Principles

Alternative Forms of Regulation: Cost of Service, Price Cap, Revenue Cap, Benchmarking, Hybrid Approaches

Core References

Understanding Regulation: Theory, Strategy, and Practice
New York: Oxford University Press, 1999, Chapters 15, 17, and 18.
Baldwin, Robert, and Martin Cave

Discusses need for revenue to cover total cost. Describes rate of return regulation, price cap regulation using RPI-X, issues of excess returns, profit sharing approaches, error corrections, benchmarking, and yardstick regulation.

Comparison of Building Block and Index-based Approaches
paper prepared for the Utility Regulators Forum, Australian
Competition and Consumer Commission, 2002.
Farrier Swier Consulting

Examines price cap and revenue cap regulation in Australia, focusing on efficiency incentives, risk, robustness, transparency, simplicity, administration, and cost and availability of information required. Considers whether regulators should incorporate utility-specific factors, benchmarking, and appropriateness to statutory objectives.

Regulation: Price Cap and Revenue Cap
Public Utility Research Center Working Paper
Jamison, Mark

Describe the basic features of price cap and revenue cap regulation and how they are managed, including how to identify the proper context for each.

The Economics of Regulation: Principles and Institutions
Cambridge, MA: MIT Press, 1988, Reissue Edition, vol. I, Chapter 2.
Kahn, Alfred

Describes traditional rate of return regulation for the U.S.

Principles of Price Cap Regulation
in Infrastructure Regulation and Market Reform: Principles and Practice, edited by Margaret Arblaster and Mark Jamison. Canberra, Australia: ACCC and PURC, 1998, pp. 46-54.
King, S.

Explains that a price cap simply sets a maximum allowed inter-temporal path for the price of a specific product. The rules for the path are set in advance and only depend on factors that are beyond the control of the regulated firm. Finds that in practice, however, price caps tend to be more complex because firms produce multiple products and these products may be bundled together in the price cap, the price cap may automatically adjust for exogenous changes in specific prices that have strong implications for the profitability of the regulated firm, and price regulation may have associated regulation covering service quality. Explains that a variety of forms of price cap are used when a regulated firm produces multiple products, such as fixed weight price cap, average revenue regulation (current quantities), average revenue regulation (lagged quantities), and tariff basket regulation.

Sectoral References

ELECTRICITY

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 2.
Green, Richard, and Martin Rodriguez Pardina

Describes two major kinds of price control, namely price baskets and revenue yield controls. Describes how price baskets (price caps) allow a firm to charge more efficient prices by increasing some prices by more than the allowed average provided that others are increased by a lesser amount. Explains use of weights and two-part tariffs. Describes revenue control, which does not require the regulator to specify a list of prices, which may not be possible if the set of prices is complex. States that pass-through terms may be included in a price control if the firm faces significant costs that are both uncertain and outside its control, and if consumers can better bear the risk than can the firm. Mathematical formulae for both price basket and revenue yield controls are specified.

TELECOMMUNICATIONS

ICT Regulation Toolkit
Washington, D.C.: infoDev and the International Telecommunications Union, 2007, Module 2.

Describes different approaches for regulating telecommunications prices, including discretionary price setting, rate of return regulation, rate of return-incentive regulation (banded rate of return, rate case moratoria and earnings sharing), and price cap regulation.

Designing Incentive Regulation for the Telecommunications Industry
Cambridge, MA: MIT Press, 1996, Chapters 1 and 3.
Sappington, David E.M., and Dennis L. Weisman

Describes advantages and disadvantages of price cap regulation and rate of return regulation.

TRANSPORTATION

Transport Policies for the Euro-Mediterranean Free-Trade Area: An Agenda for Multimodal Transport Reform in the Southern Mediterranean
World Bank, Washington, D.C., 2007.
Muller-Jentsch, Daniel

Maps out national and cross-border policy reforms that would be needed to create a ‘common transport space’ that spans both sides of the Mediterranean sea. Benchmarks against international best practice; and draws lessons from the EU-internal reform experience in the transport sector.

