Telstra TEM Substantiation Report Quarter 2 – …...The 2015/16 TEM Report for Quarter 2 (Q2 FY16)...

TELSTRA CORPORATION LIMITED (ABN 33 051 775 556)

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Telstra TEM Substantiation Report

Quarter 2 – 2015/16

Quarter 2: 1 October 2015 – 31 December 2015

29 February 2016

Public Version

Telstra TEM Substantiation Report Quarter 2 – 2015/16

TELSTRA Public | Substantiation Report – Q2 FY16

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Contents

1. Executive Summary 3

2. TEM Report Results 4

2.1. Reportable Wholesale Bundles 4

2.2. Wholesale Customers 6

3. Explanation of Results 7

3.1. TEM and the FLSM 8

3.2. Forecast versus actual data 9

3.3. Geographic differentiation 9

3.4. Other Economic Costs 10

4. Notes 11

4.1. Financial Events 11

4.2. Model Drivers 11

5. Glossary 12

Appendix A – Quarter 2 2015/16 Results 13



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1. Executive Summary

Telstra’s Structural Separation Undertaking (SSU) includes commitments to ensure equivalence in

pricing across Wholesale Customers and Telstra’s retail business, and improved transparency in relation

to Telstra’s internal costs. As part of this commitment, Telstra regularly publishes reports based on the

Telstra Economic Model (TEM) to make the revenue and cost information that Telstra itself uses to run

the business transparent to the ACCC.

Where a TEM Report shows that the External Wholesale Price (EWP), the price faced by Wholesale

Customers, is not within +/-5% of the effective Internal Wholesale Price (IWP) faced by Telstra for certain

wholesale service bundles, Telstra is required to submit to the ACCC a ‘Substantiation Report’ providing

an explanation for this result.

The TEM Reports and any Substantiation Reports will be available for any future ACCC regulated

pricing reviews.

The 2015/16 TEM Report for Quarter 2 (Q2 FY16) indicates that due to variations in Corporate Administration costs which occur periodically, and an update of the WACC, there is a negative variance between the EWP and IWP for this quarter (with the EWP being greater than the IWP). However, overall the variance measured since this reporting began in FY2013, remains within +/-5%.

The nature of the EWP and IWP variance metrics within the TEM reports means that they are susceptible to quarter-to-quarter movements in costs – particularly indirect and unattributable costs such as depreciation and corporate administration expenses, which will have highly variable impacts on individual quarterly results over the financial year. As such, any quarterly results need to be assessed in the context of results over a longer time period.

There are other considerations that are important when considering the TEM report:

The prices for the Wholesale services included in the TEM are regulated by the ACCC.

The methodology used to determine costs in TEM differs from that used by the ACCC’s models

used in setting prices for fixed line services. For example, the TEM Report uses allocation rules

from Telstra’s accounting systems, while the ACCC’s Fixed Line Services Model (FLSM) used to

set the current regulated prices as part of the Fixed Line Services Final Access Determination

(FAD) 2015 uses a different allocation model.

The TEM is based on recent historical information, while the ACCC’s pricing model is based on

forecasts made at the time of the pricing decision.

While different wholesale services tend to be purchased in different geographic areas (e.g. ULLS

and LSS are typically sold in lower cost areas and resale services tend to be sold in higher cost

areas), TEM is unable to differentiate costs geographically in the same way.

The IWP calculation does not necessarily account for all economic costs that are appropriately

recovered through prices.

The actual experience of Wholesale Customers is also important here, as these companies typically

purchase a range of services from Telstra Wholesale. For example, Telstra has looked at the likely

average weighted variance between the IWPs and EWPs for two of Telstra’s largest Wholesale

Customers, Optus and TPG, using publicly available subscriber numbers. This analysis estimates these

companies are treated more favourably than Telstra’s retail business units in relation to the bundle of

services they purchase, and have the benefit of a variance ranging up to 69% across their voice and

broadband services.

Note: while the ACCC released a Final Access Determination for regulated fixed line services in October 2015, the prices are set for the period 1 November 2015 to 30 June 2019, and so affected the EWP for only two of the three months of the quarter.



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2. TEM Report Results

Telstra provides the TEM Report to the ACCC for each reporting Quarter. This report tables the financial

measures for the Reportable Retail Products and the Reportable Wholesale Products specified by the

SSU, and reports the IWP and EWP for the Reportable Wholesale Products and Reportable Product

Bundles.

