General

Digicel notes Flow’s continued characterisation of the Office’s development of this model as an ex ante exercise in the regulation of infrastructure pricing.

While it is clearly an ex ante exercise in identifying costing methodologies and developing a tool to allow an assessment of the merits of pricing disputes should one be raised, the consultation does not purport to set or impose prices for infrastructure sharing.

The fact that a model exists would allow the timely resolution of disputes should they arise.

Many of the issues raised by Flow would be cured by the updating of input values to reflect the actual fact circumstances of any dispute. In this regard Digicel draws a distinction between the ex ante development of the model and its ex post deployment.

Commercial realities mean that the incumbent will point out areas where it believes that the model underestimates cost and access seekers will point out areas where they believe it overcompensates the incumbent.

To the extent that benchmarks or other assumed inputs provided by the Office’s experts are used to populate the model this serves to allow an assessment of its correct operation and also provides both Access Providers and Access Seekers some indication of the likely range of pricing which such a model
might produce.

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