Best Methods of Railway Restructuring and Privatization
CFS Discussion Paper Series, number 11, World Bank, Washington, D.C., 1995.
Kopicki, Ron and Louis Thompson

Focuses on “best” methods built on seven case studies of recent railway restructuring efforts. The case studies cover Japan National Railway, New Zealand Railways, Argentina Railways, Swedish Railways, British Railways, and railroads in the United States, and Canadian Railways.

Privatization and Regulation of Transport Infrastructure: Guidelines for Policymakers and Regulators
World Bank Institute Development Study, World Bank, Washington, D.C., 2000.
Estache, Antonio

Discusses privatization and regulation trends, price and quality regulation issues that characterize the sector, and performance indicators that the sector’s regulators should be able to rely on to be effective in their jobs.

Rate-of-Return and Price-Cap Regulations for Urban Railways
Osaka University, The Institute Of Social And Economic Research(I.S .E.R.), 6-1 Mihogaoka Ibaraki Osaka 567 Japan 1997.
Kidokoro, Y.

Using a simple model of commuter railways where congestion exists, shows that price cap regulation causes congestion compared to rate-of-return regulation, shows the following results: (i) price cap regulation, in which the cap is made contingent on congestion, can correct the congestion without distorting cost-reducing efforts, (ii) price cap regulation, in which the cap depends on investment in transportation capacity, can also correct the congestion but distorts cost-reducing efforts.

WATER

Setting water and sewerage price limits for 2005-10: Framework and Approach
Periodic Review 2004. March 2003.
OFWAT

Describes incentives for efficiency in Ofwat’s price cap system and how the benefits are passed on to customers.

Tariff Setting Guidelines: A Reduced Discretion Approach for Regulators of Water and Sanitation Services
Public-Private Infrastructure Advisory Facility (PPIAF), Working Paper no. 8, 2009.
Shugart, Chris and Ian Alexander

Provides specific guidelines for tariff setting for water and sanitation services, in addition to describing basic principles. Addresses price reviews, allowed revenue, appropriate amounts for operating expenses, valuing regulatory assets, foreign exchange adjustments, cost of capital, capital maintenance charges, capital expenditures, and extraordinary reviews.

Key Words

Incentive regulation, Efficiency, Rate of return, Cost of service, Price, Price cap regulation, Benchmarking, Revenue caps, Price basket controls, RPI-X, Yardstick regulation, Service quality, Rate base

Differences Between Alternative Forms of Price Regulation: Allocation of Risks and Incentive Properties, Ability of Company to Adjust Individual Prices Within Overall Price Control, Incentives, and regulatory Procedures

Core References

Risk, Volatility and Smoothing: Regulatory Options for Controlling Prices
1999.
Alexander, Ian and Chris Shugart

Examines price caps, revenue caps, and hybrids. Considers advantages and disadvantages, with particular attention to price volatility. Discusses options for addressing price volatility.

Introduction to the Fundamentals of Incentive Regulation
in Infrastructure Regulation and Market Reform: Principles and Practice, edited by Margaret Arblaster and Mark Jamison. Canberra, Australia: ACCC and PURC, 1998, pp. 37-45.
Berg, S.

Explains that incentive regulation is about creating incentives for the utility to adopt efficient pricing and patterns of investment, that the need for incentive regulation comes about from the inherent informational asymmetries that exist between utility and regulator, and that successful regulation will depend largely upon the degree of incorporation of relevant fundamental economic principles in the design of an incentive mechanism for each particular case.

Comparison of Building Block and Index-based Approaches
paper prepared for the Utility Regulators Forum, Australian Competition and Consumer Commission, 2002.
Farrier Swier Consulting

The Economics of Regulation: Principles and Institutions
Cambridge, MA: MIT Press, 1988, Reissue Edition, vol. I, Chapter 2, vol. II, Chapter 2..
Kahn, Alfred

Describes rate of return regulation for the U.S. Describes of regulation distorts incentives for efficiency.

Sectoral References

ELECTRICITY

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 2.
Green, Richard, and Martin Rodriguez Pardina

States that price baskets (price caps) are only feasible when the set of prices is relatively small and unchanging, and some limits on price rebalancing may be appropriate. Describes disadvantages of revenue-yield control. Says that “revenue drivers” must be included in the formula to tie total revenue to factors such as the number of customers and sales to each customer group; specific examples are given and discussed.