The IWP is calculated as the sum of allocated expenses, depreciation and amortisation, and cost of

capital, divided by the total demand for each Reportable Product Bundle and Reportable Wholesale

Product. This is effectively the internal cost for the same network requirements as required by the

Reportable Wholesale Bundle or Reportable Wholesale Product.

The EWP is calculated as the total revenue divided by the total demand for each Reportable Product

Bundle and Reportable Wholesale Product. This external price is in effect the average yield for each

Reportable Wholesale Bundle or Reportable Wholesale Product.

2.1. Reportable Wholesale Bundles

The TEM Report for Q2 FY16 shows that the costs allocated overall to the Total Reportable Wholesale Product Bundle are less than the revenue earned for the quarter. It shows that price per SIO for the bundle of all Reportable Wholesale Services is 5.8% higher than the allocated cost per SIO. The results also show that prices for the bundles of voice and voice plus WDSL are favourable to Telstra’s Retail business unit by 17.2% and 21.7%, respectively, but prices for the bundle of ULLS and LSS are more favourable to Wholesale Customers by 18.4%.

Table 1. TEM Q2 FY16 Results – Reportable Product Bundles

Wholesale Bundle Internal

Wholesale Price

(per qtr)

External

Wholesale Price

(per qtr)

Variance

All Reportable Wholesale Products per SIO $95.77 $101.29 -5.8%

Voice and WDSL Bundle per SIO $124.83 $151.95 -21.7%

Voice Bundle per SIO $75.82 $88.82 -17.2%

ULLS and LSS Bundle per SIO $53.08 $43.30 18.4%

Note: See Appendix A for complete table including all Reportable Wholesale Product Charge Types.

Accounting for quarter-to-quarter volatility in variance results

Since the introduction of TEM Reporting, a great deal of variability has been observed in the quarterly variance between the IWP and the EWP. Assessment of the underlying drivers of changes in IWP and EWP variance from quarter to quarter has shown that a significant proportion of observed change is due to the impact of volatility in unattributable and indirect costs, rather than fundamental change in the directly attributable costs and revenues of the relevant services. Examples of unattributable and indirect costs that are impacting on quarterly results include: financial adjustments (foreign exchange and bond rates); quarterly variation in administration costs (and the treatment of these costs); reviews of asset service lives and consequent variability in depreciation expenses incurred – period-on-period; and movement in the Corporate WACC bi-annually.

The impact of accounting and/or corporate overhead changes on the IWP and EWP variance outcomes also needs to be carefully considered in interpreting the results set out in TEM Reporting.

In order to take account of the quarterly variation associated with the timing of accounting events such as those set out above, it is useful to examine the variance over a longer period.



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Taking the total variance since the introduction of TEM Reporting (that is, the aggregate variance observed over sixteen TEM reports), it can be seen that the variance for the bundle of all wholesale services is much lower than the single quarter view, as set out in Table 2.

Table 2. TEM Cumulative Results – Reportable Product Bundles Q3 FY12 to Q2 FY16

[Commercial-in-confidence commences] [Commercial-in-confidence ends] The cumulative variance since the introduction of TEM Reporting remains within +/-5% and is currently -1.5%.

As set out in Chart 1, since the introduction of TEM Reporting, a steady decline can be seen for both the IWP and EWP while the number of services has continued to rise. Chart 1. Total Reportable Wholesale Product Bundle IWP, EWP and SIO index time series

[Commercial-in-confidence commences] [Commercial-in-confidence ends]



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2.2. Wholesale Customers

Equivalence should be considered at an aggregate level because Wholesale Customers typically purchase a range of services, taking into consideration their own retail customer base. Telstra Wholesale Customers typically purchase a range of services across the Total Reportable Wholesale Product Bundle.

While the aggregate result for all Wholesale Customers is important, for the purpose of illustrating the position likely to be faced by Wholesale Customers, Telstra has also looked at the likely average weighted variance between the IWPs and EWPs for two of Telstra’s largest Wholesale Customers.

