REGULATION OF THE PRIVATE PROVISION PUBLIC WATER-RELATED SERVICES

1. Vertical and horizontal restructuring

(a) Horizontal restructuring
(b) Vertical restructuring
(c) Structural reform and service provision in rural areas

As a matter of general principle, public policy should seek to isolate the natural monopoly elements in an industry and to prevent the firms entrusted with activities with natural monopoly characteristics from extending their monopoly powers beyond the segment of the market where these characteristics exist (Vickers and Yarrow, 1988). This objective can be achieved by detaching, by means of restructuring or contractual arrangements, the potentially competitive activities from those which are natural monopolies or characterized by other categories of market failure, and opening them to various forms of competitive provision (see Figure 3).

When sunk costs are not pervasive in an industry, but rather are centred in a particular sector of its operation, "by isolating the activities with which the heavy sunk costs are associated, their damaging consequences can be quarantined" (Baumol, Panzar and Willig, 1982). Recent advances in economic theory and technological innovations have contributed to the understanding that some water resource development activities commonly regarded as natural monopolies or characterized by other categories of market failure in fact "bundle" together the activities in which market failure is not important with those in which it is. Many elements of market failure inherent in the provision of water­based services are associated with some, very specific, elements of market structure and do not occur equally in all parts of a water management system. The rest of the system comprises artificial monopoly, and therefore the appropriate policy response is the application of general competition and anti­trust policy.

The most common firm in water­based services is an integrated utility responsible for all aspects of service provision in the area under its jurisdiction. For example, the provision of network facilities, whether for drinking water supply, sewage or electricity, exhibits scale economies of such significance that they can be regarded as natural monopolies, but these economies are less important in the case of water extraction and treatment, wastewater treatment and electricity generation, and hardly exists in certain drinking water supply, sanitation and irrigation technologies.

The problem with the integrated model is that a market failure in the provision of one service may allow its provider to gain an unfair advantage over other firms in the services which are potentially competitive. Functional separation promotes competition by separating out ­ to the extent permitted by economies of scale and scope ­ the potentially competitive elements from those in which competition is inevitably imperfect. It seeks to leave the maximum number of operations to the free market and to limit industry­specific conduct regulation to the segment of the industry that is inextricably associated with heavy sunk costs.

Other potential benefits of functional separation include expanding the domain of economic activity in which there is effective competition, increasing the spectrum of opportunities for private sector participation (e.g. by increasing the scope for franchising), reducing the asymmetry of information between regulator and firm, and improving the quality and quantity of the information available to the regulator. It should improve management accountability and increase efficiency by allowing operators to specialize provided that adequate incentives and channels for communication and coordination are incorporated into the institutional design.

Functional separation is, however, by no means a panacea. For example, vertical or horizontal integration which apparently reduces competition may also raise efficiency. The potential benefits of structural reform may also be counter­balanced by other concerns such as the encouragement of a higher rate of service expansion and the achievement of higher service quality. To decide whether and how to effect separation, many factors need to be carefully analyzed, such as technical, technological and economic constraints to separation and the legacy of history and institutions. Attempts to separate closely interdependent activities can impose high costs on the sector, including the loss of the economies of scale and scope for each firm as its size and service area fall and the costs of sector restructuring, which need to be carefully weighted against the potential benefits of cost­minimizing behaviour under competitive pressure.

The network characteristic of most water sector activities raises the possibility that the efficient operation of the system as a whole will not be achieved without adequate mechanisms of central coordination. This can impose high transaction costs as the coordination between several independent and rival firms is inherently more difficult and costly and less effective than within a single organization. The experience of successful integrated organizations questions the wisdom of excessively dismembering the integrated production, particularly where integration involves significant technological and transactional economies, and suggests that undue fragmentation can lead to serious misallocation of resources and over­investment. Fragmentation of responsibilities for planning, investment, operations, maintenances, and debt services may lead to lack of accountability and inefficiency because actors do not have an appropriate level of control over decisions and actions that affect their efficiency (Triche, 1990).

