Building trust in regulation a global study of operator regulator relationships

No member fi rm has any authority to obligate or bind KPM G International or any other member fi rm vis-à-vis third parties, nor does KPM G International have any such authority to oblig

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w ith KPM G International KPM G International provides no client services No member fi rm has any authority to obligate or bind KPM G International or any other member fi rm vis-à-vis third parties, nor does KPM G International have any such authority to obligate or bind any

ECO N O M I CS & REG U L AT I O N

Building Trust in Regulation

A global study of operator-regulator relationships

A DV I S O RY

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1 Forew ord 1

6 KPM G Com m ent: Working m ore constructively together 11

8 KPM G Com m ent: Em erging issues in em erging m arkets 20

10 KPM G Com m ent: Building fi rm foundations for the

11 KPM G Com m ent: Tackling uncertainty, safeguarding

13 KPM G Com m ent: Converged data, im proved perform ance 31

5 BUILDING TRUST IN REGULATION

Contents

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Foreword

Trust is the glue that holds relationships together but also the lubricant that keeps things moving This study, from the Economist Intelligence Unit, commissioned by KPMG International examines the current state of trust between regulators and the industries they regulate around the globe

Many of the findings relate to the need for better communication and ensuring that regulators and operators can establish a common understanding between one another: concerns that KPMG firms care deeply about and work with many clients to address While it is encouraging that levels of trust seem to be improving, these relationships can be extremely fragile Moreover, as global economic uncertainty continues, the potential cost of related regulatory uncertainty is an unnecessary burden at a time when investment and revenues are under threat Now, more than ever, trust between parties

is critically important

This is not to say that we all ‘hug a regulator’, or that we throw away robust regulatory strategies, or that regulators shouldn’t take decisions that might negatively affect certain stakeholders, but it’s the environment in which you communicate those decisions that is important: one characterized by respect

We hope that the findings stimulate further thoughts in an area of consistent change and challenge and would be delighted to talk with you about what KPMG firms are doing

to help our clients build levels of trust that enable better regulation and benefi ts to the economy

Finally, I would like to thank the survey’s participants and interviewees for their time

David Thomas

Global Head of Communications Regulation, KPMG

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BUILDING TRUST IN REGULATION 2

About the research

KPM G International commissioned the Economist Intelligence

Unit to w rite Building Trust

in Regulation The report

is based on the follow ing research activities:

The Economist Intelligence Unit conducted

a survey, completed in 2009, of 213 executives w ho are closely involved w ith the regulation of current and former utilities The survey brings together practitioners from both sides of the commercial operator-regulator divide, including 165 respondents from operators and 48 from regulators All are closely familiar w ith their organization’s key regulatory relationships, and they hail from fiv e heavily regulated industries – telecommunications, power, water,

transport and post The survey sample

is global, w ith 36 percent of participants based in Europe, 23 percent in North America and 20 percent in Asia-Pacifi c

A total of 77 respondents – 36 percent

of the sample – are based in developing countries

To supplement the survey, the Economist Intelligence Unit conducted a program of interview s w ith senior executives of both commercial operators and regulators in the aforementioned industries We are grateful

to the survey participants and interviewees for sharing their valuable time and insights

The views and opinions expressed herein are those of the Economist Intelligence Unit and do not necessarily refl ect the views and opinions of KPMG International or KPMG member

fi rms The KPMG comment sections were written by professionals from KPMG member fi rms

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Executive summary

Recent revelations of failures in regulatory oversight have helped

to put regulation under the microscope

Effective regulation resulting in effi cient markets, however, is the result not only

of the regulator’s performance but also

of the quality of interaction between the regulator and the market’s commercial players In heavily regulated sectors

w here existing or former public utilities are dominant – telecommunications, power, water, transport and post1 – and w here policy reforms over the past two decades have created new regulatory bodies and competitors, relationships between regulator and regulated have frequently been troubled Trust is the foundation of any good relationship; it has arguably been

in shorter supply among market players in these sectors than others, and the lack of it has stifled aspects of market grow th even

in fast-grow ing economies

This study of operator-regulator2 interaction

in five heavily regulated sectors reveals, perhaps surprisingly, a large percentage

of regulatory relationships in w hich the parties deem the level of trust to be “ high”