Using publicly available information, Telstra has set out the subscriber (SIO) numbers and the proportions of On-Net SIOs and Off-Net SIOs reported for two of Telstra’s Wholesale Customers, and estimated the variance between IWP and EWP weighted by On-Net and Off-Net SIO proportions (Table 3). On-Net services are typically provided using the LSS or ULLS products, while Off-Net services are supplied using either WLR (for voice services) or WDSL (for broadband services).

For example, Optus reports a split of approximately 99% On-Net and 1% Off-Net broadband subscribers. While their public reporting does not distinguish whether LSS or ULLS are employed to provide the On-Net services, the variances for port charges for these service are approximately 78% and 16% respectively. The table demonstrates that based on their publicly reported mix of services, both Wholesale Customers are likely to be treated more favourably than Telstra’s retail business units in relation to the bundle of services they purchase.

Table 3. Estimated Variance between IWP and EWP for Selected Wholesale Customers

Reported SIOs ‘000s

Reported On-Net

SIOs

Reported Off-Net

SIOs

Weighted Variance Q2

Optus1 Voice (exc HFC) 490 96% 4% 10%

Broadband (exc HFC) 512 99% 1% 10% to 69%

TPG2 Voice 591 92% 8% 8%

Broadband 777 92% 8% 8% to 62%

Notes: On-Net and Off-Net SIOs are as publicly reported (see footnotes).

Voice Weighted Variance calculated using Q2 variances for ULLS (for On-Net) and WLR (for Off-Net)

Broadband Weighted Variance ranges calculated using Q2 variances for ULLS and LSS (for On-Net) and

WDSL (for Off-Net).

1 SingTel Group Results Q3 FY16, Historical Financial Summaries spreadsheet, "Optus Drivers" tab http://info.singtel.com/about-

us/investor-relations/financial-results

2 TPG Full Year Results Presentation, 22 Sep 2015, page 10 "Consumer: Broadband Subscribers" & page 12 "Consumer: Home

Phone Subscribers" https://www.tpg.com.au/about/pdfs/FY15_Annual%20Presentation.pdf (does not include iiNet data post merger)

http://info.singtel.com/about-us/investor-relations/financial-results

http://info.singtel.com/about-us/investor-relations/financial-results

https://www.tpg.com.au/about/pdfs/FY15_Annual%20Presentation.pdf



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3. Explanation of Results

In the SSU, Telstra commits to include an explanation for any differences of more than 5% between the IWPs and EWPs for Reportable Product Bundles. As indicated above, for Q2 FY16, the voice bundle, the voice and ADSL bundle and the bundle of all Reportable Wholesale Products have a Variance between the IWP and EWP of more than 5%.

The remainder of this report explains the reasons for differences between the IWPs and EWPs in more detail.

As the EWPs tend to be similar to the regulated prices for services included in the Reportable Product Bundles, the difference between IWPs and EWPs can be explained by the difference between IWPs and regulated prices. The former is calculated from TEM and the latter is calculated from the ACCC’s FLSM used to set the current regulated prices as part of the Fixed Line Services FAD 2015. TEM and the ACCC’s FLSM are quite different models - some of the major differences between these models are explained in section 3.1 of this report.

As discussed in section 3.2, the TEM uses historical financial information for operating and capital expenditure and demand relating to the relevant financial period, while the ACCC’s FLSM was based on forecast information.

A further explanation for differences between the IWPs and EWPs for ULLS and WDSL services is that the EWPs are largely based on geographically deaveraged prices, while the IWPs are based on geographically averaged costs. The effect this has on the difference between the IWPs and EWPs is discussed in section 3.3.

Finally, the regulated prices for services are set having regard to legislative criteria that are broader than what is measured by TEM reporting. In the setting of prices for some Regulated Services, those legislative criteria would be promoted by considering economic costs that are not counted in TEM. This is explained in section 3.4 of this report.

Table 4 sets out the applicable explanations for each of the individual services and Reportable Product Bundles.

