development of the danish lraic model for fixed …...changes that occurred in the fixed danish...

Development of the Danish LRAIC model for fixed networks

Fixed LRAIC Model - Consultation Document

3 February 2020

Excellence in Business

2020© Axon Partners Group 1

Contents

Contents ............................................................................................................. 1

1. Introduction .................................................................................................. 3

2. The consultation process ................................................................................. 4

2.1. Description of the files submitted to consultation .......................................... 4

2.2. Procedure to submit answers ..................................................................... 6

2.3. Clarification process ................................................................................. 7

3. LRAIC model for fixed networks ....................................................................... 8

3.1. Main inputs of the Excel model ................................................................... 8

3.1.1 Demand ........................................................................................................................... 8

3.1.2 Coverage ....................................................................................................................... 10

3.1.3 Broadband traffic .......................................................................................................... 11

3.1.4 Access network topology .............................................................................................. 12

3.1.5 Access network inputs .................................................................................................. 13

3.1.6 Transmission network topology .................................................................................... 16

3.1.7 Transmission network inputs ........................................................................................ 18

3.1.8 Unit costs and useful lives ............................................................................................. 20

3.1.9 Non-network overheads ............................................................................................... 21

3.1.10 Fully Depreciated Assets ............................................................................................... 22

3.1.11 Copper shut down ......................................................................................................... 25

3.1.12 Additional inputs ........................................................................................................... 29

3.2. Reconciliation of the Excel model.............................................................. 30

3.2.1 Number of network elements ....................................................................................... 30


3.2.2 Cost base ....................................................................................................................... 32

3.3. Main outcomes of the Excel model ............................................................ 33

3.3.1 Wholesale copper access .............................................................................................. 37

3.3.2 Wholesale fibre access .................................................................................................. 38

3.3.3 Wholesale coax access .................................................................................................. 39

3.3.4 Wholesale BSA .............................................................................................................. 40

3.3.5 Other recurring services ................................................................................................ 41

3.3.6 Ancillary services ........................................................................................................... 42

4. Template to comment ................................................................................... 43


1. Introduction

Since 2003, the DBA has annually regulated the wholesale prices for several fixed-network

services through a Long Run Average Incremental Cost (LRAIC) model. As presented in

the Model Reference Paper (hereinafter, ‘the MRP’) from October 20191, the relevant

changes that occurred in the fixed Danish market since the last major update of the model

in 2013, merited a new update of the fixed LRAIC model (hereinafter, ‘the model’) to make

sure it is representative of the current situation and can fulfil DBA’s regulatory needs.

This consultation round aims at providing stakeholders in the Danish fixed telecoms market

an opportunity to comment and advice on the draft version of the model developed by the

DBA with the support of Axon Partners Group (hereinafter, ‘Axon’), with the final objective

of maximising its representativeness and accuracy. This is going to be the first of two

consultation rounds that are expected to take place, with the second starting on April 2020

(expected) – both with the same objective of allowing stakeholders to review, comment

and advice on DBA’s model.

The draft model submitted to consultation has been developed following the

methodological principles laid out in the MRP from October 2019, which was subject to

consultation with the industry between 1st July to 30th August 2019. Consequently, DBA

does not expect to receive feedback on the methodological grounds of the draft model,

but on the reasonability and representativeness of its inputs, calculations and outcomes.

DBA invites stakeholders to participate in this consultation process following the indications

presented in the following section.

1 Link: https://erhvervsstyrelsen.dk/sites/default/files/2019-10/Final%20MRP.pdf

https://erhvervsstyrelsen.dk/sites/default/files/2019-10/Final%20MRP.pdf


2. The consultation process

This section describes the consultation process, including:

Description of the files submitted to consultation

Procedure to submit answers

Clarification process

2.1. Description of the files submitted to consultation

The following files are shared with stakeholders as part of this first consultation round:

Consultation Document (this document): After a description of the consultation

process, it develops the most relevant aspects of the draft model submitted to

consultation for which the DBA expects to receive feedback from the industry. It also

includes a set of specific questions that stakeholders are expected to answer.

The file provided is named 'Fixed LRAIC model – 1st consultation document.pdf'.

Annex 1 – Presentation of the 1st draft model: This presentation provides a

medium-level description of the consultation process, the model’s structure and

architecture, its main inputs and the outcomes it produces. Stakeholders are strongly

encouraged to read this presentation once they have gone through this consultation

document to get a broad and consolidated overview of the consultation materials and

their characteristics.

The file provided is named 'Fixed LRAIC model – Presentation of 1st draft model.pdf'.

Annex 2 – LRAIC Excel Model: This excel file contains the inputs, calculations and

outputs (results) that conform the cost model. It is responsible for calculating the

network assets, the cost base and the service-level costs of the modelled operator

based on the inputs it has been filled in with.

For the sake of preserving the confidentiality of the data provided by the stakeholders,

the inputs of the model have been anonymized by multiplying them by a random factor


between ±30%. Anonymised inputs have been marked in a different colour in the

model2. This anonymisation process implies that:

• The inputs presented in this Consultation Document, in the presentation of the 1st

draft model (Annex 1) and in the Excel Model (Annex 2) are all anonymised. This

is, none of them represent the actual figures considered by DBA, although they are

representative enough to allow a meaningful review from the stakeholders.

• The outputs presented in this Consultation Document and in the presentation of

the 1st draft model (Annex 1) are the actual results obtained by DBA. This is, they

are not anonymised in order to provide stakeholders with a clear view of the actual

outcomes of the model. However, in the Excel Model, as the outputs are directly

linked to the anonymised inputs, they will not reflect the actual results obtained by

DBA and will differ slightly from the outcomes presented in this document and in

the presentation of the 1st draft model.

The file provided is named 'Fixed LRAIC model – 1st draft LRAIC Excel model.xlsb'.

Annex 3 – Sample of LRAIC R Model: The R model is responsible for extracting a

number of KPIs mainly related to the dimensioning of the fixed access network. Given

the highly confidential and complex nature of this information, only a sample of the

actual LRAIC R model, including anonymised information on two random areas of

Denmark, has been shared in this consultation process. However, all the relevant

algorithms are preserved in this version of the R model to allow stakeholders to review

it in full.

The file provided is named 'Fixed LRAIC model – 1st draft R model.zip'.

Annex 4 - User manual: This document introduces the general structure of the Excel

and the R models, providing guidance on how to operate them for the first time.