However, the research – based on a global survey of 213 operator and regulator executives, as well as a series of one-on-one interview s w ith practitioners – also suggests that relationships in some sectors and parts of the world are weaker

than others It also makes clear that, even

w here relationships are good, trust is an extremely fragile commodity w hich does not take much to undermine M istrust often breeds uncertainty, w hich can have tangible negative consequences for market players

Follow ing are the main conclusions of the research:

• Operator-regulator relationships are evolving for the better This is

encouraging in a global context that has seen renewed calls for a more vigorous approach to regulating competitive markets M ore executives in our survey characterize the level of trust between operators and regulators in their sector

as “ high” than those w ho think the opposite, and more participants believe that operator-regulator relationships are improving than those w ho see deterioration Operators are less satisfied than regulators w ith the levels

of mutual trust, and operators in developed economies are not as positive in their assessments as their counterparts in the developing world But majorities of both operators and regulators in our survey expect improvement in their mutual relationships in the coming years

• Breakdow ns in trust often result from regulatory uncertainty, w hich can negatively impact industry development Uncertainty and a

resulting loss of trust carry a variety of

1 This study’s coverage of the power sector includes electricity and gas utilities In the transport sector the research focuses

on railways, airports and other ports

2 The term “ operator” is used in this report to refer to commercial service providers in the five sectors covered by our research Other terms, such as “ utility” or “ company”, are also commonly used in different parts of the world to describe these entities

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potential consequences for market

players, from direct financial losses to

an increase in litigation Operators in the

survey cite the most frequent outcomes

of regulatory uncertainty to be direct

increases in cost, lost revenue,

cancelled or postponed investments,

business initiatives put on hold or

increased litigation Taken at overall

market level, the uncertainty can

quickly translate into slower market

development and service penetration

• Achieving genuine trust between

operator and regulator hinges on

the development of a mutual

understanding of each side’s

objectives and constraints With each

party’s perception of the other shaped

by its ow n experience, culture and

market interests, the ability to

understand the influences and motives

driving the other side is a vital factor in

building trust Operators are adamant

that regulators must achieve a greater

appreciation of business operations and

risks Regulators, for their part, insist

that operators gain an improved

know ledge of regulatory and policy

objectives

• Transparency of processes and clarity

of the regulatory framework increase

levels of trust The trust gap w idens on

issues that are susceptible to political

influence and unpredictability, w hile

routine, process-oriented interaction

tends to proceed more smoothly for the

parties For example, both operators

and regulators highlight licensing as a largely problem-free area of interaction,

w ith monitoring and compliance, consumer protection, and data transfer also proceeding relatively smoothly

• Industry consultations, a key tool in building trust, w ill w iden the trust gap if they are more form than substance While the survey revealed a

consensus on the need for consultations

on key issues, several operators voice concern w ith the consultation process itself, complaining that regulators treat consultations as no more than a formality Generally speaking, operators also tend to value informal consultations over the public variety By contrast, regulators seem more wary of such informal exchanges, w hich they see as contradicting the need for transparency

• Trust suffers w ithout strong mechanisms to share relevant and accurate information The provision

of relevant information is another important rung in the trust-building ladder, but information-sharing remains

an area of friction between operators and regulators There is a substantial gap between the regulator’s need

of information to fulfill its mission, and operator w illingness to share information, ow ing to concerns around confidentiality and relevance of information Ultimately, the parties must work together to make the information-sharing process productive

• Processes and frameworks are important, but people and personal relationships are the critical ingredients in building trust Asked to

identify the most important contributors

to an effective operator-regulator relationship, both groups of survey respondents point w ith equal emphasis

to good personal rapport between senior executives from both parties Strong personal relationships help

to smooth potentially antagonistic relationships by offering each side some visibility into the motives and constraints of the other, and they ultimately help build trust among the parties

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Introduction

The role of industry regulation across the world has risen in prominence with

an economic crisis brought about – at least in part – by regulation in a number of sectors that appears to have been inadequate to the task

Even prior to the global dow nturn, however, the fundamental nature of market regulation was already evolving in a number of industries Rapid technological change and increased competition broke the traditional, silo-based structure of the telecommunications market, for example

