The reform of utility regulation in Britain: some current issues in historical perspective.


The privatization of the British utility industries by Conservative governments from the early 1980s entailed a new regulatory system to replace public ownership. That new system has been the subject of much criticism, and the remodelled Labour party, while in opposition, committed a new government to its reform. "New Labour," however, ruled out a return to the old system of nationalization in favor of a reformist program [Blair 1995, 2-4]. During summer 1997, the newly elected Labour government announced the setting up of a wide-ranging review of utility regulation to be undertaken at an inter-departmental level. The review was to examine many of the reform proposals advanced by critics of the existing system and was to lead to the issue of a government Green Paper - a consultative document - on favored reform measures.

This paper seeks to explore some of the key issues in the modern reform debate by drawing on the store of regulatory practice accumulated in Britain before World War II. A good deal of recent discussion about utility regulation in Britain has tended to adopt a fairly short-term historical perspective as in Veljanovski [1991, 6-9], Bishop, Kay, and Mayer [1995, 3, 9], and the report of the Commission on the Regulation of Privatised Utilities [CRPU 1996, vii, 20]. Attention has focused on the so-called distinctive features of the "UK model of regulation" developed since the 1980s compared with nationalization [Butler 1993, 3]. Neglect of earlier British regulatory experience may have encouraged some reformers to look abroad for guidance as with T. Blair [1995, 4], or led to the highly questionable view of C. Price [1994, 81] that the United States has a much longer history of regulation than Britain.

In contrast, this paper suggests that insights may be drawn from earlier British regulatory experience. There are historical and institutional parallels between utility regulation prior to World War II and in Britain today, and some current thinking has strong roots in British experience before 1939. This runs counter to the recent claim of the CRPU that British experience during the last decade has been novel and unique [CRPU 1996, vii].

In the period before World War II, the regulatory system, as today, was the focus of substantial criticism. The eventual outcome in the earlier period was the displacement of existing forms of utility regulation by nationalization although it is debatable as to what extent this marked a radical new departure. Control of utilities through various forms of public ownership, as well as control of private companies, was already characteristic of prewar Britain as noted in the report of the Next Five Years Group [1935, 89-96] and in the account of H. Macmillan [1938, 174]. A mixed system of regulation was a hallmark of the British system, and variety was one of the principal features of British public utility control, as J. M. Keynes pointed out [1927, 644-6]. Public ownership was supported by many non-socialists, so it is important also not to overemphasize the ideological aspects of public ownership before the war. New problems required varying forms of regulation, as the American observer M. E. Dimock noted in the early 1930s [1933, 43]. It was mainly the advent of a Labour government in 1945 that brought about the nationalization form of public ownership, and partly as a result, other prewar forms like municipalization declined in significance.

The first part of the paper examines the particular form of price cap control that has been central to British utility regulation since the early 1980s and investigates the alternative regulatory tools suggested by critics. Recent attention has focused upon "hybrid" forms of regulation with particular interest in the "sliding scale mechanism." This paper makes a comparison with various methods of regulation before 1939 and suggests that some ideas that are now exciting interest were tried then and found wanting. Indeed, the charge that regulatory mechanisms, like the sliding scale, were not working encouraged some prewar critics to advocate deregulation in a manner reminiscent of some market-oriented economists today.

A key issue at the present time in Britain is whether there should be significant change in the regulatory regime - the institutional, procedural, and "constitutional" aspects of regulation [CRPU 1996, 19]. In particular, there is an argument that the individual regulator characteristic of each utility industry should be replaced by a regulatory commission or panel. The paper considers the current debate on these institutional arrangements in the light of earlier British experience.

RPI-X Price Control: The Rough and Ready Short-Term Solution?

Arguably, the most distinctive feature of the new regulatory system introduced in Britain during the 1980s was the method of price control in the form of RPI-X price cap regulation. Basically, the regulator sets the prices, rather than the profits, of the company [Rees and Vickers 1995, 358; Beesley and Littlechild 1991]. At its simplest, the price cap is a number of percentage points (X) below the standard rate of inflation as measured in the retail price index (RPI).