The file provided is named 'Fixed LRAIC model – 1st draft user manual.pdf'.

Annex 5 – Descriptive manual: Detailed technical document describing the structure

of the Excel model, the definition of its key inputs, and the algorithms implemented to

2 Please note that the inputs presented in the Consultation Document, the Annex 1 – Presentation of the 1st

draft model and in the Annex 2 – LRAIC Excel Model, have been anonymised due to confidentiality reasons.

These figures have been defined within a ±30% range of the inputs obtained with the confidential information.

Meanwhile, the outputs presented in the Consultation Document and in Annex 1 – Presentation of the 1st draft

model represent the actual figures calculated in the model. Results included in Annex 2 – LRAIC Excel Model

presents results that depend on the inputs included in the model, which been anonymized. This implies that

the stakeholder will see different figures in the model compared to the ones presented in this document and

the results presentation.


dimension the network, calculate its costs and allocate them to the final services. It

also describes the geographical calculations performed in the R model.

The file provided is 'Fixed LRAIC model – 1st draft descriptive manual.pdf'.

Annex 6 – Template to comment: This document includes the list of questions

included in section ‘4 Template to comment’ to ease the process of responding to this

public consultation process.

The file provided is named 'Fixed LRAIC model – Template to comment.xlsx'.

2.2. Procedure to submit answers

This public consultation is conducted by DBA within the framework of its competences from

the Act.

Stakeholders are invited to submit their comments in reply to the relevant questions issued

in this document by making use of the template to comment included in section ‘4

Template to comment’ of this document.

The public consultation is launched on Monday 3 February 2020 and will end on

Friday 6 March 2020. Responses should be submitted in English and in electronic

form before the end of the public consultation.

The consultation responses from the industry may be published in full and outlining the

corporate name of the respondent by DBA. In case the responses contain confidential

information that should not be published, operators are responsible of reporting a separate

version of the document removing any information that shall be considered confidential

for publication.

Responses and questions should be submitted to the following email addresses:

[email protected] and [email protected].

Respondents are encouraged to support their statements and comments with any relevant

justifications, as DBA cannot accommodate suggestions without sufficient reasoning.

DBA will assume that if a stakeholder does not answer a specific question, the stakeholder

is accepting the approach presented to such question under this document.


2.3. Clarification process

We strongly recommend stakeholders taking part in this consultation process to analyse

all the materials provided along with this document. We expect that several potential

questions may already be clarified by going through these documents.

However, if there are still any questions or doubts about any of the aspects related to the

topics included in this document, we encourage each stakeholder to send a single set of

questions to DBA through the email addresses provided in section ‘2.2 Procedure to submit

answers’.

Questions are accepted within the first two weeks of the consultation process (before

Wednesday 19 February 2020). Answers to the questions received, together with a

presentation of the 1st draft model, will be provided by the DBA-Axon team in a workshop

in DBA’s premises that will take place on Wednesday 26 February 2020.

Questions sent to DBA and DBA’s answers will be shared with all stakeholders.


3. LRAIC model for fixed networks

This section provides an executive overview of the model’s inputs, its reconciliation with

the modelled operator’s financials as well as its outcomes. On each of these topics, a

number of questions are raised for which DBA is particularly seeking stakeholders’

feedback.

3.1. Main inputs of the Excel model

This subsection presents the main inputs of the Excel model, namely:

Demand

Coverage

Broadband traffic

Access network topology

Access network inputs

Transmission network topology

Transmission network inputs

Unit costs and useful lives

Non-network overheads

Fully Depreciated Assets

Copper shut down

Additional inputs

All data presented in this section has been anonymised in order to protect the

confidentiality of the data provided by the stakeholders.

3.1.1 Demand

The demand of the modelled services is one of the primary inputs of the Excel Model and

is crucial to determine the required elements in some parts of the network, as well as to

calculate the unit costs of the services. This input is introduced in worksheet ‘1A INP

DEMAND’ of the Excel Model for each of the modelled services and for the whole modelling

period (i.e. from 2005 to 2038).


As per the MRP, the demand inputs shall represent the realities of the SMP operator in

markets 3a) and 3b) which, at the time of the consultation, means that it should reflect

TDC’s demand. Consistently, the model considers, for each access network (copper, fibre

and coax), TDC’s actual demand as shown below:

Exhibit 3.1: Demand of access services per access network3 [Source: DBA]

Section ‘3.1. Demand’ of the Descriptive Manual provides further information on how

demand inputs have been obtained.

Question 1: Do you agree with the demand considered for the modelled operator?

If you don’t agree, please justify your position and provide supporting information and

references.

3 The figures presented in this exhibit do not consider the shutdown of copper networks. Please see Section

‘3.1.11 Copper shut down’ for further details.

-

0,5

1,0

1,5

2,0

2,5

3,0

Access lin

es (

MM

)

Copper Fibre Coax


3.1.2 Coverage

Coverage inputs refer to the number of connected homes by each access network.

Coverage inputs are defined in worksheet ‘2A INP COVERAGE’ of the Excel Model per

geotype and year.

These inputs were defined following different approaches for the copper and coax networks

on one hand, and for the fibre access network on the other, as shown below:

Copper and coax coverage: The coverage levels from 2018 were extracted from the

data available within DBA (see section ‘4.1.3 Coverage database’ of the Descriptive

Manual for further information about this database). Coverage levels for the other

years (before and after 2018) were set at the same level as for 2018 based on the

indications received from the modelled operator.

Fibre coverage. The 2018 coverage levels were also extracted from data available

within DBA. In this case, the evolution of the fibre footprint was based on the data

reported by the modelled operator.

The exhibit below summarizes the figures considered, in terms of homes connected, for

each access network.

Exhibit 3.2: Number of homes connected per access network [Source: DBA]


Question 2: Do you agree with the coverage levels considered for copper, fibre and coax

access networks?


references.

3.1.3 Broadband traffic

One of the critical inputs in the dimensioning of the transmission network is the broadband

traffic. Worksheet ‘1D INP NW EVO’ of the Excel Model includes a series of inputs to

calculate the broadband traffic that goes through the transmission network in the busy

hour (in Mbps) for a typical subscriber in each access network. These inputs include:

Average download traffic: It represents the average traffic, in GB per year,

consumed by a typical user in each access network (copper, fibre and coax).

Peak to mean ratio: It represents the ratio between the peak and average download

traffic. It is used to calculate the traffic in the busy hour.