TELECOMMUNICATIONS

ICT Regulation Toolkit
Washington, D.C.: infoDev and the International Telecommunications Union, 2007, Module 2.

Describes weakness of rate of return regulation, incentives of earnings sharing mechanisms and rate case moratoria. Explains that price cap regulation is meant to provide incentives that are similar to competitive market forces. Advantages of price cap regulation are detailed.

Competition in Telecommunications
Cambridge, MA: MIT Press, Chapter 2.
Laffont, Jean-Jacques, and Jean Tirole

Describes economics of price cap regulation for telecommunications. Provides narrative and technical explanations.

Designing Incentive Regulation for the Telecommunications Industry
Cambridge, MA: MIT Press, 1996, Chapters 1 and 3.
Sappington, David E.M., and Dennis L. Weisman

Compares price cap regulation and rate of return regulation for telecommunications.

The Effects of Incentive Regulation on Retail Telephone Service Quality in the United States
Review of Network Economics 2(4): 356-375, December 2003.
Sappington, David E. M.

Describes how price cap regulation affects service quality in telecommunications.

TRANSPORTATION

A Primer on Efficiency Measurement for Utilities and Transport Regulators
Washington, D.C.: World Bank Group, 2003.
Coelli, Tim, Antonio Estache, Sergio Perelman, and Lourdes Trujillo

Reviews regulatory techniques for recently “privatized” utilities and transport services. Designed as a starter kit, surveys the options available and provides guidelines as to how to chose between these options, identifying the costs and benefits of the various approaches in situations most relevant to regulators. Covers the measurement of efficiency in the context of a tariff revision aiming at redistributing at least some of the efficiency gains from the producers to the users. Also addresses the challenges from comparative efficiency assessments allowing the introduction of yardstick competition.

Other References

Price Caps, Rate-of-Return Regulation, and the Cost of Capital
Note no. 87 in Public Policy for the Private Sector. Washington, D.C.: World Bank Group, September 1996.
Alexander, Ian, and Timothy Irwin

Demonstrates that price cap regulation results in a higher cost of capital for regulated firms than does rate of return regulation, indicating that price cap regulation shifts risk from customers to shareholders.

Privatization: An Economic Analysis
Cambridge, MA: MIT Press, 1988, Chapter 4.
Vickers, John, and George Yarrow

Explains Averch-Johnson effect, regulatory lag, information asymmetries, RPI-X regulation and Ramsey pricing, and implications of competition.

Key Words

Incentive regulation, Efficiency, Information, Rate of return, Cost of service, Price, Price cap regulation, Benchmarking, Revenue caps, RPI-X, Yardstick regulation, Service quality, Rate base

Use of Extraordinary Price Adjustments and Other Techniques for Handling Major Changes in Financial/Economic Equilibrium

Core References

How to Determine the X in RPI – X Regulation: A User’s Guide
Telecommunications Policy 24(1): February 2000, pp. 63-68.
Bernstein, Jeffrey I., and David E. M. Sappington

Explains that the proper choice of an X-factor is critical for price cap regulation. Too small an X-factor could lead to excessive profits and thereby jeopardize the legitimacy of the regulator. Too large an X-factor could hurt the financial integrity of the operator. The X-factor should reflect the extent to which the regulated industry has historically achieved higher productivity growth and faced lower input price inflation than other industries in the economy. Details, conditions, and exceptions are examined.

Incentive Regulation in Water – Case Study
in Infrastructure Regulation and Market Reform: Principles and Practice, edited by Margaret Arblaster and Mark Jamison. Canberra, Australia: ACCC and PURC, 1998, pp. 68-74.
Booker, A.

Explains that to ensure real productivity gains in U.K. water regulation, Ofwat introduced quality service monitoring. The initial caps were allowing substantial profits, which were retrieved using a glide path. The second periodic review will take even more notice of service quality and place more importance on environmental concerns.

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 4.
Green, Richard, and Martin Rodriguez Pardina

Describes how regulators choose the form of price control in a price review process. Describes pass-through terms for price caps and revenue caps.