Table 4. Summary of explanations for IWP/EWP Variances

Differences

between TEM

and the FLSM

Difference

between FLSM

forecasts and

TEM actuals

Geographic

differentiation

Other Economic

Costs

ULLS X X X X

LSS X X

WADSL X X X X

WLR X X X

Local Cal ls X X X

PSTN OTA X X XBU

ND

LE O

F FI

XED

WH

OLE

SALE

SER

VIC

ES

VO

ICE

AN

D

WD

SL

BU

ND

LE

VO

ICE

BU

ND

LE

Explanation affecting IWP/EWP variance (if any)



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3.1. TEM and the FLSM

The individual services underlying the Reportable Product Bundles are regulated by the ACCC and

subject to FADs. As such, the EWPs tend to be similar to the regulated prices set for those services,

although revenue allocations, product definitions, and commercially negotiated deviations from regulated

rates are causes for some differences. This is illustrated in Table 5 for Q2 FY16.

As noted earlier, the most recent FAD for regulated fixed line services set prices for the period

1 November 2015 to 30 June 2019, and so impacted on the EWP for two of the three months of the

quarter.

Table 5. Average Monthly EWPs and Regulated Prices Q2 FY16

The difference between the IWPs and the regulated rates (and EWPs), for all reportable wholesale

services, can be explained by the fact that IWPs are determined by the TEM whereas regulated rates

(and EWPs) were determined by the ACCC’s FLSM used during the Fixed Line Services FAD 2015.

TEM is not a regulatory cost model, it is the set of management accounts used by Telstra to measure

costs and revenues associated with specific services and to inform internal decision making. The FLSM

and TEM are fundamentally different models. Some of the major differences which have contributed to

the Variances in the reports include:

methods of cost allocation;

methods of unitisation;

timing of inputs; and

differences in inputs and definitions (including the WACC).

The methodologies of cost allocation in TEM differ from those used in the ACCC’s FLSM. The TEM

allocation factors are based on activity accounting methodologies, guided by the allocation principles set

IWP EWP Regulated

Price

TOTAL BUNDLE OF FIXED WHOLESALE SERVICES Per SIO 31.92 33.76

VOICE AND ADSL BUNDLE Per SIO 41.61 50.65

Wholesale ADSL In-Place Connection per connection 78.00 47.33 20.66 to 44.02

New Connection per connection - - -

AGVC per Mbps 33.89 30.85 29.27

Port Zone 1 per SIO 13.92 22.09 22.14

Port Zone 2 per SIO 17.55 27.86 26.87

VOICE BUNDLE Per SIO 25.27 29.61

Wholesale Line Rental (WLR) In-Place Connection per connection 39.89 45.98 n/a

New Connection per connection 192.90 222.37 n/a

Rental per SIO 64.30 20.87 20.69

Local Calls Usage per call 0.061 0.084 0.081

PSTN OTA Usage per end min 0.0121 0.0093 0.0086

Unbundled Local Loop Service (ULLS) Connection per connection 94.72 73.90 Variable

Port per SIO 18.23 15.26 14.68 to 43.65

Line Sharing Service (LSS) Connection per connection 107.40 47.70 Variable

Port per SIO 7.72 1.69 1.63

MTAS Usage per end min 0.036 0.036 0.036

Wholesale Services



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out in the SSU. They are also updated regularly to reflect the latest activity information. The FLSM’s

allocators were guided by the fixed principles in the ACCC’s FAD and adjusted by the use of an “NBN

scale adjustment”. They were set for the four-year regulatory period and so reflect forecasts made at the

beginning of that regulatory period. There are also specific differences in allocation methodologies. For

example, the TEM allocates network costs to all services that use the network, while for some network

costs (for example, CAN costs) the ACCC only allocated costs to a specific group of services.

With respect to unitisation, the TEM Report divides annual costs by actual demand for the Quarter. The

ACCC’s FLSM divided the annual revenue requirement (cost) by forecast demand.

Additionally, as mentioned above, the time period used in the TEM Report is significantly different from

that used in the FLSM for the 2015 FAD process. The TEM Report refers to the immediate past quarter

of actual financial results and uses demand for that quarter, while the FLSM sets prices for the current

regulatory period based on forecasts for both costs and demand for the financial years 2015/16 through

to 2018/19. These timing differences mean that outputs from TEM, which represent a point-in-time,

should not be expected to match the outputs of the FLSM which reflects the average prices from a long-

term forecast.

The TEM Report also uses different inputs to the FLSM, including asset lives, value of some assets,

depreciation rates, and the WACC, amongst other items. It also has different definitions for services that

can affect any comparison. For example, the FLSM defined OTA and LCS to include the sum of all retail

and wholesale minutes, while TEM treats retail and wholesale minutes separately.