The exhibit below illustrates the figures considered, in terms of GB per year per active

broadband subscriber, in each access network.

Exhibit 3.3: Download broadband traffic per line per access network [Source: DBA]


Section ‘3.5. Broadband traffic’ of the Descriptive Manual provides further information on

how these inputs have been obtained.

Question 3: Do you agree with the broadband traffic inputs considered to characterize

traffic requirements?


references.

3.1.4 Access network topology

The model follows a similar architecture to the one actually deployed by the modelled

operator. Particularly, the model defines a series of levels or layers in the access network,

which are described below:

Central Office (CO), which represents the last concentration node of the access

network, establishing the boundaries between the access and transmission networks.

Remote Cabinet (RC), which represents an intermediate point in the access network

which is used to locate the access node (MSAN or OLT) closer to the end user.

Distribution Point (DP), which are used to aggregate cables and routes in the access

network in order to ensure optimal distribution.

Final Distribution Point (FDP), located just outside the end user’s premises.

The locations of the access nodes are based, when available, on the data provided by the

modelled operator (scorched-node assumption).

In each of these locations, different network elements are installed, depending on the

access network. In summary, the network topology defined for each of the access network

is presented below:


Exhibit 3.4: Topology of the access networks [Source: DBA]

Question 4: Do you agree with the access network topology considered and its

representativeness of the realities of the modelled operator?


references.

3.1.5 Access network inputs

The design of fixed access networks requires an exhaustive analysis of the geographical

areas to be covered, as they will have a direct impact on the dimensioning of the network

assets that are dependent on the underlying geography, such as cables, trenches, etc.

These calculations are performed in the R model and described in section ‘4 Geographical

analysis performed in the R model’ of the descriptive manual. The outcomes of the R model

are then loaded into the worksheets ‘2B INP NW INVENTORY’ and ‘2C INP NW ELEMENT

DIS’ of the Excel Model.

FDP

FDP

FDP

DP

PDP SDP

Splitter

Remote CabinetCentral Office

CMC

L3 Access router

PTP -

Fibre

GPON-

Fibre

Coax

Copper

Fibre cableCopper cableCoax cable

Coax OLT

Copper direct.conne. to CO

FDP

FDP

FDP

FDP

FDP

FDP

FDP

FDP

MSAN Copper

MSAN Copper

Fibre OLT

MSAN PTP


The access network inputs produced in the R model are:

Copper access network:

• Km of copper trenches

• Km of cables (pairs)

• Km of fibre cable for copper network

• Number of street cabinets

• Number of DPs

• Number of MDFs

• Number of COs

• Number of joints

• Others, such as the percentage of homes connected directly to a Central Office and

the distribution of the configurations of the different equipment. All parameters

produced by the R model for the copper access network are available in the

worksheets ‘2B INP NW INVENTORY’ and ‘2C INP NW ELEMENT DIS’ of the Excel

model.

Fibre access network

• Km of fibre trenches

• Km of strands (PON and PTP)

• Number of PON OLT

• Number of joints (PON and PTP)

• Number of DP

• Number of PTP MSAN

• Number of ODF

• Others, such as the number of PON Splitters and the configurations of the different

equipment. All parameters produced by the R model for the fibre access network

are available in the worksheets ‘2B INP NW INVENTORY’ and ‘2C INP NW ELEMENT

DIS’ of the Excel model.

Coax access network

• Km of coax trenches

• Km of coax cables


• Km of fibre cable for coax network

• Number of CMCs

• Number of coax OLTs

• Number of taps

• Number of coax splitters

• Number of DPs

• Others, such as the number of amplifiers and the configurations of the different

equipment. All parameters produced by the R model for the coax access network

are available in the worksheets ‘2B INP NW INVENTORY’ and ‘2C INP NW ELEMENT

DIS’ of the Excel model.

Only a sample of the R model has been shared with stakeholders due to confidentiality

and complexity reasons; however, the following can still be reviewed:

How these inputs have been calculated, by assessing the methodology and algorithms

adopted in the R model.

The final outcomes of the R model, accepting a ±30% differential due to the

anonymization of these figures in the Excel model, by reviewing the inputs including in

worksheets ‘2B INP NW INVENTORY’ and ‘2C INP NW ELEMENT DIS’ of the Excel Model.

The exhibit below provides an illustrative example of the kilometres of trenches in the fibre

access network for different geotypes in the Hovedstaden region:


Exhibit 3.5: Illustrative example of the outputs produced by the R model for the access network

(kilometres of trenches in the fibre access network for different geotypes in the Hovedstaden

region) [Source: DBA]

Question 5: Do you agree with the access network inputs considered and their



references.

3.1.6 Transmission network topology

The transmission network topology used in the cost model is based on the actual hierarchy

adopted by the modelled operator. Four layers are considered in the transmission network:

Core nodes

Distribution nodes

Aggregation nodes

L3 access nodes

-

500

1.000

1.500

2.000

2.500

3.000

3.500

4.000#

Km

of

tren

ch

es i

n t

he f

ibre n

etw

ork

URBAN SUBURBAN RURAL


A summary of the topology considered is presented in the exhibit below:

Exhibit 3.6: Architecture of the transmission networks [Source: DBA]

Please note that, in line with the nodes of the access network, the topology and location

of the nodes in the transmission network is based on data from the modelled operator.

Additionally, the exhibit below provides a high-level overview of the transmission topology

considered in the Excel model:

L3

Access

Netw

ork

L3 Access Node

Ag

greg

ati

on

N

etw

ork

Dis

trib

uti

on

n

etw

ork

Core

netw

ork

L3 Access Node

Aggregation Router Aggregation Router

Distribution Router Distribution Router

Core Router Core Router

Access Networks

Access Networks


Exhibit 3.7: Map of the transmission network defined in the model4 [Source: DBA]

Question 6: Do you agree with the transmission network topology considered and its



references.

3.1.7 Transmission network inputs

As for access networks, transmission networks require an exhaustive geographical

analysis, as they have a direct impact on the dimensioning of the network assets that are

dependent on the underlying geography, such as cables, trenches, etc.

These calculations are also performed in the R model and described in section ‘4

Geographical analysis performed in the R model’ of the descriptive manual. The outcomes

4 The L3 Access layer is not represented in this exhibit for the sake of the simplicity and clarity of the

illustration.