In many countries, increased environmental concerns refocused regulation in the energy and water sectors even as they were being opened to competition Security considerations led to an expansion, in some parts of the world,

of the regulatory purview in the transportation sector

To societies and governments, the effective regulation of certain industries is a necessity in order to ensure that the latter’s services or products are made available to the population in as affordable, safe and efficient a manner as possible This is particularly the case w hen it comes to services provided by existing and former

“ public utilities”, such as telecoms, water, power, post and transport The suppliers of these services and products also benefi t from good regulation in many ways, but many of the largest suppliers tend to view regulation less as a virtue than as an unavoidable aspect of doing business Over the past two decades, markets for these services have been liberalized to some degree in many parts of the globe, resulting in the emergence of competitors

to erstw hile monopoly providers This has not only made the regulatory agencies’ tasks more complex, but has greatly

“As a consequence of the economic crisis, we are in a

ago,” according to Lord Carter, former UK M inister for

Communications, Technology and Broadcasting, speaking

of the challenges facing regulators and policymakers in

today’s environment Rapid response to problems posed

by the crisis is imperative, he says, but existing policy

frameworks do not necessarily allow for this

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expanded the scope for potential confl ict

between regulators and regulated In many

heavily regulated industries, the numbers

of people employed to deal w ith these

issues – both at regulators and commercial

providers (here termed “operators” for

convenience of use) – have expanded in

a like manner

This expansion reflects a recognition on

the part of both regulator and operator that

smooth and effective interaction usually

benefits both the industry as a w hole

and most of the players that operate in it

In turn, effective regulation is now w idely

acknow ledged as a core foundation of a

sustainable industry grow th framework

Even as regulators become more engaged,

however, their effectiveness in increasingly

competitive environments has become a

function of their ability to act as – and be

seen to be – independent arbiters In this

context, trust between regulator and

operator is a crucial requirement of regulatory effectiveness Operators need

to trust the regulator’s ability to maintain distance from both policymakers and other operators, to deliver consistent, timely and transparent decisions, and to have the requisite authority to oversee the sector Conversely, regulators need to trust operators to abide by established rules and

be co-operative As this study makes plain, the ability to build trust in regulation requires enormous patience and fortitude from regulators and operators alike

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The state of relationships

The level of regulator trust in the fi ve industries researched in this study is surprisingly strong

operator-in light of the expandoperator-ing role of regulation across industries and countries over the past ten years

M ore executives in our survey characterize the level of trust – between operators and regulators – in their sector as “ high” than those w ho think the opposite Similarly, trust-building seems to be moving in the right direction: more participants believe that operator-regulator relationships are improving than those w ho see deterioration While by no means glow ing assessments of the mutual relationships, these findings are encouraging in a global context that has seen renewed calls for

a more vigorous and potentially more intrusive approach to regulating competitive markets

Lord Carter, for one, is not surprised by the improvement in relationships and the relatively high levels of trust registered in the survey One reason for this, in his view,

is a vast improvement achieved in the quality of regulatory execution in recent decades “ In the UK and elsew here in Europe, we have seen a ‘professionalization’

of the regulatory discipline in the last 25-30 years.” An increasingly professional and thorough approach on the part of regulators helps also to engender respect – and trust – from operators

The assessments of trust are not uniformly positive across all groups of executives Operators, for example, are more guarded than regulators in their appraisal of existing levels of trust Among operators, view s also differ between executives based in developing economies – w here 42 percent

of operators say relationships are improving – and those in developed economies – w here only 23 percent say they are

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How would you characterize the overall level of trust that exists between operators and regulators?

Source: Economist Intelligence Unit 2009

How, if at all, has your operator–regulator relationship changed in the past year?

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The varying assessments may be

explained by different levels of maturity of

the relationships or sector dynamics at a

given point in time, among other factors

Operators, moreover, w ho do not benefi t

from all regulatory decisions, may be

expected to display a slightly more critical

perspective on relationships Still, the

larger point remains that

regulator-regulated relationships appear to be

evolving for the better

What’s going right?

