconcilable and readily available information Ensures recovery of all costs Provides economically efficient pricing decisions for investment decisions Weaknesses No accounting for potential efficiency gains Does not reflect the economic cost of providing the service Requires current cost accounting Requires assessment of cost volume relationships which can be complex
- 13. Bottom-Up Top- Down Strengths Minimum Cooperation needed from incumbent Accounts for theoretical operational efficiency Avoids data confidentiality problems Based on actual costs Accounts for cost details Provides strong audit trail Weaknesses Little resemblance to actual costs Poor transparency; hard to authenticate Can’t deal with operational costs Substantial investment required Cannot take full account of potential efficiency improvements Substantial upfront investment required Data Sources and confidentiality 131313 Key Modeling Principles Considerations Modelling Approach - Top-Down Top Down model would provide results that would be easier to validate, particularly in the event of legal challenges to regulatory decisions Although bottom up models account for theoretical operational efficiency, a top down model using CCA will provide a good proxy to efficient costs
- 14. 14141414 Key Modeling Principles Considerations Depreciation Method- Tilted Straight Line Two main approximations to economic depreciation: tilted straight line vs. tilted annuity Tilted straight line depreciation allows for the forward-loading of straight line depreciation to precisely the extent justified by the average annual decline in asset prices. In other words it requires the adjustment of HCA straight line depreciation to reflect the current replacement cost of the asset Tilted annuity depreciation likewise tilts the basic annuity calculation (in which the total capital charge, equal to depreciation plus return on capital, is held constant throughout an asset's lifetime) The tilted annuity approach is commonplace in bottom-up cost models, because bottom-up models tend to work on the assumption that the network is redesigned each year to be efficient for the subscriber and traffic requirements of that year In a top-down model there is no such reason to prefer the tilted annuity approach.
- 15. 1515151515 Key Modeling Principles Profile of different depreciation accounting methods Depreciation Method- Tilted Straight Line The tilted straight line profile is closest to the economic depreciation profile. Asset Life
- 16. 16 HCA as a Proxy Modern Equivalent Asset (MEA) Direct Indexation Strengths Not as burdensome as CCA valuations Can be used when the asset is no longer available for purchase or technology is outdated. Considered to be robust Detailed information on the quantity and specification of assets is not required Weaknesses Can produce inefficient results Difficult to compensate for the potential differences in operating costs of, and functionality between, the MEA and the existing asset. Implementation can be resource intensive. Information on quantity and price of assets in FAR needed. Info typically found in independent databases resulting in no direct link between the valuation and the FAR. Still requires from FAR: age profile of all assets in a given asset class, split between individual cost elements. Reliable price indices may not be available. 161616 Key Modeling Principles Considerations Asset Revaluation – Indexation as preferred method Indexation is appropriate for assets where there has been little technological change and all direct costs incurred and capatilised to date would be incurred if the asset were replaced today There are particular asset classes where a reliable price index is not available and cannot be constructed There are therefore specific circumstances under which alternative revaluation approaches may be required
- 17. 1717 Alternative Valuation Approach Criteria Direct Valuation Where suitable price indices do not exist BUT where information on unit replacement costs and asset quantities are available MEA Valuation Where assets are no longer available for purchase or the technology of the existing asset is outdated HCA Valuation Proxy Where , the asset is relatively new and there are no expectations that the value will change; OR the asset has a relatively short life; OR the asset does not contribute materially to the overall value of the asset base. 171717 Key Modeling Principles Criteria for Choice of Alternative Valuation Approach
- 18. 181818181818 Key Modeling Principles Efficiency Adjustments The LRAIC Model should reflect the forward looking costs that are efficiently incurred in the provision of services. As a result the following may be adjusted or excluded where the Authority considers it appropriate : Sunk Costs Stranded Assets Fully Depreciated Assets The above costs must be provided on an HCA basis to allow for re-conciliation of CCA outputs with statutory accounts. An efficiency study will also be conducted.
- 19. 1919191919 Key Modeling Principles Calculating the return that an operator must be expected to earn Cost of Capital - WACC The cost of capital is typically measured using a weighted average cost of capital (WACC) and includes both the cost of equity and debt finance, weighted by the assumed debt to equity ratio for a company. Calculating the Cost of Equity: Capital asset pricing method (CAPM) re = rf + β x (rm - rf) Where: re is the cost of equity; rf is the risk-free rate; β (beta) is the measure of relative risk of the relevant assets; and rm is the expected return on the equity market. The difference between the market return and the risk-free rate is known as the equity risk premium (ERP).
- 20. 202020202020 Key Modeling Principles CAPM: Considerations and Assumptions Cost of Capital - WACC CAPM is a simple and transparent method. Estimations to be used for CAPM: rf : the return on benchmark risk free government securities such as US government bonds. β : based on information on the calculated beta for a sample of comparable operators in other jurisdictions. Note: Concessionaires are not publicly listed so it will not be possible to directly estimate the beta for any of the concessionaires. ERP: US Based Estimates In order to reflect any greater perceived risk of investing in Trinidad and Tobago, for example due to currency exchange risks, it may be appropriate to add a country specific risk premium to the estimated cost of equity.