Where economies of scale and scope are significant for a relevant market size, water sector services can be provided more economically by a single supplier and separation will raise the costs of service provision (see Figure 4). On the other hand, the existence of potential benefits is not sufficient to ensure that they will be effectively realized under monopoly provision. It is possible that the inefficiencies resulting from the sacrifice of economies of scale and economies of scope would be more than off­set by efficiencies resulting from a competitive market structure and advantages of flexibility and proximity to clients that smaller organizations usually enjoy. Large organizations suffer from organizational diseconomies of scale. In the real world where a monopoly without external pressure usually undertakes only limited cost minimization activity, the introduction of competition, even in a naturally monopolistic industry, could result in lower costs.

To the extent that effective competition can be established, in the long run the costs of making wrong separation decisions about the initial post­privatization industrial structure may not be too severe (Vickers and Yarrow, 1988). In theory at least, the subsequent evolution of market structure, through mergers, new entry, division, takeovers, etc. will take care of the problem. This underlines the importance on injecting as much competition as possible in the water sector at the moment of privatization. Unfortunately, the underlying technological and market conditions of many water­related activities are such that there are limits to substantially increasing competition, as in drinking water supply and sewerage, but in others, particularly in hydroelectricity generation and, possibly, wastewater treatment, there are greater possibilities.

For example, in the privatized water industry in England and Wales, spatial competition currently takes two forms ­ new appointments for new developments within existing allocated company areas (see Box 4) and cross boundary competition where a company must respond to requests for domestic water from any customer regardless of location (OFWAT, 1995f). The customer would have to meet any costs involved in providing the necessary pipework. The possibility of extending cross boundary access to non­domestic water supplies is being considered.

Horizontal separation in the electric power generation sector would tend to encourage inter­utility competition, conclusion which is confirmed by the generally successful experiences of Argentina and Chile. In Argentina, for example, the three major federal utilities were broken into numerous concessions (Torres, 1995).

On the other hand, the exhaustion of economies of scale for generation does not in itself guarantee that a full and effective competition will emerge from horizontal separation. For example, the effects of potential entry on market behaviour may generally be small, particularly is the short­ and medium­term, because of the importance of sunk costs in generating plant investments, the lumpiness of those investments, and the ability of generators to communicate price changes rapidly (Schmalensee and Golub, 1984). In the longer­term, new entry will depend on the growth of demand. Breaking­up an integrated utility can impose high costs on the sector which need to be carefully weighed against the potential benefits of cost­minimizing behaviour under competitive pressure.

If effective competition cannot be introduced through vertical separation on balance it may be better to leave the industry horizontally integrated (Bacon, 1994). The effects of horizontal separation would probably be negative in the economies at lower levels of development and small power systems because of the inability to exhaust economies of scale at the level of individual generators and the impossibility to adopt sophisticated bidding systems such as power pools. Furthermore, in the countries where such sophisticated devices cannot be made to work, horizontal separation will involve the extra cost of maintaining reserve margins against uncertainties.

For effective competition there should be a sufficient number of firms to avoid collusion and gaming in the system (Bacon, 1994). In the smaller and less developed countries, the market can be too small to support enough firms to achieve truly competitive behaviour, except at an unacceptable loss of economies of scale. A concentrated industry structure where generating capacity is concentrated in two or three firms which can influence the price at which electricity is purchased from them is likely to be seriously inefficient. Firms should be similar in size and cost structure, adequate transmission capacity should exists and transmission costs should be low. Entry into the industry (obtaining licenses, constructing the plants, etc.) should be easy and rapid and incumbents should not enjoy important cost advantages unavailable to new entrants (Bacon, 1994).

Horizontal separation along regional lines may tend, however, to encourage companies to develop geographic market sharing. As a result, competition would be constrained through tacit collusion not to compete for each others markets (Vickers and Yarrow, 1988).

Improved access to information. Even when horizontal separation leads to local monopolies, unless there is no correlation in the cost conditions among them, it enables regulators to have access to information from a group of independent providers of comparable services, characterized by a variety of common features in the input and output markets. This provides a basis for comparisons across those firms useful for setting incentives, based on relative performance, and hence opportunities for the implementation of more effective regulatory incentive structures ­ based on comparative yardsticks or benchmarks ­ than those that are feasible when there is only one firm.