Precisely w hat is working better w ill also

vary in line w ith individual and institutional

experiences, but there are some common

threads The regulatory manager of an

Asia-Pacifi c electricity provider points to the clarity of the regulatory framework in his national market and the clear demarcation that exists between those w ho make the rules and those w ho enforce them While this contrasts w ith many markets w here responsibility for both regulatory rules and their implementation lie w ith a single body, clarity as to w here accountability lies remains key

M ore transparency of regulation, at least in some markets, is contributing to better relationships Patricia De Suzzoni, Director

of M arkets w ith France’s energy regulator CRE, believes that regulator efforts to increase the levels of transparency have contributed positively to building trust This

is particularly the case in areas of regulator interaction that are process-driven and clearly outlined “ The level of trust is higher w hen an issue is subject to global, objective analysis and scrutiny,” says Sean Williams, M anaging Director, Retail Strategy, w ith BT, the United Kingdom’s largest fixed-line telecoms operator

operator-“ Lower levels of trust exist,” he maintains,

“ concerning issues that are susceptible to political influence and unpredictability.”

“ Routine functions tend to go smoothly,”

agrees Julie Veach, Acting Chief of the Competition Policy Division at the US Federal Communications Commission (FCC), “ w hile larger policy issues bring tougher discussions.”3

In w hich operational areas does interaction between operator and regulator work smoothly? (Top responses)

3 Julie Veach’s remarks, here and elsew here, reflect her personal view s only and are not necessarily the official position of the FCC

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Important though they may be, market dynamics are only one part of a complicated equation Trust is also in the eye of the beholder, with each player’s perception of the other party shaped by its own experience, culture and market interests. “Trust in the regulator is largely

an issue of corporate culture,” says Ms De Suzzoni. Some operators may regard regulation more favorably if they are set

to beneit from it, while those that stand to see their position negatively impacted by regulatory action may be more guarded towards the regulator.

Regulatory conservatism induced by a sense of selfpreservation can develop into

a fullblown suspicion of any regulatory action. Steve Smith, Managing Director, Networks at Ofgem, the UK energy regulator, points out that some operators have an inherent conservatism that makes them more guarded about regulatory action. “It’s not that operators don’t trust the regulator”, says Mr Smith. “There is just

a risk aversion ingrained in operators that makes them sometimes not give the beneit of the doubt to the regulator.”

A modicum of structural stability is also important in building trust The tenure of the regulator, a track record of reliability and – as already discussed – transparent processes are critical foundations. Ofgem, for example, has been regulating the British energy sector for the past twenty years, a tenure that has built some goodwill for the regulator.

More broadly, trust in the regulatory process is also often an extension of market participant trust in the political and policy processes. Regulatory bodies are a relection of the institutional framework within which they evolve, argues Michael Pollitt, Assistant Director of the Electricity Policy Research Group at the University of Cambridge. In turn, the best regulatory agencies – or at least those perceived as such – are typically found in countries that have strong political and competition institutions, notably in western and northern Europe To illustrate this point, around onethird of the operators in our survey that had noted a deterioration in their relationship with the regulator pointed

to political uncertainty at government level

as the primary factor, with 36 percent also pointing to excessive government inluence.

© 2009 KPMG International. KPMG International is a Swiss cooperative. Member irms of the KPMG network of independent irms are afiliated with KPMG International. KPMG International provides no client services. No member irm has any authority to obligate or bind KPMG International or any other member irm visàvis third parties, nor does KPMG International have any such authority to obligate or bind any

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KPM G Comment

Working more constructively together

Building trust in the regulatory relationship

is about improving the efficiency but not

changing the fundamental dynamics

of the relationship between a regulator

and operator

Respondents indicated in the survey

that a better understanding of business

operations and risks on the part of

regulators, and a better understanding of

policy objectives on the part of industry

were the best means of improving the

overall levels of trust The ability for

respective stakeholders to put themselves

‘in the shoes’ of others is clearly, therefore,

a key competence for all engaged in the

regulatory sphere

It is clear that this means setting the

appropriate ‘tone at the top’: the

relationships between the regulator and

the regulated and the example it sets for

the rest of their respective organizations

The survey results suggest that

respondents agree, citing good senior level

relationships as the key contributor to

effective regulator–industry relationships

In some instances, however, the

relationships are fundamentally fractured

and more drastic action is required By the

late 1990s, relations between the UK

telecommunications incumbent, BT plc,

and former regulator, Oftel, were

considered poor by many commentators

and in the words of former chairman,

Sir Christopher Bland, ‘adversarial’4

From its creation in 2003, Ofcom and BT

were able to use the different environment

and personalities

brought by the change to establish a more trusting and effective relationship, as evidenced by Sean Williams, formerly

of Ofcom and now at BT

It is striking that the UK government has been considering extending Ofcom’s powers to incorporate the responsibilities currently held by PostComm, the postal regulator In his report on the UK postal system as chairman of the Independent Review of the Postal Services Sector, Richard Hooper w rites that he is:

struck by the depth and range of disagreements between Royal M ail and Postcomm Even the most basic facts are disputed… The systems and necessary data needed to build a constructive and professional regulatory relationship are not yet in place…