A ggregation node C ore-Core link

A gg-Agg link

Dis tribution node

Dis t-Core Link

C ore node Dis t-Agg link


of the R model are then loaded into the worksheet ‘2D INP CORE & TX RINGS’ for each

transmission network, namely:

L3 Access network

Aggregation network

Distribution network

Core network

The transmission network inputs produced in the R model are:

Number of nodes

Number of rings/chains

Total route length of chains

The total percentage of traffic handled by each chain

Only a sample of the R model has been shared with stakeholders due to confidentiality

and complexity reasons; however, the following can still be reviewed:

How these inputs have been calculated, by assessing the methodology and algorithms

adopted in the R model.

The final outcomes of the R model, accepting a ±30% differential due to the

anonymization of these figures in the Excel model, by reviewing the inputs included in

the worksheet ‘2D INP CORE & TX RINGS’ of the Excel Model.

The exhibit below provides an illustrative example of the distribution of the length of the

transmission networks across the different layers defined, as generated by the R model:


Exhibit 3.8: Illustrative example of the outputs produced by the R model for the access network

(share of transmission routes per transmission network category) [Source: DBA]

Question 7: Do you agree with the transmission network inputs considered and their



references.

3.1.8 Unit costs and useful lives

The assets’ unit costs and associated information (including cost trends, OpEx

percentages, useful lives) are included in the worksheet ‘1B INP UNIT COSTS’ of the Excel

Model for each of the network elements defined. These inputs are used to calculate the

annualised operational (OpEx) and capital (CapEx) expenses per asset and year.

For each of the assets defined in the model, this worksheet includes:

Inputs relevant to capital expenditures.

• Unit CapEx. Represents the acquisition and installation costs of the network

element.

72,3%

19,0%

6,2%

2,5%

L3 Access Network Aggregation Network

Distribution network Core Network


• CapEx trend. Represents the evolution of the asset price over the years.

• Useful live. Represents the average technical duration (in years) of the asset.

Inputs relevant to operational expenditures.

• Unit OpEx. Represents the annual cost of maintaining and operating the asset as

a percentage of its unit CapEx. It also includes rental expenses.

• Percentage of labour work. Represents the share of OpEx that is related to staff

costs.

As per the MRP, the prices used in the model reflect those that an efficient operator would

face, considering the scale of the modelled operator.

Section ‘3.2. Asset Costs’ of the Descriptive Manual provides further information on how

these inputs have been obtained.

Question 8: Do you agree with the unit costs and useful lives introduced in the worksheet

‘1F INP UNITARY COSTS’ of the Excel Model?


references5.

3.1.9 Non-network overheads

Non-network overheads are included in the model to account for costs that are not directly

related to the network, but yet should be (partially) recovered through the wholesale rates

for regulated services. As presented in the MRP, these costs are included in the Excel

model as a mark-up over network costs

Four different non-network overheads have been considered in the model depending on

their nature:

G&A: It represents the costs of general and administrative activities. This mark-up

has been calculated based on the cost accounts of the modelled operator using the

following formula:

5 References may include items such as invoices, information that shows the representativeness of the invoice

for the entire network (e.g. in terms of number of elements associated to the invoice in comparison with the

overall number of elements in the network), audited accounting systems, etc.


% 𝐺&𝐴 𝑚𝑎𝑟𝑘 − 𝑢𝑝 =𝑆𝑢𝑝𝑝𝑜𝑟𝑡 𝑎𝑛𝑑 𝑜𝑣𝑒𝑟ℎ𝑒𝑎𝑑𝑠 𝑐𝑜𝑠𝑡𝑠 (𝑟𝑒𝑙𝑒𝑣𝑎𝑛𝑡 𝑓𝑜𝑟 𝐿𝑅𝐴𝐼𝐶 𝑚𝑜𝑑𝑒𝑙)

𝑇𝑜𝑡𝑎𝑙 𝑐𝑜𝑠𝑡𝑠 (𝑟𝑒𝑙𝑒𝑣𝑎𝑛𝑡 𝑓𝑜𝑟 𝐿𝑅𝐴𝐼𝐶 𝑚𝑜𝑑𝑒𝑙)= 8,50 %

IT: It represents the costs related to general IT platforms (e.g. billing). This mark-up

has been calculated based on the cost accounts of the modelled operator using the

following formula:

% 𝐼𝑇 𝑚𝑎𝑟𝑘 − 𝑢𝑝 =𝐼𝑇 𝑝𝑙𝑎𝑡𝑓𝑜𝑟𝑚 𝑐𝑜𝑠𝑡𝑠 (𝑟𝑒𝑙𝑒𝑣𝑎𝑛𝑡 𝑓𝑜𝑟 𝐿𝑅𝐴𝐼𝐶 𝑚𝑜𝑑𝑒𝑙)


Wholesale and commercial: It represents the costs related to wholesale and

commercial specific operations. This mark-up has been calculated based on the cost

accounts of the modelled operator using the following formula:

% 𝑊ℎ𝑜𝑙𝑒𝑠𝑎𝑙𝑒 𝑚𝑎𝑟𝑘 − 𝑢𝑝 =𝑊ℎ𝑜𝑙𝑒𝑠𝑎𝑙𝑒 𝑐𝑜𝑠𝑡𝑠 (𝑟𝑒𝑙𝑒𝑣𝑎𝑛𝑡 𝑓𝑜𝑟 𝐿𝑅𝐴𝐼𝐶 𝑚𝑜𝑑𝑒𝑙)


Working Capital: It refers to the cost or revenues generated by the working capital

of the modelled operator. As informed in the MRP, given that the modelled operator

has not been able to quantitatively prove its existence, it has been left empty.

Further details on the calculations of these inputs are provided in the descriptive manual.

Question 9: Do you agree with the non-network overheads considered for the modelled

operator?


references.

3.1.10 Fully Depreciated Assets

As presented in the MRP, the model does not take fully depreciated assets in copper and

coax access networks6 into consideration to avoid over-recovering their costs. Particularly,

this consideration applies to the following assets:

Copper networks: Copper cable, including civil infrastructure used to install these

cables (trenches, ducts, etc.).

6 No adjustment is applied in the case of fibre networks


Coax networks: Coax cable, including civil infrastructure used to install these cables

(trenches, ducts, etc.).

To apply this adjustment, detailed information from the Fixed Asset Register (FAR) of the

modelled operator is required. Particularly, the following items are needed:

Total gross book value (GBV) of the assets under operation in the copper and coax

access networks.

The year when the assets were originally purchased.