The benefits of informational advantages in creating and maintaining many similar firms are more likely to outweigh the loss of economies of scale or scope where a regulated industry is mainly an aggregate of several local monopolies (e.g. drinking water supply and sewerage) than where the natural monopoly element is itself on a national scale (Beesley and Littlechild, 1989). The higher the correlation in the firms' environments, all else being equal, the more likely it is that the benefits from the enhanced effectiveness of regulation when there are several firms outweigh the possible loss of economies of scale and scope that functional separation would involve (Armstrong, Cowan and Vickers, 1994).

Although an increased number of firms can assist regulators by providing them with greater information and improving its quality, horizontal separation also implies that regulatory agencies will be faced with the prospect of regulating and monitoring different sets of tariff structures and service quality standards with variations in cost and other conditions (Vickers and Yarrow, 1988). This may cause serious administrative problems that could potentially impair the quality of regulation, particularly if the regulatory body does not have adequate resources.

The role of the capital market. The transferability of private ownership rights in the capital market reveals information via changes in share prices, which, if the market is efficient, capitalizes the consequences of current actions for future profits (Vickers and Yarrow, 1991). The existence of regional private companies exposes the industry to competition in the capital market where water sector utilities must complete for capital both among themselves and with other investment opportunities. By reducing the size of privatized utilities, horizontal separation facilitates acquisition and reorganization of the poorly performing utilities and facilitates the generation of comparative information with which shareholders can assess their performance (Bishop and Kay, 1989).

Although the capital market can encourage productive efficiency through competition in terms of corporate takeovers, this might conflict with the need to maintain a sufficiently large number of independent utilities to enable the regulatory agency to conduct benchmark competition (Armstrong, Cowan and Vickers, 1994). Restrictions on the concentration of shareholdings and the large size of public utilities, some of them rank among the largest private enterprises in the economy, can reduce the threat of takeovers (Bishop and Kay, 1989). In addition, since mergers increase industrial concentration and market power, there may be a loss of incentives for innovation and managerial efficiency. This implies that additional regulatory vigilance could be needed to ensure that customers are not penalized for any inefficiency.

This concern has led in England and Wales, to the DGWS to call for separate Stock Exchange listings for all regulated water companies after takeovers, mergers or where a company outside the water industry wishes to acquire a regulated water business, to ensure that sufficient transparency is maintained to allow effective regulation (Murray, 1995 and OFWAT, 1995r). One example is the Lyonnaise des Eaux/Northumbrian Water merger where OFWAT has secured agreement by Lyonnaise des Eaux to list its entire water interests in England and Wales on the Stock Exchange by the end of 2005 (OFWAT, 1995q and 1995r).

Capital markets also provide a powerful disciplinary force on poorly performing regulators. The stock market valuation of the firm changes following any action by the regulator as its decisions are reflected in the change in share prices, i.e. if the market regards the regulator's decision as less favourable to the firm than expected, its share price is marked down and its cost of capital increases and vice­versa (Beesley and Littlechild, 1989). For example, compering the stock market returns for a regulated company or industry with the returns for a comparable sample of unregulated companies provides a useful way to test whether there is a regulatory capture (Dnes, 1995). Capital market response to regulatory decisions provides a feedback to the regulator and its supervisors, i.e. political authorities and customers, about the decision it takes and constraints regulatory discretion by the expectations of shareholders and customers to whatever range they deem acceptable or can be so presented. The role of capital market is particularly important because of the problem of government or regulatory failure and because regulators may be ill informed about the consequences of particular regulatory decisions for the regulated industry.

(i) Vertical restructuring in drinking water supply and sanitation
(ii) Vertical restructuring in electricity

A utility can be described as being vertically integrated if it extends its activities over more than one successive stage of the production process of transforming raw water into final goods and services (Pearce, 1986). Vertical integration eliminates contractual or market exchanges, and substitutes internal exchanges within the boundaries of the utility (Perry, 1989). Vertical separation breaks up, or unbundles, activities previously performed by an integrated vertical monopoly. Typical examples of vertical separation are the division of a state­owned power utility into separate generating, transmission and distribution companies as has been done in Argentina.

There are three broad determinants for vertical integration: technological economies, transactional economies, and market imperfections such as imperfect competition, externalities and imperfect or asymmetric information (Perry, 1989). Vertical integration adopted by unregulated firms that are subject to a reasonable degree of competitive pressure generally promote efficiency and increase welfare. The negative consequences of strong vertical links may be sufficient to overturn the general presumption in favour of vertical integration where either (Yarrow, 1991):

· vertical arrangements are not the products of competitive process, e.g. have emerged from the pre­privatization structure of a sector; or

· there is a major horizontal failure of dominance or collusion; or

· there are existing regulatory controls.