Explains that in price caps, the regulator decides how input prices are to be passed through to consumers, as any allowed cost pass through will reduce incentives to minimize costs. Another key design issue is the price review. Further explains that any ‘allowed profit’ aspect to price cap reviews – including using past performance to set future price caps – will tend to reduce the incentives of an operator to reduce costs. Raising an X-or a catch-up factor if the firm exceeds expected productivity performance also decreases incentives to improve performance.

Key Words

Incentive regulation, Efficiency, Information, Rate of return, Cost of service, Price, Price cap regulation, Benchmarking, Revenue caps, Price basket controls, RPI-X, Price review, Yardstick regulation, Service quality, Rate base

Treatment of Different Categories of Costs (Controllable vs. Non-Controllable) in Price Controls

Core References

The Regulation of Investment in Utilities: Concepts and Applications
Washington, D.C.: The World Bank, 2005.
Alexander, Ian, and Clive Harris

Examines approaches for determining whether assets should be included in the rate base.

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 4.
Green, Richard, and Martin Rodriguez Pardina

Explain that the past and future projected operating costs of the regulated firm should be collected from the firm and broken down by customer group, activity (such as customer service), and category (such as labor). Further explains that the regulator should divide these costs into three groups: ongoing controllable costs, ongoing uncontrollable costs, and one-off costs. Holds that the best available forecast of uncontrollable costs should be included in the projected cost, while some type of benchmarking or yardstick competition should be used to set a target for controllable costs that an efficient firm could meet.

Sectoral References

ELECTRICITY

Incentive Regulation and Multi-year Price Controls: An Application to the Regulation of Power Distribution in India
International Journal of Regulation and Governance 1(1): 25–46, 2001.
Alexander, Ian and Clive Harris

Considers regulator’s ability to commit to multi-year tariffs. Finding that such commitments are not credible, evaluates whether this is a barrier to incentive regulation. Considers a hybrid incentive methodology that rewards for improvements in efficiency for items under the operator’s control.

Pass Through of Power Purchase Costs: Regulatory Challenges and International Practices
Washington, D.C.: The World Bank, February 2004.
Arizu, Beatriz, Luiz Maurer, and Bernard Tenenbaum

Explains the importance of rules on pass through of power purchase costs. Identifies, compares and contrasts pass through methodologies used in both developed and developing countries. Presents lessons learned and best practices. Recommends pass through methods that rely on market prices and competitive procurements. Considers cases where data restrictions necessitate an evolutionary path for pass-through regulation.

Regulation by Contract: A New Way to Privatize Electricity Distribution?
Energy and Mining Sector Board Discussion Paper Series Paper no. 7, March 2003.
Bakovic, T., B. Tenenbaum, and R. Woolf

Explains that most regulatory contracts specify a multi-year system that includes a formula that distinguishes between controllable and non-controllable costs. Changes in non-controllable costs are automatically passed through. Changes in controllable costs are benchmarked. States that pass-through of non-controllable costs should be done frequently and automatically. Holds that a common mistake made in designing a multi-year system is the failure to distinguish between degrees of effective control. The nature of control over a particular cost item may be quite different between developed and developing countries.

TELECOMMUNICATIONS

ICT Regulation Toolkit
Washington, D.C.: infoDev and the International Telecommunications Union, 2007, Module 2.

States that price cap regulation is meant to provide incentives that are similar to competitive market forces. The formula is designed to permit an operator to recover its unavoidable cost increases through price increases, but also requires the operator to lower its prices regularly to reflect productivity increases that an efficient operator would be expected to experience.

TRANSPORTATION

Regulation and Deregulation of the Motor Carrier Industry
Ames, Iowa: Iowa State University Press, 1989.
Felton, John Richard and Dale G. Anderson

Describes the problem of rate inflexibility with regard to space and time in transportation services. Uses the backhaul problem and peak load pricing to illustrate the theory. Presents regulatory experience of the trucking industry in Great Britain and Australia, as well as the United States.