The choice of price caps appears to have been a deliberate rejection of traditional U.S.-style rate-of-return regulation,(1) which was believed to provide little incentive to improve efficiency and might give firms an incentive to overinvest [Bishop, Kay, and Mayer 1995, 4; Helm 1995, 31]. The principle behind price cap regulation is that by fixing prices utilities are given the incentive to reduce costs and increase profits; compared with conventional rate-of-return regulation, there is a reward for efficiency. Further suggested advantages of RPI-X regulation, when it was first introduced, was that it allowed "regulation with a light touch" and avoided the complexity and administrative expense involved in establishing appropriate rates of return [Rees and Vickers 1995, 359]. This fitted in well with the notion expressed by the editors of a recent British survey that the most important feature of regulation is that there should be as little of it as possible [Bishop, Kay, and Mayer 1995, 16], and it suited the new regulatory agencies, the nature of which will be examined later in the paper.

Apart from the suggested merits of RPI-X price control already mentioned, free market ideology also had some significance in its choice for the new regulatory system. The then Conservative government minister Nigel Lawson, reflecting on the privatization of British Telecom in 1984, believed that RPI-X provided a stopgap measure until regulation became unnecessary because of the growth of competition. He noted in his autobiography that the RPI-X formula was "originally envisaged as a rough-and-ready short term solution" [Lawson 1992, 223]. This perception of RPI-X regimes, as essentially temporary ones, fitted the market-oriented view that regulation should be about managing the emergence of competition and was one of the original criteria selected by Littlechild for choosing a regulatory mechanism [Burns, Turvey, and Weyman-Jones 1995b, 3]. It is a view principally identified with the Austrian school, as M. E. Beesley [1991, 155] has pointed out.(2)

The British "model" of price cap regulation also exercised an influence in the United States. Since 1984, "incentive regulation" schemes have been adopted for the telephone industry by the Federal Communications Commission and more than 30 state regulatory commissions, according to J. M. MacDonald, J. R. Norsworthy and Fu Wei-Hua [1994, 27].

R. R. Braeutigam and J. C. Panzer [1993, 197] believe that limited U.S. empirical evidence supports the view that price cap regulation "is probably most effective as a transitory step on the path toward total deregulation and full competition." In contrast, J. M. Bauer has suggested that the performance enhancement effects involved in a switch to price cap regulation, described by Braeutigam and Panzer, "have only been demonstrated conceptually and under conditions of certainty and perfect information. These results may not hold under less ideal conditions of asymmetric information and uncertainty" [Bauer 1995, 395]. Harry Trebing [1995, 410] has also questioned the Braeutigam and Panzer approach by pointing to the ambiguous findings of recent empirical research.

The Twin-Track Approach to Regulation and Criticisms of the Current Price-Capping System

The maxim frequently adopted by those concerned with regulatory issues in Britain is the twin-track approach - "competition where that is possible and regulation only where it is necessary" - as found in recent studies [Kay 1993, 14; Spottiswoode 1995, 60]. S.C. Littlechild has come to accept that there may be permanent regulation of natural monopoly network industries, as noted by P. Burns and his colleagues [Burns et al. 1995b, 3]. Indeed, neoclassical arguments about utility pricing can be used, of course, to provide a rationale for "more or less permanent" utility regulation [Beesley 1991, 14].

The Labour party's A New Industrial Strategy for Britain, published in September 1996, showed commitment to the rule of encouraging competition where practicable and efficient but provided regulation in the core natural monopolies [Dickie 1996, 8]. John Battle, in his first major speech as energy minister in the new Labour government in June 1997, reiterated the principle of the twin-track approach. During the previous month, he had met the gas and electricity regulators to discuss concerns that the pace of energy market liberalization had slackened.(3)

In practice, RPI-X has endured far longer than some imagined, but since it was first introduced, a range of variants has developed that do not all have the same clear properties identified by supporters [Waterson 1994, 116-7]. Price control has tended to become tighter and more involved, according to R. Rees and J. Vickers [1995, 359; also Vickers 1996, 91; Lennard 1995, 41]. The demands of quality regulation, which have become more urgent, have contributed to the complexity of RPI-X regimes. L. Rovizzi and D. Thompson [1995, 345-6] have argued that adjusting the price cap might appear simple, but there are real problems in establishing a quality index and appropriate regulatory mechanisms. The idea that the regulator should construct a formula that can reward the various quality dimensions founders upon the very large number of such characteristics that are relevant in the view of C. Hicks [1993, 91]. Some of these issues are familiar from prewar British regulatory history. P. Chantler regarded problems of service deterioration and limitation as key problems in utility control. " Elaborate, and within limits, effective methods of controlling profits, prices and quality of the product may be employed, but the problems of service specification and control leave a core of weakness in the system" [Chantler 1938, 78; see also Batson 1933, 1-2].