Although, even where these conditions hold, the continuation of vertical integration can usually be justified on efficiency grounds (e.g. economies of scope), in regulated industries with natural monopoly elements, vertical integration usually does possess potentially negative effects on economic efficiency.

Vertical integration can allow a natural monopoly to extend its monopoly power to the non­regulated upstream and downstream markets. It can discriminate in its own favour or in favour of affiliated firms, increasing barriers to entry and foreclosing competitors ­ by means of prohibitive network access charges or discrimination in other terms of interconnection such as the quality of access. Such negative effects are associated chiefly with network services. The existence of regulation in one of the market segments can greatly enhance the incentive for the firm to use its market position to extract profits from other stages of production or distribution (Yarrow, 1991).

Some potentially competitive and not naturally monopolistic water­related activities, e.g. electricity generation and water extraction and treatment, are upstream from the distribution network which typically is a natural monopoly, while others e.g. wastewater treatment and commercial operations, are downstream. Effective competition in any of these activities will require a regulatory framework to ensure access on a fair basis to network facilities. Ownership of network facilities, by a vertically integrated firm, is not necessarily, however, a decisive obstacle to the emergence of competition. Advances in technology, changes in factor prices and in other market conditions can erode the advantages of vertical integration and create opportunities for new entry and competition.

Vertical integration tends to hamper effective conduct regulation and, in practice, it can be difficult to hold in check anti­competitive behaviour of vertically integrated firms by vertical conduct regulation without some measures of structural separation. Vertical integration usually worsens the asymmetry of information between regulator and firms and impairs the quality of the information available to the regulator. This hinders effective conduct regulation and provides opportunities for circumvention. As a result, to be effective, conduct regulation has to be more proactive and intrusive (Stewart­Smith, 1995).

The potential benefits of vertical separation have to be carefully balanced against the loss of the economies of scope and scale, the costs of sector restructuring, and the possible loss of some internalization of externalities. If these factors ­ in particular, economies of scope ­ are significant, there may be a case for the continuation of vertically integrated monopoly. If these factors are not so significant or the benefits of competition and of more effective conduct regulation are substantial, then vertical separation would be desirable. If parts of industry must remain vertically integrated, vertical conduct regulation or measures of partial vertical separation will be needed to establish conditions for effective competition.

There are various policy options for countering the negative effects of vertical integration short of breaking up the vertically integrated firm, including, laissez faire, establishing a right to interconnect with terms left to negotiations, using antitrust law to limit anti­competitive behaviour, publishing the terms of negotiated agreements, imposing terms if the parties fail to agree, and imposing public service obligations for interconnecting firms (Guasch and Spiller, 1994).

(i) Vertical restructuring in drinking water supply and sanitation

There are two separate natural monopolies in drinking water supply and sanitation ­ water distribution and sewerage collection (Vickers and Yarrow, 1988). Economies of scale are much less in raw water extraction and treatment and in wastewater treatment and disposal. The scope for increasing competition through vertical structural reform is, however, extremely limited because of the strength of the natural monopoly conditions which derive from the established local networks of water mains and sewers. The obstacles are the need for extremely tight coordination between the services, due to the interrelated demand, the high costs of service delivery, in relation to the costs of water production or wastewater treatment, and the fact that the experience gained and the equipment used in one is useful for the other.

One alternative for promoting competition is the use of franchising, specifically service contracts, concessions and BOT contracts (see UN/ECLAC, 1995b). Many water utilities already use franchise­type arrangements, especially for auxiliary activities such as cleaning, food catering, security, vehicle leasing, etc. It is also common to contract out administrative, commercial, training, technical assistance and standard professional services as well the managing of non­core assets and activities. Activities, such as construction, billing and collecting, meter reading, and operation and maintenance, can also be contacted. It is more complicated to ensure effective coordination, controls and supervision when contracting water production, treatment and distribution, and wastewater treatment, but it also can be done. Economies of scale are not sufficiently large to justify high levels of national or regional concentration of sewage treatment (Vickers and Yarrow, 1988).