There is a lack of trust on both sides.5

KPM G firms’ regulatory specialists have been employed around the globe to advise

on the development of new regulators, working w ith governments, law yers and other stakeholders to identify w hat powers, skills and competencies are required w here confidence in regulators has been significantly eroded In other instances, we have worked closely alongside regulators to help them identify

w here they could perform more effectively and effi ciently

Equally, business, both through boards and regulatory functions, can play its part in understanding the policy agenda and communicating its operational agenda

M oreover, as KPM G’s report Bringing

Regulation into the Boardroom (KPM G LLP

(UK), 2007) demonstrated, good communication w ithin business, and particularly between the board and regulatory team, is a precondition for a robust but effective regulatory strategy

As M r Williams of BT demonstrates, there

is some career ‘cross-over’ between regulators and industry, and vice versa However, if there are concerns about

‘regulatory capture’, the survey does not bear this out Nor does the practice seem particularly frequent Rather, this suggests that there are further opportunities to build relationships and understanding between regulators and industry w ithout major risk

of regulatory capture, and that there may also be improved mutual understanding through some ‘cross-over’ – both better operational and policy competency

4 “ ‘New BT’ told it’s time to deliver - Broadband Britain benefits from lighter regulation”, The Guardian, 25 July 2002

5 “ M odernise or Decline: Policies to maintain the universal postal service in the United Kingdom”, Richard Hooper, 2009

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Turning the tables

KPM G firms are developing a new

approach, ‘Turning the Tables’, in w hich

managers and staff at operators and

regulators are taken through scenarios

developed by specialists and asked to take

a role on the “opposing team” and make

decisions that reflect realistic corporate

and regulatory challenges Approaches

such as this are clearly needed to respond

to some deeply entrenched differences in

perception between parties

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The consequences of mistrust

There is much that can go awry in operator-regulator relationships, but the perception of what doesn’t work may be colored by each party’s own vested interests

Asked to identify specifically w hat goes

w rong, respondents to our survey point primarily to those areas of regulatory implementation that have a direct, negative impact on their ability to operate or fulfi ll

their mission M arket participants are also likely to assign a negative grade to an area

of interaction that has an adverse impact

on their primary constituency (w hether it’s the government, consumers or shareholders) For example, operators in the survey cite dispute resolution and tariff regulation as the areas that are most problematic in their relationship w ith regulators By contrast, regulators see quality of service as the key area of difficulty, although they also acknow ledge problems w ith dispute resolution among competing operators

In w hich operational areas does interaction between operator and regulator work poorly? (Top responses)

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Breakdow ns in the operator-regulator

relationship often occur w hen there is a

lack of transparency in a decision or w ith

an increase in the degree of subjectivity

required by the decision or rule-making

process While most decisions involve

some degree of subjectivity, some

categories – for example, dispute

resolution – are more subject to

interpretation than others and are more

likely to create an aggrieved party

The blame game

As a result, determining the source of a

breakdow n in trust can easily devolve into

a blame game Operators, for example,

are prone to blame a breakdow n in trust on the performance of the regulator Of the respondents that say that their relationship

w ith the regulator had deteriorated, 63 percent blame poor regulator performance,

w ith another 37 percent pointing to unduly close relationships of the regulator w ith other players in the marketplace

M ost of the operators surveyed give a rating ranging from mixed to poor on regulatory performance on key items such as timeliness, consistency and transparency of decisions A regulatory manager in one Africa-based operator interviewed for this study complains that

regulator performance has negatively impacted market confi dence: “ The regulator does not meet timelines, does not digest all the inputs and does not follow procedures Over time, you start questioning their abilities.”

On a more positive note, regulators get their best rating on enforcement of regulation, w ith 46 percent of operators rating them as good or very good in this area

How would you assess the performance of the regulator on timeliness of decisions and rulings?