Under the RPI-X system, the firm has a strong incentive to produce at lowest cost and maximize profits subject to the price constraint. But critics argue that in industries where technological progress is occurring and that have economies of scale, "undeserved" or abnormal profits have been made that are not the product of managerial action [Waterson 1994, 117]. Public dissatisfaction with the very high profits made by utilities has increased pressure on regulators to improve the periodic revisions to the price cap formulae. They have used rates of return earned in order to calculate these formulae, and some have suggested that this represents a change from RPI-X to what supporters of RPI-X say is the less efficient but superficially more equitable rate-of-return legislation [Burns, Turvey, and Weyman-Jones 1995, 1]. M. Call [1993, 24] observed that a drift toward rate-of-return regulation has crept into regulatory decision making over the last decade [see also Helm 1995, 1618]. S. Glaister [1996, 36-38] has warned of a possible danger of overinvestment in the British water industry in the future that may come from inflating the capital base and "gold- plating" - problems traditionally associated with rate-of-return regulation. Whether there truly has been a shift toward rate-of-return regulation is a matter of some controversy. M. Waterson [1994, 117-118], for example, has questioned whether rate of return provides a real alternative to RPI-X and is clearly different from it. In setting the price cap, the regulator is concerned that the firm can cover its costs including the cost of capital; this means estimating a fair rate of return on assets. Although it is not the basis for decision or action, in this sense RPI-X and rate-of-return regulation are not entirely mutually exclusive. J. Kay remarked recently that "it was always appreciated by most thoughtful commentators on RPI-X that it would, in reality, have many of the characteristics of rate of return regulation, and that much of the regulatory intrusiveness which had become familiar under that regime would arise here also" [Kay 1996, 156].

Analysis of the recent experience of price cap regulation in Britain provides further evidence of weaknesses in that approach. M. A. Crew and P. R. Kleindorfer have pointed to the importance of the commitment issue in regulation - the notion that the regulator will not renege on the terms of the price cap. The behavior of electricity regulator Littlechild in March 1995 in resetting price caps and X factors in response to public pressure raised the question of whether companies would pursue efficiency as strongly [Crew and Kleindorfer 1996, 218- 219; see also Sawkins 1996, 250]. S. Cowan [1997, 53-54] has drawn further attention to technical problems associated with the form of the price index that he considers to be "a crucial factor in determining the overall effectiveness of price caps." While also considering the technical difficulties of price cap regulation, institutionalist critics have pointed to the narrow focus on efficiency inherent in the price cap approach and to the disregard of equity and distributional effects [Trebing 1995, 413; Loube 1995, 297; Miller 1995, 281-2]. H. E. Batson, writing in the early 1930s, believed that the chief disadvantage of price regulation in Britain was "the practical impossibility of drafting a set of regulations for the conduct of the undertaking that will be continuously equitable" [Batson 1933, 7]. Recent work by Trebing has demonstrated pitfalls in the market-oriented model and price cap regulation given high levels of concentration. According to Trebing, price cap regulation is significantly flawed because, among other problems of the price cap approach, price caps "are largely inefficient in constraining price leadership, conscious parallelism, limit entry pricing, the retention of cost savings greater than the productivity offset, and assuring an equitable distribution of gains from technological advance across all classes of consumer" [Trebing 1995, 410; 1997].

The Rediscovery of Sliding-Scale Regulation in Britain

In the search for alternative regulatory tools to RPI-X, the idea of a sliding scale has been resurrected, a system that existed in Britain up to 1939 [Chatwin 1995, 45; Cunningham 1995, 59]. Basically, a sliding scale involves a regulatory mechanism or formula whereby there is an inverse relationship between profits or some measure of profitability and prices. Increases in profit beyond a standard level are only allowed if prices also fall below a particular level. Conversely, prices may rise if profits fall below the stipulated level.