In Latin American and Caribbean countries, water utilities have been usually heavily vertically integrated to a degree that they include all operational and support functions, including those which do not exhibit natural monopoly characteristics. Many utilities could realize substantial cost savings and enhance efficiency through vertical separation by means of franchise arrangements with private firms. Many activities can be opened to direct competition. For example, approved contractors can compete for connection work. In Chile, services not subject to regulation, including connections, may be undertaken by contractors or the customers themselves, subject to meeting approved standards (Chile, 1988). In Mexico, wastewater treatment is contracted out on a large scale (Mexico/CNA, 1993). The Mexico City franchises are an example of what can be done in the separation of functions (see UN/ECLAC, 1995b). In England and Wales, consideration is being given to allow developers and builders to carry out connection work, subject to company inspection (Byatt, 1996), and to oblige companies to put connections out to competitive tender (Buckley, 1996).

(ii) Vertical restructuring in electricity

Natural monopoly in the electricity sector is confined to the transmission and distribution systems. There is also, however, a need for very close minute­by­minute coordination between generation and transmission, since demand fluctuates randomly, supply is subject to unpredictable outages and equilibrium must be maintained continuously throughout the system (Armstrong, Cowan and Vickers, 1994). This provides powerful arguments in favour of a policy of vertically integrated monopoly for generation and transmission and explains why in most countries the two activities have typically been vertically integrated. Other arguments in favour of integration include optimal investment and capacity planning and operational coordination (IEA, 1994). Integration also facilitates the handing of power disruptions and supply emergencies.

The problem with the integrated model is that effective competition can be difficult to achieve because control over the transmission network would give its owner an enhanced ability to deter new entry and discriminate in favour of its own subsidiaries (see Paredes, 1995). The separation of electricity generation from transmission and distribution creates conditions for effective competition and encourages new entry. Various forms of competition between generators become possible under vertical separation ranging from contract competition to supply the transmission grid under long­term contracts, which may be tradable or not, to spot market competition (Armstrong, Cowan and Vickers, 1994).

Electricity pools simulate a competitive marketplace where generators compete for the right to supply bulk electricity in time slots (usually 30 or 60 minute periods) by specifying a supply schedule of price and quantity for the slot they wish to bid for (World Bank, 1994a). Although power pools facilitate competition and provide the prospect of the maximum gains from competition for customers, they are difficult and costly to develop and operate and these costs may outweigh the benefits while their complexity and volatility can discourage investment (Turgoose, 1995).

Spot markets in electricity can make prices volatile and unpredictable so that contracts between generators and distributors or large customers are widely used. Competitive discipline is maintained through contract competition. Although long­term contracts offer generators an adequate insurance against risks, contract specification is a complex task. Inefficiencies can arise because it is impossible to cater for every eventuality and there are difficulties with contract monitoring and enforcement. In addition, the grid operator needs to have considerable authority over generators to deal with short­run contingencies (Armstrong, Cowan and Vickers, 1994).

In the countries where the power market is small in relation to the minimum efficient scale of generation, suitable sites for new generating plants are few, transmission capacity is insufficient or the costs of sector restructuring are very high, the potential benefits from vertical separation will be restricted because any efficiency gains from increased competition would be offset by the loss of economies of scale and scope and the additional coordination costs. The effectiveness of competition under vertical integration depends on characteristics of the bidding process, the terms of access to integrated firm's network and on the configuration and evolution of the transmission and distribution systems.

An energy system, whether vertically integrated or not, which includes independent power producers has a number of important advantages over the traditional integrated utility. In addition to diversification benefits of having a number of independent generators, independent power producers have powerful incentives to ensure reliability and operate plants at optimal standards. In addition, competition provides a powerful market­based system of contract selection as each contract typically must pass at least four highly efficient financial and technical evaluations from those of the developer, the construction­lender, the equity participant and long­term creditors (Siddique, 1995). Many countries in the region already have or plan to have electricity systems incorporating independent power producers.

(c) Structural reform and service provision

in rural areas

Privatization combined with horizontal separation has given rise to the possibility of a deterioration in services provision in rural and remote areas, because market forces might tend to focus supply on strong­demand, low­cost areas, at the expense of sparsely populated and remote areas (Brun, 1991). It is argued that horizontal separation will eliminate cross­subsidies between urban and rural areas. These subsidies have been extensive within public utilities providing water­related services in urban and rural areas and have been the main mechanism for subsidizing services in rural and remote areas in many countries.