Very good Good Mixed Somewhat poor Very poor Don’t know

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How would you assess the performance of the regulator on consistency of decisions and rulings?

46%

2%

Regulators’ self-assessment

How would you assess the performance of the regulator on transparency of decisions and rulings?

17%

46%

Regulators’ self-assessment

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How would you assess the performance of the regulator on enforcement of decisions and rulings?

It is probably not surprising that regulators

in the survey have a better opinion of their

performance in these areas than operators

have The magnitude of the gap in some

areas, however – 77 percent of regulators

consider their performance in the area of

timeliness of decisions as good or very

good compared w ith only 22 percent of

operators w ho feel the same – is striking

There may be a number of reasons for

such a divergence of view s First,

regulators are more likely to rate their ow n

performance positively, w hile operators

take a more nuanced view Further, the two

parties often have differences on w hat

Operators’ rating of regulators

should be the key functions of the regulator, or the focus of its activities at any given point in time In turn assessment

of regulator performance is based on a distinct set of expectations Whatever its reasons, this gap in the assessment of regulator performance points to often tense relationships and highlights the scale

of the effort that must be undertaken to build trust between the two sides

Regulators are just as likely to ascribe some of the blame for a breakdow n in trust

to the other side Regulator respondents, for example, blame regulatory uncertainty

in deepening the trust gap Paul Foran, Vice President, Regulatory Programs of American Water, a US water utility, points out that past abuses by some providers often lead regulators to regard an entire sector w ith suspicion “ Utilities have to

do their share to engage in building trust,”

he says

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License conversion, litigation and

trust in South Africa

The South African telecoms market offers

a good illustration of the challenges of

maintaining trust between parties in a

context of rapid technology evolution,

increased competition and a policy

framework looking to keep pace In 2005,

the country’s parliament enacted the

Electronic Communications Act (ECA),

a new law designed to replace one w hich

was deemed both complex and obsolete

Where the previous law created silos

primarily based on the types of services

offered (for example, one for voice and

one for data), the ECA separated the

physical network infrastructure from the

communications services running on top

of the networks

The task befell the relatively young

regulator, the Independent

Communications Authority of South

Africa (ICASA), to convert licenses issued

under the previous law to the new

licensing regime In effect, ICASA was

to set the framework for transforming a

market w ith five major operators and an

array of value-added service providers

to one having nearly 300 market players

w ith varying degrees of fl exibility to

deploy their ow n network infrastructure

ICASA’s task required the creation of new processes and regulations across

a multitude of issues, from license conversion to frequency licensing, facilities leasing, interconnect, license fees and others, each issue rife w ith potential for acrimony “ The market is at a critical juncture”, remarks Karabo M otlana, CEO of ICASA, “ and there are a lot of fights on ancillary issues”

The ECA provided a two-year transition period during w hich ICASA was to complete the license conversion process and replace existing regulations, w ith a possible six- month extension (to January 2009) After industry consultations, the regulator determined that some smaller players would receive services licenses rather than network infrastructure licenses (w hich some felt they should receive) As a result, ICASA was taken

to court in a bid to force the judicial body

to provide an interpretation of established policy that would allow those players

w ho wanted to do so to build their

ow n networks

Follow ing a court decision siding w ith the operators, ICASA awarded licenses to the relevant players, but not before levels of trust between parties had effectively sunk

to low levels Nonetheless, the market had taken some important steps towards legal clarity

Why does trust break dow n?

These differences in the perception of

w hat goes amiss raise some larger issues

If the sides cannot agree on w hat is w rong, fixing it becomes all the more diffi cult

A key step in developing some common ground is to devote more effort toward understanding the motives of the other party

The precise role of regulators, for example, can be a source of friction M r Foran notes that there is an increasing trend of market regulation overlapping w ith consumer advocacy A number of regulators are perceived to straddle the fine line between protection of the consumer interest and consumer activism; this is particularly the case in developing economies, or in markets w ith a higher level of public-service influence (water and postal services, for instance) On the fl ip side, many operators see the regulator as a custodian for the sector, one that protects the interest of the market at large, including consumers and service providers

As a result of these differences, operators are typically accused of focusing

excessively on short-term fi nancial results

at the expense of the greater good of the overall market Regulators, on the other hand, are blamed for either not holding real power or, w hen they do, leveraging their power in an unw ieldy manner, acting primarily as consumer advocates

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