According to a recent evaluation, sliding-scale regulation was first introduced as a way of bringing peace to the regulatory chaos of the pre-1875 gas industry [Burns, Turvey, and Weyman-Jones 1995, 2-4]. Subsequently, the system drew the attention of American observers dissatisfied with rate-of-return regulation in the United States.(4) Sliding-scale regulation spread to the United States, being used, for example, in the electricity industry in Washington, D.C., during the early 1930s [Bussing 1936, 5]. In Britain, the system was extended to electricity, but the whole system became obsolete with nationalization.

C. D. Foster has suggested that the original sliding scale used in Britain was a kind of "precursor of RPI-X," but unlike RPI-X it made no allowance for price inflation and was "defeated by inflation during the First World War... [and] disappeared from Britain" [Foster 1992, 62]. M. Chick [1994, 318] has argued that price capping in the gas industry became irrelevant since gas costs fell.

Certainly, there are very mixed views about the efficacy of the sliding- scale system, which may lead us to question the recent assumption of Burns and colleagues that it "may once again offer peace" to the regulatory difficulties that exist today in Britain [Burns, Turvey, and Weyman-Jones 1995, 4]. They quote with approval a statement by George Livesey, who was responsible for introducing the sliding scale in London in 1899, but then tell us nothing of the subsequent history of gas industry regulation [Burns, Turvey, and Weyman-Jones 1995, 4]. It does appear that the sliding scale did meet public satisfaction during the period when it was coming into general use before 1914. The American observers in 1906 recorded their belief that the sliding scale had proved "an inducement to the gas companies in Great Britain to manage their business prudently, skillfully and economically" [Chantler 1938, 92]. The Liberal Industrial Inquiry was content to describe the situation in the late 1920s as follows: "Since about 1875 dividends of gas companies have generally been regulated under a sliding scale which provides that they may increase beyond a standard figure on consideration that there is a reduction in the price of gas below a fixed standard price. Conversely, prices may rise if dividends fall" [Liberal Industrial Inquiry 1928, 74]. I. Bussing [1936, 5] also clearly assumed that the sliding scale was still widely and effectively used in Britain in the mid-1930s.

However, this rosy picture of the sliding scale perhaps needs to be toned down. Critics have pointed to institutional defects and have suggested a less successful history of the sliding scale in Britain during the interwar period. Writing in the late 1930s about the gas industry, P. Chantler recognized the weakness, noted by Foster above, that sliding-scale mechanisms were not inflation-proofed. Chantler also observed that the "problem of service," mentioned in an earlier section of this paper, was totally ignored in the sliding-scale mechanism. As he expressed the problem, "it is conceivable that a lower price might be attained not through increased managerial efficiency but through reduced service to gas customers. . . . secondly a low price for gas in the present might be given only at the cost of consumers themselves in the long run, if the undertaking was undermined as a consequence" [Chantler 1938, 95].

Chantler noted that the sliding-scale system was being superseded by the "basic" system of price and profit control. Between 1920 and 1937, the basic system had been adopted by 36 companies together supplying more than half of all gas sold by companies in Britain. The basic system was a way of providing for the equal division of the "surplus profits" between shareholders and employees. It enabled a company to give its workers some financial interest in its efficiency, although this was "a provision perhaps more important psychologically than materially" [Chantler 1938, 96-98].(5)

In the late 1930s, the McGowan Report on the reorganization of the British electricity industry also pointed to the defects of the "old sliding-scale" system of regulation; according to an account written at the time, the minimum prices determined under the sliding scale became "farcical" very quickly, since no allowance was made for the effects of improvements in science and technology on costs [Jones 1938, 268].

A report on the gas industry on the eve of World War II argued that the current system of regulatory control with statutory maximum rates, the sliding scale, and the basic system was too complex and obstructive and believed that there was a clear case for simplifying the public regulation of gas prices [PEP 1939, 170-172].

Both the reform group Political and Economic Planning (PEP) and Chantler, writing about the same time, pointed to the growth of competition in the gas industry and argued that the regulatory system needed to be overhauled with a strong case being evident for discontinuing the sliding scale, basic system, and statutory maximum rates [PEP 1939, 176; Chantler 1938, 105].

The electrical industry appears to have moved away from sliding-scale price control to rate-of-return regulation by the late 1930s, with Jones suggesting that "recourse has been had not only to American practice but also to American theory" [Jones 1938, 269].