Separating service provision in urban and rural areas generally does not imply a major loss of economies of scale and scope, with the possible exception of some loss of economies of scale in administration and regulation, and of the possible benefits from some internalization of externalities. The technology widely used in rural areas means that rural drinking water supply systems are not natural monopolies or have low economies of scale. By isolating the urban service, horizontal separation could promote new entry and direct competition in rural areas. The benefits of cost­minimizing behaviour under competitive pressure can be counted on to offset, at least in part, any losses of economies of scale or scope.

Horizontal separation makes cross­subsidies between urban and rural areas more transparent, helps identify more precisely the subsidies needed to provide services in rural and remote areas, and improves accountability in service delivery. It also facilitates conduct regulation, because service providers will have less opportunity to circumvent regulation and because it allows for better performance comparisons and more efficient regulatory monitoring through benchmark competition.

Cross­subsidies between urban and rural sector are difficult to justify, except for political reasons. There is nothing intrinsically "fair" about cross­subsidies between two groups of a population where the supply of a product such as water or electricity to one group consumes more scarce resources than supply to the other. Poorly designed cross­subsidy schemes can also affect the international competitiveness of exporters. Direct assistance to the disadvantaged population groups generally would be more efficient, than to use market­distorting cross­subsidies to achieve income redistribution objectives (Stevens and Michalski, 1993).

Rural and urban drinking water supply and sanitation require different technological, institutional and financial approaches, therefore, it may not be wise to assign responsibility for the two to a single operator (Triche, 1990). Failure to effect horizontal separation can have perverse, unintended consequences for service provision in the rural areas, such as the application of urban standards. The continuation of subsidies can stifle the emergence of alternative technologies and forms of service provision better reflecting the needs and peculiarities of the rural sector.

For a long time it has been widely assumed that because of the special characteristics of rural areas ­ low population density and low income level ­ financially viable service provision of adequate quality is impossible there without an external subsidy. These considerations have led many governments to believe that rural people have only a basic need which can be best met by limiting services by supporting only low­cost technologies. This approach has restricted choices and has proved highly counterproductive, even in many instances offering services which do not correspond to what rural people want and has led to the so­called "low­level equilibrium trap" in which customers are not willing to pay for what they find to be an unsatisfactory service (Serageldin, 1994).

A recent multi­country study by the World Bank of households' demand for improved drinking water supply services found that household income, although important, is not the overriding determinant of demand for improved services, and that there are many villages in which most households' willingness to pay for reliable private connections is high relative to the costs of supply (Briscoe et al., 1993). According to the study, many more communities fall within this category than is commonly assumed. Although the study specifically refers to rural communities in northeastern and southeastern Brazil, its authors are of the opinion that, in general, most of the large rural communities in Central and Latin America probably fall in this category. In these communities a large proportion of rural people want and are willing to pay substantial amounts for private connections, and will pay more if the service is reliable.

The possible negative consequences of horizontal separation for service delivery in rural areas could be avoided by adopting measures to facilitate private sector participation in the provision of services in the rural areas where households face difficulties in paying the full cost of improved services. External subsidies can be maintained or other forms of fiscal equalization and spatial transfer could be adopted. Rural drinking water supply programmes should be, however, demand­driven, any subsidies should not distort the community's choice, and beneficiaries should mobilize a considerable portion of the resources (see Briscoe et al., 1993). Demand­side assistance, i.e. giving subsidies directly to households and not to utilities, should be encouraged because these ensure that the intended beneficiaries are properly targeted.

Where supply­side subsidies have to be used for rural drinking water supply, one option would be to award contracts either on the basis of an explicit, pre­specified subsidy, with the winning bidder quoting the lowest tariff, or on the basis of a given tariff, with the bidder quoting the lowest subsidy. Where initial connection charges are large and rural households cannot mobilize the funds needed to pay them, subsidies in the form of soft loans, recoverable over an extended period, would do more to improve households' welfare than price subsidies.

Community participation is often an essential feature of the provision of drinking water supply and sanitation services in rural areas. There is much evidence that projects with high levels of community participation are more likely to have the drinking water supply maintained in good condition (see Figure 5).

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