- 21. 21212121212121 Key Modeling Principles The Cost of Debt: Considerations Cost of Capital - WACC Calculating the Cost of Debt The Authority will consider the debt premium by observing the actual cost of debt of comparator telecoms companies. In making this comparison, the following factors will be taken into account: the size, credit rating and gearing levels of the comparator firms; the maturity of debt held by comparators; the time period over which the debt premium is calculated; any country specific risk premium; decisions on the debt premium made by other telecoms regulators; and available information on the optimal debt to equity ratio.
- 22. 2222222222222222 Key Modeling Principles Other Considerations Cost of Capital - WACC Decisions yet to be made in consultation with industry Should there be: One industry WACC; Concessionaire specific WACCs; or Market specific WACCs? Factors to consider include: the extent to which different concessionaires face different risks; the extent to which different markets are subject to different risks given differences in the demand, cost and technology characteristics; the impact on the incentives of concessionaires to invest; the feasibility of estimating separate WACCs for each concessionaire will be limited by data availability. Data availability for T&T is limited and the estimation is likely to rely on a significant amount of benchmark data.
- 23. 232323232323 Key Modeling Principles Calculating Joint and Common Costs - EPMU Fixed common and joint costs between increments are recovered by use of an EPMU (Equi- proportionate Mark-up), whereby fixed common costs are recovered pro rata to incremental costs. The model will calculate common costs for subsets of increments, (such as the network) on a cost category by cost category basis as set out below: For each LRAIC cost category the sum of component incremental costs (where each component is removed in turn) is compared to the incremental cost for the subset of components as a whole (where all components are removed at once). The difference between these two sets of costs is the fixed common and joint costs across these increments for this cost category. These common costs to the subset of components are then allocated to the components using an EPMU approach.
- 24. 24 The Model Development Process
- 25. 25 Overview of Modeling Process Data Requirements CCA Revaluation Study LRAIC Model Outputs LRAIC Model Inputs
- 26. 26262626262626262626 Data Requirements Economic costing Incremental costing Reporting i. Data on operating costs categorised by ‘LRAIC cost categories’ ii. CCA asset valuations iii. CCA depreciation iv. Historic and forecast demand v. Balance sheet information (working capital) i. Data on cost drivers and cost dependencies i. Volume data ii. Routing factors Role of Operators: To provide inputs into each stage of the model development process to ensure that the model results reflect the underlying operating conditions in Trinidad and Tobago.
- 27. 2727272727272727272727 Data Requirements Economic Costing Information Description of data required Possible sources Data on operating costs categorised according to ‘LRAIC cost categories’ CCA asset valuations for various asset groups Balance sheet items Revaluation Study Activity based costing (ABC) studies that may have been conducted in the past Asset register Financial management information Purchasing orders
- 28. 282828282828282828282828 Data Requirements Incremental Costing Information Description of data required Possible sources Data on how costs vary as different service volumes change Data on how the cost of one cost category can impact other cost categories (such as how the number of call minutes drives the number of switches which in turn drives building space requirements which in turn drives maintenance costs and therefore HR costs) Engineering rules underlying the network and capacity constraints on network elements Financial management information Network engineers that understand the dimensioning of the network and/or that work in network planning ABC studies if available of management estimates
- 29. 292929292929292929292929 Data Requirements Reporting Information (Routing Factors) Description of data required Possible sources Traffic data Data on how individual services make use of the network such as how calls are routed over the network Diagram of network topology Billing systems (retail and wholesale) Network planning engineers
- 30. 30 CCA Revaluation Study Review asset register and categorise assets Calculate the GRC for each asset category Calculate CCA depreciation charges and net replacement costs Step 1 Step 2 Step 3 Reconciliation of outputs to inputs and statutory accounts Step 4
- 31. 31 Stage Role of TATT Role of concessionaire Initial review of data availability Ascertain level and nature of data already collected by concessionaires for day to day commercial and regulatory purposes Respond to requests for high level information Issue of detailed data request Issue CCA reference paper that sets out the requirements for the CCA study and reflects the level of data available, the time scale for data collection and the LRAIC model requirements Seek clarification on any aspects of the data request not fully understood Submission of initial CCA results Review CCA data as it is submitted Request clarification of data submitted where necessary Provide clarification of data requested as required by operators Assist operators in methodological issues and identifying potential data sources Submit data as it becomes available and before the deadline for data submission Provide clarification/validation of data requested as required within a reasonable time period Submission of final version of CCA data Submit final version of CCA data and full documentation of methodology, sources and results Input data submitted into LRAIC model Input data into LRAIC model and sense check the outputs Provide clarification where necessary Overview of CCA Data Collection Process
- 32. 32 LRAIC Model Outputs Services covered Time periods Format of output Fixed network On-net calls, off-net calls and call termination Line rental (access) Internet, Data services Leased lines (point to point transmission) Mobile network On-net calls, off-net calls and call termination Roaming SMS and packet data services Based on historic data Annual data Separate outputs for concessionaires Total and unit costs in nominal TTD and USD
- 33. 3333 LRAIC Model Outputs Other Applications Other Requirements Ex-post competition cases (e.g. predatory pricing) Access Deficit calculations The model further needs to take into account any unregulated services that: •are provided over the same infrastructure as the above; and •share common cost with the above services. As the market develops the structure of the relevant markets may evolve. Thus the model should reflect a forward looking view of networks, as far as this is possible and proportionate. It should be noted that the market definitions are technology neutral. However for the purposes of service costing, the model will not explicitly produce separate costs for services using differing technology. Given that the nature and scope of ex post competition investigations cannot be defined in advance, the LRAIC model developed will need to be flexible enough to provide input to the process for any services or markets required.