As a further example, if we replace the WACC used in the FLSM with the post-tax equivalent of the pre-

tax WACC used in the TEM Report, the resulting external wholesale prices for the fixed line services

would be [Commercial-in-confidence commences] [Commercial-in-confidence ends] higher. Note also

that the WACC used in the FLSM was held constant for the Regulatory period, whereas the WACC used

in the TEM Report is reviewed regularly and updated where appropriate.

Table 6. Difference between average FLSM prices for 2015/16-2018/19 using ACCC WACC and TEM WACC

[Commercial-in-confidence commences]

[Commercial-in-confidence ends]

3.2. Forecast versus actual data

As mentioned in Section 3.1, the TEM uses financial information from Telstra’s accounting systems,

including historical operating and capital expenses, and demand that relates to the relevant financial

period. In contrast, the ACCC’s FLSM used during the Fixed Line Services FAD 2015 was a forward-

looking model that used forecasts for operating and capital expenses and demand over the regulatory

period. Table 7 illustrates the difference between the operating expense and demand forecasts used in

the FLSM and actual operating expenses and demand reported in the TEM Quarterly reports.

Table 7. Differences between Operating Expense and Demand forecasts and actual



3.3. Geographic differentiation

While different wholesale services tend to be purchased at different prices in different geographic areas

(e.g. ULLS is typically purchased in lower cost areas and WDSL services tend to be purchased in higher

cost areas), TEM is unable to differentiate costs geographically in the same way, as Telstra’s financial

systems do not capture this information.

For example, the WDSL EWP depends on geographically de-averaged prices, while the WDSL IWP is

calculated using geographically averaged costs. The revenue per WDSL Zone is identifiable but the

WDSL expenses and capital are not, as Telstra’s financial systems are unable to determine the same



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geographic split. The IWP for WDSL by Zone was calculated by allocating costs as per the proportional

revenue for each Zone.

At the same time, the take-up of WDSL services in regional areas (Zone 2 and Zone 3) is

disproportionate compared to the take-up of all ADSL services. As at December 2015, [Commercial-in-

confidence commences] [Commercial-in-confidence ends] of WDSL services were acquired within Zone

2/3, compared to [Commercial-in-confidence commences] [Commercial-in-confidence ends] for all retail

and wholesale ADSL services. As a result, the WDSL EWP, which reflects this bias in service take-up to

higher-priced regional areas, will naturally be higher than the IWP, which is mostly calculated on the

basis of costs averaged over all geographic areas.

ULLS exhibits similar issues, with the relative take-up of ULLS being highly skewed to ULLS Bands 1, 2

and 3, relative to the distribution of all access lines. As a result, care must be taken in comparing the

IWPs and EWPs for these services in isolation.

Table 8 illustrates the bias of take-up of ULLS and WDSL services and the impact on the average price

per SIO.

Table 8. ULLS and WDSL geographic distribution



3.4. Other Economic Costs

The regulated prices for services were set having regard to legislative criteria that are broader than what

is measured by TEM reporting. It is often the case that those legislative criteria would be promoted by

considering economic costs that are not necessarily counted in TEM, which measures accounting costs.

For example, the legislative criteria require a different approach to valuing land assets, to that applied in

TEM. Land assets are valued accounting for the cost of inflation, which promotes the legislative criteria,

while the TEM values land at historic cost. Land assets in the FLSM used during the Fixed Line

Services FAD 2015 were relevant to the pricing of WDSL, ULLS, WLR, local calls and OTA.



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4. Notes

From time to time there will be events which impact the costs and revenue included in the TEM Report,

and flow through to the IWPs and EWPs for the Reportable Wholesale Products and Reportable Product

Bundles.

4.1. Financial Events

A certain amount of volatility is expected in Corporate Administration and Support costs over the course

of a financial year. This can be attributed to periodic reviews of company-wide overhead costs which will

potentially impact any given TEM Report. Treatment of these costs has been consistent from a product

profitability perspective however their variable nature and subsequent influence upon results should be

considered.

As noted earlier in this report, the nature of the EWP and IWP variance metrics within the TEM reports means that they are susceptible to changes in unattributable costs such as corporate administration expenses, which will have highly variable impacts on individual quarterly results over the financial year.