This information is required to understand the percentage of assets under operation that

are fully depreciated. Note that, as explained in the MRP, the useful lives from the existing

LRAIC models are considered instead of the accounting useful lives to ensure consistency

with the regulation adopted by DBA so far.

However, we identified three main limitations when performing this assessment:

There is no information regarding assets that were fully depreciated by 1995.

Therefore, these could not be accounted for in the calculations performed, leading to

a potential underestimation of the percentage of fully depreciated assets.

Even though the percentage of fully depreciated assets had to be calculated as of the

first year of the model (i.e. 2005), the DBA-Axon team only had access to a detailed

Fixed Asset Register from the modelled operator for the year 2018, meaning that the

calculation of the percentage of fully depreciated assets actually refers to 2018. This

could arguably lead to a potential overestimation of the percentage of fully depreciated

assets.

The optimal useful lives to be considered could be argued, given that even though

regulatory useful lives should be preferred, they were only used for regulatory

purposes since the late 2000s. This means that TDC probably recovered most of the

access assets’ costs beforehand, considering their financial useful lives. Therefore, the

adoption of the regulatory useful lives may lead to a potential underestimation of this

percentage.

As a result of these limitations and given that they could drive the actual share of fully

depreciated assets in opposite directions, it must be concluded that there is some degree

of uncertainty on the actual share of fully depreciated assets as of 2005 in the modelled

operator’s copper and coax networks.


Despite this situation, the table below illustrates the figures obtained from the 2018 FAR

from the modelled operator:

Parameter Copper

networks

Coax

networks

Figures from the FAR

Total GBV of the assets currently under operation 100,0 100,0

Total GBV of the fully depreciated assets 27,0 23,6

Figures from the FAR indexed to 2018, based on inflation

Total GRC of the assets currently under operation [a] 150,6 118,7

Total GRC of the fully depreciated assets [b] 55,4 32,2

Indexed ratio of fully depreciated assets [b/a] 36,8% 27,1%

Exhibit 3.9: Figures7 considered for the calculation of fully depreciated assets [Source: DBA]

Further, in order to verify the reasonability of the figures obtained, the DBA-Axon team

has assessed the results obtained under the two methodological alternatives available to

implement the EC’s Recommendation:

Calculate the Gross Replacement Cost (GRC) of the relevant copper and coax access

assets as of 2005, considering only the non-fully depreciated assets, and depreciate

them based on their technical useful lives. No additional investments in such assets

after 2005 are considered under this approach.

Calculate the Net Replacement Cost (NRC) of the relevant copper and coax access

assets as of 2005 and depreciate them based on their remaining technical useful lives.

New investments in such assets are considered after 2005 under this approach when

the remaining technical useful live expires and those assets are still required in the

network.

As expected from a theoretical perspective, both approaches have led to similar results,

thus pointing to the overall reasonability of the exercise performed.

However, given the underlying uncertainty of the share of fully depreciate assets that shall

be considered in the Excel Model, four different alternatives have been presented in the

control panel (30%, 40%, 50% and 60%) which may easily be selected by the user, as

shown below:

7 Figures have been normalised to preserve the confidentiality of the operator.


Exhibit 3.10: Selection of the percentage of fully depreciated assets [Source: Axon Consulting]

Question 10: Do you agree with the fact that it may not be possible to extract the actual

percentage of fully depreciated assets from the modelled operator’s financials due to the

reasons explained? In this case, which percentage (30%, 40%, 50% or 60%) do you think

that would better reflect the status of the modelled operator’s network?

Given the relevance of this input, stakeholders are highly advised to support their

suggested percentage with thorough analyses based on actual data whenever possible.

3.1.11 Copper shut down

As described in the MRP, the modelling period goes from 2005 until 2038. This means that

it may be plausible that the copper network is shut down within the modelled period. A

copper network shutdown would imply that:

There is no demand in the copper network beyond the shutdown year (any copper

demand introduced in the worksheet ‘1A DEMAND’ is automatically migrated to the

fibre access network).

LRAIC Model for Fixed Networks

Control panel

Execution mode Full execution

Execution time 04:17 1

Input scenarios

Demand scenario Base case

selected.demand.scenario

Copper shutdown year 2.030

selected.copper.shutdown GENERAL CHECK

Annualisation of copper shut-down costs GRC annualised within active years OK

selection.annualisation.copper.shutdown

Remove fully depreciated assets? Yes

selection.fully.depreciated

Percentage of fully depreciated assets 50%

selection.fully.depreciated.percentage

Annualisation methodology Economic Depreciation

selection.annualisation.method

WACC 4,54%

input.wacc

Risk premium 2,00%

input.risk.premium

Consider productivity factor? Yes

selection.productivity.factor

RUN

UPDATE

KPIs

CONTENTS

MAP


There are no operational costs in the copper access network beyond the shutdown

year. Further, the model considers that the operational costs from the copper access

network will progressively decrease progressively as the copper network is being

dismantled.

The copper shutdown year can be selected by the user through the control panel as

illustrated below. As a reference, the base case considered in the model shared with the

stakeholders is that the copper network is going to be switched off in 2030.

Exhibit 3.11: Selection of the year for copper shutdown [Source: Axon Consulting]

When assessing the impact of a copper shutdown before the end of the modelling period,

it is particularly important to evaluate its implications on the recovery of the capital costs.

In particular, the model calculates and annualises the investment required for copper

access networks over the useful lives of the assets. At the same time, the timeframe of

the model was set in line with the useful lives of these assets to guarantee a consistent

approach in the depreciation of their GRC. However, if the copper network is shut down


Control panel



Input scenarios













WACC 4,54%

input.wacc

Risk premium 2,00%

input.risk.premium



RUN

UPDATE

KPIs

CONTENTS

MAP


before the end of their useful lives, it becomes important to define the treatment to be

given to the annualization of such costs. There are mainly two alternatives to address this

issue:

a) All GRC is annualized within the “active” years of the copper network. This

would imply artificially adjusting the useful lives of the copper access assets to ensure

they are either lower or equal to the modelling timeframe.

b) Only the GRC that, according to the technical useful lives of the assets, is

expected to be annualized during the “active” years of the copper network is

considered. This would imply keeping the originally defined technical useful lives and

consider the default annualisation costs generated by these assets in any year of the

model.

Alternative a) above would naturally lead to higher unit costs for the copper access services

when a copper network shutdown is expected to take place before 2038 (the last year of

the model). On the other hand, if no shutdown of the copper network is expected (or if it

takes place in 2038), both alternatives will lead to the same results.