Key Words

Incentive regulation, Efficiency, Information, Rate of return, Cost of service, Price, Peak-load pricing, Price cap regulation, Benchmarking, Revenue caps, Price basket controls, RPI-X, Price review, Yardstick regulation, Service quality, Rate base, Controllable costs, Non-controllable costs

Trade-Offs Between Flexibility and Predictability of Regulatory Arrangements

Core References

Understanding Regulation: Theory, Strategy, and Practice
New York: Oxford University Press, 1999, Chapters 6, 17, and 21.
Baldwin, Robert, and Martin Cave

Examines practices for ensuring quality regulation, considering the role of legislation, due process, and agency expertise. Discusses tradeoffs between predictability and flexibility in price cap regulation. Also examines accountability of the regulatory agency, with attention to oversight of regulatory agency by legislative bodies, government, appeals bodies including courts, super-agencies, and consumers.

Developing Network Monopoly Price Controls: Workstream A: Regulatory mechanisms for dealing with uncertainty
A final report prepared for Ofgem, March 2003.
Frontier Economics

Develops a framework for examining the best regulatory response to uncertainty. Considers the “tension between offering the firm incentives to reveal its efficient cost level, and offering it insurance against unforeseen events,” including how the regulatory response affects operator incentives and vulnerability.

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 6.
Green, Richard, and Martin Rodriguez Pardina

Explains that one disadvantage of revenue-yield control is that while prices are set initially, revenue cannot be checked until after the fact, which means that a correction factor should be included in the revenue cap formula. Pass-through terms may be included in a price control if the firm faces significant costs that are both uncertain and outside its control, and if consumers can better bear the risk than can the firm.

Privatization, Restructuring, and Regulation of Network Industries
Cambridge, MA: MIT Press, 1999, Chapter 2.
Newbery, David M.

Examines problems of regulatory commitment and how it impacts credibility and various regulatory instruments.

Sectoral References

ELECTRICITY

Regulation by Contract: A New Way to Privatize Electricity Distribution?
Energy and Mining Sector Board Discussion Paper Series Paper no. 7, March 2003.
Bakovic, T., B. Tenenbaum, and R. Woolf

States that the tariff-setting system should include a mechanism for the pass-through of costs associated with unanticipated external events such as natural disasters or major changes in law, regulations and some taxes. Whenever possible, the regulatory contract should include specific “trigger” mechanisms to adjust tariffs for extraordinary events. In developing countries, the civil law concept of restoring the enterprise’s “financial-economic equilibrium” is not a workable approach for dealing with extraordinary events.

TELECOMMUNICATIONS

Designing Incentive Regulation for the Telecommunications Industry
Cambridge, MA: MIT Press, 1996, Chapters 3, 4, and 7.
Sappington, David E.M., and Dennis L. Weisman

Examines the features and economic effects of various forms of regulation, including rate of return regulation, earnings-sharing plans, revenue-sharing plans, and price cap regulation. Discusses regulatory goals, priorities, and resources. Also examines the importance of regulatory commitment, including causes of lack of commitment, the effects of lack of commitment, and the implications of low commitment powers for designing incentive regulation.

Main Steps in Conducting a Price Review

Core References

Understanding Regulation: Theory, Strategy, and Practice
New York: Oxford University Press, 1999, Chapter 17.
Baldwin, Robert, and Martin Cave

Describes how to review prices under price cap regulation.

Describes the steps Ofwat took in its early price reviews.

Note: Green (1997) and the Green and Pardina (1999) are substitutable for each other.

Utility Regulation – A Critical Path for Revising Price Controls
Note no. 133 in Public Policy for the Private Sector. Washington, D.C.: World Bank Group, Nov. 1997.
Green, R.

States that the regulatory process needs to begin two years before the new control is due to come into effect. Explains that the review process includes: (1) Gathering and analyzing information on costs, investment plans, and demand forecasts; (2) Forecasting revenue requirements; (3) Choosing whether to use price caps or revenue caps; (4) Projecting revenue and cash flows using different price control parameters (such as the service baskets and the anticipated efficiency gains) to find a set of parameters that result in the appropriate cash flows; and (5) Making the announcement. Holds that the regulator should release information at several stages of the review process so that interested parties are kept informed. Suggests the following time table: (1) Request information (2 years ahead); (2) assess and amend information (18 months ahead); (3) determine form of control and rate of return (15 months ahead); (4) calculate revenue needs (1 year ahead); (5) select candidate price control and predict revenues, iterating until match revenue needs (1 year to 9 months ahead); (6) Propose price control (9 months ahead); (7) complete appeal process (3-9 months ahead); (8) implement price control (1 month ahead).