Table 9 illustrates the variability of the total costs included in the Corporate Administration category over

the last four Quarters.

Table 9. TEM Report Corporate Administration Costs Q3 FY15, Q4 FY15, Q1 FY16 and Q2 FY16



4.2. Model Drivers

Telstra performs periodic reviews and updates of the inputs used in the TEM. These reviews may result

in differences between the results reported for each Quarter.

This Quarter coincided with an update of the WACC used in the TEM Report. The TEM Report uses the

endorsed Telstra pre-tax WACC to calculate the cost of capital. The corporate WACC is reviewed by

Telstra’s Senior Economist on a six-monthly basis and updated in the next submission of the TEM

Report. The timing of the WACC revision means that the impact may be seen at Q2 and Q4. The

updated WACC used in the TEM Report is lower than has been used in any previous TEM Report, and

this is due to an update in market-driven parameters, predominantly a reduction in the risk-free rate.

Table 10 illustrates the variability of the total costs included in the Cost of Capital for the Wholesale

Services over the last four Quarters.

Table 10. TEM Report Cost of Capital Q3 FY15, Q4 FY15, Q1 FY16 and Q2 FY16

[Commercial-in-confidence commences] [Commercial-in-confidence ends]

Depreciation costs can also show an amount of volatility quarter to quarter. A reduced depreciation

charge has been seen this period, as Telstra closely manages the service life of its fixed line assets to

accommodate the shifting access network landscape.

Table 11. TEM Report Depreciation Q3 FY15, Q4 FY15, Q1 FY16 and Q2 FY16





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5. Glossary

Term Definition

ACCC The Australian Competition and Consumer Commission

ADSL Asymmetric Digital Subscriber Line

AGVC Aggregated Virtual Circuit service

CAN Copper Access Network

EWP External Wholesale Price

FAD Final Access Determination

FLSM Fixed Line Services Model

IWP Internal Wholesale Price

LCS Local Carriage Service

LSS Line Sharing Service

PSTN Public Switched Telephone Network

PSTN OTA PSTN Originating and Terminating Access service

Reportable Product or Bundle Those products specified in the SSU which must be included in the TEM

Report

SIO Service in Operation

SSU Structural Separation Undertaking

TEM Telstra Economic Model

TSLRIC Total Service Long Run Incremental Cost

TW Telstra Wholesale business unit

ULLS Unbundled (unconditioned) Local Loop Service

WACC Weighted Average Cost of Capital

WDSL Wholesale ADSL service – covers both ADSL and ADSL2+ services

WLR Wholesale Line Rental service


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Appendix A – Quarter 2 2015/16 Results

Internal

Wholesale Price

External

Wholesale

Price

% Variation

(Costs Telstra retail

business units faces for

the same components

purchased by

w holesale customers)

(Average revenue

from supply to

w holesale

customers)

Wholesale Line Rental (WLR) In-Place Connection per connection 39.89 45.98 -15.28%

New Connection per connection 192.90 222.37 -15.28%

Rental per SIO 46.91 62.60 -33.46%

Local Calls Usage per call 0.06 0.08 -37.42%

PSTN OTA Usage per end min 0.012 0.009 23.22%

VOICE BUNDLE Per SIO 75.82 88.82 -17.15%

Wholesale ADSL In-Place Connection per connection 78.00 47.33 39.32%

New Connection per connection - - -

AGVC per Mbps 101.66 92.56 8.95%

Port Zone 1 per SIO 41.76 66.28 -58.71%

Port Zone 2 per SIO 52.65 83.57 -58.71%

VOICE AND ADSL BUNDLE Per SIO 124.83 151.95 -21.72%

Unbundled Local Loop Service (ULLS) Connection per connection 94.72 73.90 21.98%

Port per SIO 54.68 45.77 16.30%

Line Sharing Service (LSS) Connection per connection 107.40 47.70 55.58%

Port per SIO 23.15 5.08 78.07%

TOTAL BUNDLE OF FIXED WHOLESALE SERVICES Per SIO 95.77 101.29 -5.76%

MTAS Usage per end min 0.036 0.036 0.00%

Wholesale Services

Telstra TEM Substantiation Report Quarter 2 – …...The 2015/16 TEM Report for Quarter 2 (Q2 FY16)...

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