Even though alternative b) could seem to lead to an under-recovery of costs by the

modelled operator, it is important to clarify that this may not necessarily be the case. This

is because the model considers all non-fully depreciated assets to be newly deployed in

2005, which is a common technique in Current Cost Accounting (CCA) Bottom-Up cost

models but does not reflect the factual situation of the modelled operator. This implies

that the NRC considered in the model in 2005 is notably higher than the Net Book Value

(NBV), even if indexed, registered in the modelled operator’s financials.

As discussed in the previous section, when no copper shutdown is considered, the

difference in the 2005 NRC is offset throughout the modelled period because the model

does not consider new reinvestments in the main passive copper access assets while the

modelled operator does in practice (e.g. due to the yearly replacements required). This

means that under this scenario, the cost base recovered in the model and the cost base

expected to be recovered by the modelled operator are broadly similar.

However, if a copper shutdown is considered to take place before 2038, alternative a) may

indeed lead to an over-recovery of the modelled operator’s costs, as the financial NBV

(even if indexed) of the modelled operator could not have enough time to reach, in

practice, the 2005 NRC considered in the model.


The exhibit below provides an illustrative example of the behaviour that should be

expected in the model and in the modelled operator’s financials when no copper shutdown

is considered and when the copper network is expected to be shut down in 2025 (under

alternatives a and b):

Exhibit 3.12: Illustrative behaviour of the model and the modelled operator’s financials under

different copper shutdown scenarios [Source: DBA]

Both alternatives can be selected by the user in the control panel to assess their impact

on the final results when a copper network shutdown is expected, as shown below:

ALTER

NA

TIV

E B

NO

SH

UTD

OW

N

OPERATOR

MODELGRC: 100NRC: 100

Total amount depreciated: 100

GRC: 150NRC: 30


No new investments

Investment: 30 Investment: 30 Investment: 30

SH

UTD

OW

N 2

02

5

OPERATOR



GRC: 150NRC: 30


No new investments

Investment: 30ALTER

NA

TIV

E A

OPERATOR



GRC: 150NRC: 30


No new investments

Investment: 30

20382005 2025


Exhibit 3.13: Selection of the scenario for the recovery of copper costs when a shutdown is

considered [Source: Axon Consulting]

Question 11: Do you agree with the consideration that the copper access network will be

shut down around 2030?


references.

Question 12: What approach do you believe should be adopted in the Excel Model to

recover the capital costs of the copper access network when it is switched off before the

end of the modelling period?

Please support your suggested approach with analyses, information and/or references.

3.1.12 Additional inputs

Beyond the inputs detailed above, the model includes additional parameters that are

relevant for the dimensioning and costing of the network. Some examples of these inputs

include:


Control panel



Input scenarios













WACC 4,54%

input.wacc

Risk premium 2,00%

input.risk.premium



RUN

UPDATE

KPIs

CONTENTS

MAP


Percentage of civil infrastructure shared with utility companies

Percentage of lines that are inactive but have a drop installed

Allocation of the coax spectrum to each service (broadband, TV, VoD).

Other access network inputs, such as the number of pairs per copper cable

All these inputs are included in the worksheets ‘1C INP NW’ and ‘1D INP NW EVO’ of the

model.

Question 13: Do you agree with the remaining inputs of the Excel model?


references.

3.2. Reconciliation of the Excel model

This section summarises the results of the reconciliation performed between the outcomes

of the Excel model and the operational and financial realities of the modelled operator.

The reconciliation has been performed in terms of:

Number of elements

Cost base

3.2.1 Number of network elements

The number of elements calculated by the model is compared to the actual number of

elements reported by the modelled operator to ensure the modelled network is

representative of the actual network deployed by the modelled operator. This comparison

is performed solely for the year 2018. In all cases we consider that figures are reconciled

if the result of the model is within a ±10% range from the reference value.

The results of the reconciliation of the number of network elements are presented in the

table below:


Network element Difference compared

to the reference Comments

Copper networks

Copper cable 4,6% Figures are reconciled

Trenches (km) -7,2% Figures are reconciled

MSAN 7,0% Figures are reconciled

MDF -1,9% Figures are reconciled

DP 0,4% Figures are reconciled

Fibre networks

Fibre Cable N/A

No reference for comparison was provided by TDC. Its

reasonability was assessed through a comparison with

the results of the old model.

Trenches (km) N/A




OLT -0,0% Figures are reconciled

MSAN - PTP -27,8%

Figures are not directly comparable given that, for

instance, based on the data reported by TDC, there are

MSAN – PTP installed in areas without FTTH coverage.

Coax networks

Coax cable N/A




Coax trenches N/A




CMC 0,7% Figures are reconciled

Amplifiers 1,3% Figures are reconciled

TAP 5,6% Figures are reconciled

Power splitter -28,4%

Difference is originated by the consideration of a full

DOCSIS 3.1 network in the cost model (instead, TDC

figures may be representative of a mix of DOCSIS 3.0

and 3.1).

Coax cabinet -20,1%

Difference is originated in the consideration of a full

DOCSIS 3.1 network in the cost model (instead, TDC

figures may be representative of a mix of DOCSIS 3.0

and 3.1).

Transmission networks

TX fibre N/A




Core router - Figures are reconciled

L3 router -47,8%

The model considers the migration towards the chain

configuration in the L3 Access Network, which results in

a lower number of L3 routers

Submarine cable - Figures are reconciled

Landing stations - Figures are reconciled

Exhibit 3.14: Reconciliation of the number of network elements [Source: DBA]


Question 14: Do you agree with the results of the reconciliation of the number of network

elements?


references.

3.2.2 Cost base

The reconciliation of the cost base compares the total costs of the model with the relevant

network costs of the modelled operator to assess their representativeness. This

comparison is performed solely for the year 2018. Similar to the previous exercise, the

results were considered to be reconciled when they fell within a ±10% range from the

reference figure.

In order to extract the reference figures, in terms of depreciation and operational costs,

we extracted its costs from an analysis of the Accounting Separation system of the

operator. Notably, TDC reported its Accounting Separation results for the year 2018 with

a detailed degree of disaggregation. From the total results reported by TDC, we subtracted

costs that were not applicable to the fixed LRAIC model to calculate the final reference

figures. Notably two steps were followed in the calculation of the final reference figures

based on the total depreciation and operational costs from TDC:

First, costs related to fixed voice as well as to TDC’s mobile unit were removed, based

on the cost classifications provided by TDC. Additionally, other costs (including costs

from CDNs, IoT platforms and customer premise equipment, among others) were also

removed.