- 34. 34 Cost Categories To group cost information together into a LRAIC cost category: costs must share the same driver costs must have the same dependencies Eight (8) groups of LRAIC cost categories: network components; network infrastructure and support equipment (e.g. network power equipment) non-network assets (e.g. office furniture, billing systems) network activities (including network maintenance) product management (e.g interconnect product management) support activities (e.g. HR and finance department costs) direct costs, cost of sales, and so on (e.g. interconnection out payments) balance sheet items.
- 35. 35 LRAIC Model Inputs The LRAIC model requires the following key inputs: Base cost information • operating expenditure, direct costs, cost of sales, depreciation, capital employed Cost of capital LRAIC cost categories Cost drivers CVRs Hierarchy of dependencies Increment specific fixed and common costs (ISFC)
- 37. 37 Issues and Challenges to date Stage Concerns and /or Challenges Faced Solution Could have been avoided by: Pre Model Development Unable to set cost based rates using an independent model (e.g. interconnection) Limited regulatory resources Benchmarking, although it is difficult to acquire cost-based benchmarking data Training of staff Prioritising establishment of a cost model pre- liberalisation Establishing Model Principles Had to be done in consultation with industry in accordance with consultation procedures, therefore time consuming (approx. 2 yrs). Difficult to agree on basic principles Limited regulatory resources Limiting consultation periods as far as possible (written, face- to-face). Limiting consultation to only basic principles. Benchmarking with other jurisdictions (careful analysis of local circumstances) Training of Staff Establishing key principles in legislation – pre-liberalisation Combining consultation on principles with development of model as one project (although this may have presented different challenges).
- 38. 3838 Issues and Challenges to date Stage Concerns and /or Challenges Faced Solution Could have been avoided by: Selecting a Suitable Consultant Allocating enough funds Getting the best value for money Ensuring that actual project team are experts in cost model development Benchmarking costs (based on required model functionality), although this information may not always be readily available. Widespread advertisements (locally, internationally recognized periodicals) Requiring references in proposals. Soliciting and evaluating reference feedback. Including consultants proposed project team as a contractual obligation. Establishing approval process for replacements where this may be unavoidable Still to be tested.
- 39. 3939 Issues and Challenges to date Stage Concerns and /or Challenges Faced Solution Could have been avoided by: Data Collection Process Resource intensive for concessionaires, particularly smaller ones. Delays due to late data submissions. Allocating enough time in project plan. Providing data templates. Issuing initial data request at very beginning of project and having face-to- face meeting opportunities. Possibly providing assistance to smaller concessionaires or making data requirements as simple as possible. Not completely avoidable. Limiting costing obligations to dominant or incumbent operators in legislation as done in other jurisdictions (although it may be argued that there are benefits to small market players participating in such an exercise: • better understanding of own costs •Better understanding of industry cost accounting practices • could facilitate increased efficiency and therefore increased competitiveness in a globalised environment.)
- 40. 404040 Issues and Challenges to date Stage Concerns and /or Challenges Faced Solution Could have been avoided by: Model Specification and CCA Reference Consultation Low participation by concessionaires, particularly smaller ones (may not have required in-house expertise or appreciate the relevance of the exercise). Delays due to: • extended deadline to facilitate other consultations • late responses Allocating enough time in project plan. Providing opportunities for face-to-face meetings in addition to soliciting written feedback. Possibly providing training to smaller concessionaires on LRAIC modeling and CCA principles. Limiting costing obligations to dominant or incumbent operators in legislation as done in other jurisdictions (although it may be argued that there are benefits to small market players participating in such an exercise: • better understanding of own costs •Better understanding of industry cost accounting practices • could facilitate increased efficiency and therefore increased competitiveness in a globalised environment. Possibly providing industry training at an earlier stage. Model Development, Population & Implementation Potential for: •Low participation by smaller concessionaires •Further delays Possibly providing assistance or exercising forbearance to smaller concessionaires or making data requirements as simple as possible.
- 41. 41 The End