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999.
Green, Richard, and Martin Rodriguez Pardina

Identifies four stages a regulator should follow in resetting a price control, namely information gathering, analysis and decision-making, announcement (and possible appeal), and implementation. In this framework, the regulator would: (1) collect information from the firm, focusing on the future; (2) gather information and views from other interested parties; and (3) communicate with the firm and all interested parties throughout the process to increase the likelihood of acceptance of the final outcome of the review. Describes processes for analyzing financial information: (1) Firm projections about the future are compared against independent evidence when possible, and the reported costs and investment plan should be evaluated to see if they are reasonable; (2) The amount of revenue necessary to cover costs is calculated and transformed into a price control given demand forecasts; (3) announce the new price control as soon as possible to allow the firm time to react and possibly appeal. Possible outcomes may be discussed during the review process, to hear reactions and allow the parties to become used to the proposals before they are finalized. The new price control may be integrated into the company’s concession contract and enforced by the regulator. Examples of each of these stages are described for Argentina and the U.K.

Sectoral References

WATER

OFWAT Annual Report 2003-2004
2004.
OFWAT

Outlines how Ofwat regulates prices and sets out plans for upcoming price review.

Key Words

Incentive regulation, Information, Regulation, Price, Price cap regulation, Benchmarking, Revenue caps, Price basket controls, RPI-X, Price review, Yardstick regulation, Service quality, Rate base

Establishing the Duration of the Price Control

Core References

Resetting Price Controls for Privatized Utilities: A Manual for Regulators
Washington, D.C.: World Bank, 1999, Chapter 4.
Green, Richard, and Martin Rodriguez Pardina

Explains that in setting the duration of the price controls, a regulator must trade off the productive efficiency that increases with duration against allocative efficiency, which decreases with duration if prices become significantly higher than costs over time. That is to say, the regulator must weigh the increased incentives of long intervals against the risks that prices will get out of line with costs. Holds that during privatization, longer intervals may be beneficial since there may be considerable scope for efficiency gains. Suggests that including a provision in the price control that specifies when an early price review could take place might also be beneficial.

Designing Incentive Regulation for the Telecommunications Industry
Cambridge, MA: MIT Press, 1996, Chapter 3.
Sappington, David E.M., and Dennis L. Weisman

Key Words

Incentive regulation, Information, Price cap regulation, Benchmarking, Revenue caps, Price basket controls, RPI-X, Price review, Yardstick regulation, Service quality, Rate base

Case Studies

Governance and Regulation: A Tale of Two Concessions in Argentina
in Spilled Water: Institutional Commitment in the Provision of Water Services, edited by William Savedoff and Pablo Spiller. Washington, D.C.: Inter-American Development Bank, 1999, pp.197-248.
Artana, Daniel, Fernando Navajos, and Santiago Urbiztondo

Rules for Setting Distribution Wheeling Rates for Privately Owned Electricity Distribution Utilities Operating Under Performance Based Regulation
(First Entry Group: Third Regulatory Period)
Energy Regulatory Commission, 2009
Republic of the Philippines

Regulatory Reset for the July 2011 to June 2015: Third Regulatory Period for the First Entry Group of Privately Owned Distribution Utilities Subject to Performance Based Regulation (Position Paper)
Energy Regulatory Commission, 2009
Republic of the Philippines

Managing the Regulatory Process: Design, Concepts, Issues, and the Latin America and Caribbean Story
Washington, D.C.: The World Bank Group, 1999, Chapter 7.
Guasch, J. Luis, and Pablo Spiller

Financeability
in CRI Regulatory Review – 2006/2007, University of Bath School of Management, pp. 421-444.
Mason, Keith

Electricity Distribution Price Control Review: Initial consultation
July 2003.
Ofgem

Final Determinations. Future Water and Sewerage Charges 2000-05: Periodic Review 1999
November 1999.
OFWAT

Setting water and sewerage price limits for 2005-10: Framework and Approach
Periodic Review 2004. March 2003.
OFWAT

OFWAT Forward Programme: 2004-05 to 2006-07
31 March 2004.
OFWAT