Secondly, costs that were not relevant for the Bottom Up model were discarded. These

include i) installation costs8 ii) international connectivity costs and iii) other costs such

as administrative costs 9 , costs for work carried out for public authorities and

costs/revenues from compensation cases, among others.

Further, some of the models features need also to be adjusted in order to assess the

reconciliation of the cost base, in particular:

8 Even though the model calculates the unit costs for the one-off services, installation costs are not accounted

for in the total cost base calculated in the model.

9 General and administrative expenses are excluded from the cost base and included as a mark-up afterwards.


The depreciation methodology has to be set at “tilted annuities”

The cost trends for the unit costs are set to zero.

The WACC is also set to zero

Non-network overheads are excluded from the cost base

Application of the adjustment for fully depreciated assets from the FAR (without

indexing) to all years of the model.

The results of the reconciliation of the cost base are presented in the table below:

Cost type Difference compared

to the reference Comments

CapEx -1,8% Figures are reconciled

OpEx 3,9% Figures are reconciled

Exhibit 3.15: Reconciliation of the cost base [Source: DBA]

Question 15: Do you agree with the results of the reconciliation of the cost base?


references.

3.3. Main outcomes of the Excel model

The main outcomes of the Excel Model are presented in the following worksheets of the

model:

Worksheet ‘COVER’: The user may select up to three different scenarios for display. In

each scenario, the user may select a recurring service and the relevant geotype

(combination of region, degree of urbanisation, type of building and

regulated/unregulated areas) to be displayed, as shown below


Exhibit 3.16: Snapshot of the results overview presented in the cover of the model [Source: DBA]

Worksheet ‘8A RESULTS SERV’: This worksheet shows the results of all the recurring

services simultaneously, under the geotype (combination of region, degree of

urbanisation, type of building and regulated/unregulated areas) selected by the user,

as shown below:

Result overview

Scenario 1 Scenario 2 Scenario 3

Selected service: Access.Copper.Wholesale.Raw CopperAccess.Fibre.Wholesale.Raw access

(POI1)

Access.Coaxial.Wholesale.BSA

Access (POI2/POI3)

Units DKK / Lines / Year DKK / Lines / Year DKK / Lines / Year

Region All All All

Degree of Urbanisation All All All

Type of building All All All

Regulated areas All All All

869892

915937

962988

1.016 1.034

1.220 1.236 1.2551.282 1.300 1.318 1.336 1.356

593 602 612 622 632 644 657 670

-

200

400

600

800

1.000

1.200

1.400

1.600

2018 2019 2020 2021 2022 2023 2024 2025

DK

K /

Lin

es /

Ye

ar

Scenario 1 Scenario 2 Scenario 3


Exhibit 3.17: Snapshot of the results table presented in the worksheet '8A RESULT SERV' [Source:

DBA]

Worksheet ‘8B RESULTS ANC SERV’: This worksheet shows the results of the ancillary

services per year, as illustrated below:

Region All

Degree of urbanisation All

Type of building All

Regulated areas All

Service Units 2005 … 2017 2018 2019 2020 2021 2022 … 2038

Access.Copper.Wholesale.VULA

(POI0)DKK / Lines / Year 695 … 890 911 933 954 976 1.000 … -

Access.Copper.Wholesale.VULA

(POI1)DKK / Lines / Year 725 … 927 949 971 993 1.015 1.040 … -

… … - … - - - - - - … -

Access.Fibre.Wholesale.Raw

access (POI0)DKK / Lines / Year - … 796 806 819 834 857 870 … 1.164

Access.Fibre.Wholesale.Raw

access (POI1)DKK / Lines / Year - … 1.206 1.220 1.236 1.255 1.282 1.300 … 1.683

Access.Fibre.Wholesale.VULA

access (POI1)DKK / Lines / Year - … 985 993 1.003 1.016 1.037 1.048 … 1.317

… … - … - - - - - - … -

Access.Coaxial.Wholesale.BSA

Access (POI2/POI3)DKK / Lines / Year 524 … 586 593 602 612 622 632 … 935

… … - … - - - - - - … -


Exhibit 3.18: Snapshot of the results table presented in the worksheet '8B RESULTS ANC SERV'

[Source: DBA]

This section presents the results produced by the model for some of its key services,

namely:

Wholesale copper access

Wholesale fibre access

Wholesale coax access

Wholesale BSA

Other recurring services

Ancillary services

As detailed in section ‘3.1 Main inputs of the Excel model’, the model allows for the

calculation of costs under different scenarios. The results presented in this section have

been produced considering the following options:

Copper shut down year: 2030

Annualisation of copper shut-down costs: GRC annualised within active years

ServiceService

Identifier2005 … 2017 2018 2019 2020 2021 2022 … 2038

Migration Services.From

Raw/Shared Copper to

BSA/VULA

5.5.2.1 210 … 210 212 211 211 211 211 … 209


BSA/VULA (without PSTN) to

Raw Copper

5.5.2.2 248 … 248 250 249 249 248 249 … 247


BSA/VULA (without PSTN) to

Shared Copper

5.5.2.3 225 … 225 227 226 225 225 225 … 224

Migration Services.From BSA

(without PSTN) to BSA (with

PSTN)

5.5.2.4 73 … 73 74 74 73 73 73 … 73

… … … … … … … … … … … …

Installation.New installation

(unassisted) – eBSA5.6.2.4 432 … 432 436 434 433 433 433 … 430


(unassisted) – VULA5.6.2.5 354 … 354 357 356 355 355 355 … 352


(unassisted) – Raw Fibre5.6.2.6 354 … 354 357 356 355 355 355 … 352

… … … … … … … … … … … …


Remove fully depreciated assets?: Yes

Percentage of fully depreciated assets: 50%

Annualisation methodology: Economic Depreciation

WACC: 4,54%

Risk premium: 2,00%

Consider productivity factor?: Yes

Please note that the results included in the sections below have been calculated

based on the confidential inputs and, thus, will differ from the ones included in

the anonymised version of the model shared in this 1st consultation.

3.3.1 Wholesale copper access

The following exhibit illustrates the unit costs of the main wholesale copper access services

from 2018 until 202510:

10 The exhibit presents results for the period from 2018 to 2025, however the model calculates the costs from

2005 until 2038.


Exhibit 3.19: Unit costs for the main wholesale copper access services [Source: Excel Model]

It should be noted that the slight increase in the unit costs of these services is driven by

the asset cost trends introduced in the worksheet ‘1B INP UNIT COSTS’. If these were set

to zero, a fully flat unit cost per line would be obtained from the Excel Model.

Question 16: Do you agree with the results obtained for the wholesale copper access

services?


references.

3.3.2 Wholesale fibre access

The following exhibit illustrates the unit costs of the main wholesale fibre access services

from 2018 until 202511:


2005 until 2038.

-

200

400

600

800

1.000

1.200D

KK

/li

ne/

year

VULA Copper (POI0) VULA Copper (POI1) Raw Copper


Exhibit 3.20: Unit costs for the main wholesale fibre access services [Source: Excel Model]

It should be noted that the slight increase in the unit costs of these services is driven by

the asset cost trends introduced in the worksheet ‘1B INP UNIT COSTS’. If these were set

to zero, a fully flat unit cost per line would be obtained from the Excel Model.

Question 17: Do you agree with the results obtained for the wholesale fibre access

services?


references.

3.3.3 Wholesale coax access

The following exhibit illustrates the unit costs of the main wholesale coax access service

from 2018 until 202512:


2005 until 2038.

-

200

400

600

800

1.000

1.200

1.400

1.600

DK

K/

lin

e/

year

Raw fibre access (POI0) Raw fibre access (POI1) VULA fibre access (POI1)


Exhibit 3.21: Unit costs for the main wholesale coax access service [Source: Excel Model]

It should be noted that the slight increase in the unit costs of this service is driven by the

asset cost trends introduced in the worksheet ‘1B INP UNIT COSTS’. If these were set to

zero, a fully flat unit cost per line would be obtained from the Excel Model.

Question 18: Do you agree with the results obtained for the wholesale coax access

services?


references.

3.3.4 Wholesale BSA

The following exhibit illustrates the unit costs of the main wholesale BSA services from

2018 until 202513:


2005 until 2038.

-

100

200

300

400

500

600

700

800D

KK

/li

ne/

year

BSA Coax Access (POI2/POI3)


Exhibit 3.22: Unit costs for wholesale BSA services calculated in the model14 [Source: DBA’s draft

BULRIC Model for Fixed Networks]

Question 19: Do you agree that the unit costs for wholesale BSA services calculated in

the model are representative of the costs borne by the modelled operator in the provision

of these services? Please explain your views and support any comment with information

and evidence.

3.3.5 Other recurring services

Question 20: Do you agree with the results obtained for the other recurring services

presented in worksheet ‘8A RESULTS SERV’?


references.

14 Note that the figures included in this slide include the access costs of the service.

-

500

1.000

1.500

2.000

2.500D

KK

/li

ne/

year

BSA Copper broadband - POI2 BSA Copper broadband - POI3BSA Fibre (PTP) broadband - POI2 BSA Fibre (PTP) broadband - POI3BSA Coax broadband - POI2 BSA Coax broadband - POI3


3.3.6 Ancillary services

The unit costs of the ancillary services considered in the model are presented in worksheet

‘8B RESULTS ANC SERV’. Given the high number of ancillary services included in the Excel

model, their results are not reproduced here.

Question 21: Do you agree with the results obtained for the ancillary services?


references.


4. Template to comment

In order to participate in this consultation process, stakeholders have to provide their

comments through the template included below. While stakeholders may, at their will,

provide comments beyond the scope of this table, DBA will give priority to the feedback

provided under the scope of the template below:

# Category Question Position (Agree / Partially

Agree / Disagree) Comments and justifications

1 Inputs

Do you agree with the demand

considered for the modelled

operator?

If you don’t agree, please

justify your position and

provide supporting information

and references.

2 Inputs

Do you agree with the coverage

levels considered for copper,

fibre and coax access

networks?




and references.

3 Inputs

Do you agree with the

broadband traffic inputs

considered to characterize

traffic requirements?




and references.

4 Inputs

Do you agree with the access

network topology considered

and its representativeness of

the realities of the modelled

operator?




and references.

5 Inputs

Do you agree with the access

network inputs considered and

their representativeness of the

realities of the modelled

operator? If you don’t agree, please



and references.

6 Inputs


transmission network topology

considered and its

representativeness of the


operator?







and references.

7 Inputs


transmission network inputs

considered and their

representativeness of the


operator? If you don’t agree, please



and references.

8 Inputs

Do you agree with the unit

costs and useful lives

introduced in the worksheet ‘1F

INP UNITARY COSTS’ of the

Excel Model?




and references.

9 Inputs

Do you agree with the non-

network overheads considered

for the modelled operator?




and references.

10 Inputs

Do you agree with the fact that

it may not be possible to

extract the actual percentage of

fully depreciated assets from

the modelled operator’s

financials due to the reasons

explained? In this case, which

percentage (30%, 40%, 50%

or 60%) do you think that

would better reflect the status

of the modelled operator’s

network?

Given the relevance of this

input, stakeholders are highly

advised to support their

suggested percentage with

thorough analyses based on

actual data whenever possible.

11 Inputs


consideration that the copper

access network will be shut

down around 2030?




and references.

12 Inputs

What approach do you believe

should be adopted in the Excel

Model to recover the capital

costs of the copper access

network when it is switched off




before the end of the modelling

period?

Please support your suggested

approach with analyses,

information and/or references.

13 Inputs


remaining inputs of the Excel

model?




and references.

14 Reconciliation

Do you agree with the results

of the reconciliation of the

number of network elements?




and references.

15 Reconciliation


of the reconciliation of the cost

base?




and references.

16 Outputs


obtained for the wholesale

copper access services?




and references.

17 Outputs


obtained for the wholesale fibre

access services?




and references.

18 Outputs


obtained for the wholesale coax

access services?




and references.

19 Outputs

Do you agree that the unit

costs for wholesale BSA

services calculated in the model

are representative of the costs

borne by the modelled operator

in the provision of these

services? Please explain your

views and support any

comment with information and

evidence.

20 Outputs Do you agree with the results

obtained for the other recurring




services presented in

worksheet ‘8A RESULTS SERV’?




and references.

21 Outputs


obtained for the ancillary

services?




and references.

Exhibit 4.1: Template to respond to this public consultation [Source: DBA]

development of the danish lraic model for fixed …...changes that occurred in the fixed danish...

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