The overall impression of prewar regulation in Britain is of a mixed system with a great variety of forms of regulatory mechanisms including the sliding scale. There is no clear overwhelming evidence, however, that the sliding scale was successful or brought lasting peace, as the work of Burns and colleagues might suggest. Consideration of hybrid schemes during that period in fact illustrates, much as today, a loss of regulatory credibility and a need to overhaul the system of public control. Market-oriented economists called for deregulation, but the more insistent, growing, prewar demand was for more radical change through the mechanisms of public ownership.

Regulated and Unregulated Sectors

Diversification of utility companies in Britain away from traditional core activities since privatization has also caused problems for price cap regulation; in part, this has been caused by the incentive for firms to move into areas that are unregulated to escape the price cap. In some measure, this is comparable with the situation of railway companies in Britain before the 1870s. Price fixing applied to conveyance charges and rates, but charges for services and accommodation at railway termini were unregulated and thus rife for exploitation [Barker and Savage 1974, 90]. Moreover, at the turn of the twentieth century, some railway companies came to own buses partly due to lighter regulation in that sphere, but mainly to counter the competitive threat posed to railways [see the account in Simmons 1986, 37]. It is a curious fact that companies in the deregulated bus sector have been engaged in taking up railway franchises in Britain!

One recently suggested remedy to the regulatory problems brought by diversification is to link price in the regulated sector inversely to the total overall profits of the firm in both the regulated and unregulated sectors [Waterson 1994, 103, 120; see also Corry 1995, 4]. Waterson, indeed, has commented that a mechanism designed by Braeutigam in 1993 [Braeutigam 1993] along the lines described is the modern equivalent of the sliding scale.

Hybrid Regulatory Mechanisms

During the last few years, there has been considerable interest in Labour party circles in the idea of moving away from the present RPI- X regimes. An assortment of alternative tools and "hybrid" mechanisms has received attention including "rate-of-return sliding scales" and modified price cap regulation in which companies have to share profits above a certain level with customers. To an extent, the debate about sliding-scale regulation and measures to control utility profits has followed developments already put into practice in parts of the United States. Most of the price cap mechanisms implemented in the United States include limits on how much a firm can gain or lose before triggering profit sharing with customers [Braeutigam and Panzer 1993, 191-198; see also Lyon 1994, 13; Fraser 1995, 115-119].(6)

T. P. Lyon [1994, 16] has observed that a useful characteristic of hybrid regulatory mechanisms is that they address problems of implementation not dealt with by theorists. Furthermore, they are seen as a "flexible combination" of the alternatives of rate-of-return and price cap regulation [Lyon 1996, 228]. From that perspective, they have been attractive to Labour party reformers who have had no desire to push any strong ideological line but are keen to grapple with the practicalities of regulatory reform.

The new Labour government in Britain, while ruling out any switch to a traditional U.S.-style rate-of-return approach, has in fact included the "halfway house" approach of profit sharing in its review of utility regulation [Beavis and Weston 1997].

However, the government has been under strong pressure from vested interests to drop some of the more radical proposals considered in opposition. Michael Hughes, chief executive of the U.S.-owned regional power company Midlands Electricity, warned recently that "profit sharing is bureaucratic and it puts up costs. It damages incentives and it pushes up prices" [Godsmark 1997b]. Ian Byatt, the water regulator, has argued that "sliding scale formulae can never obviate the need for thorough periodic pricing reviews" [Beavis 1995]. It appears that Margaret Beckett, Trade and Industry Secretary, has been persuaded that dropping price caps would reduce incentive toward greater efficiency [Wighton 1997]. Less than two weeks into the government review of utility regulation, a commentator suggested that Trade and Industry department [DTI] civil servants had identified what they considered to be severe barriers to profit sharing schemes. Foremost was the suggested difficulty of designing a complex mechanism to calculate profit ceilings for each of the utility companies [Godsmark 1997c].(7)

Any change in the regulatory tool, for example, toward profit sharing would have important repercussions for the regulatory authority. Profit sharing embroils the regulator in additional measurement, asymmetric and other problems calling into question the appropriateness of the particular institutional form of regulation. Significantly, in Britain the debate over the relative merits of different regulatory tools has been linked with significant proposals to reform the structure of the British regulatory authorities. Reformers have advocated changes in the nature of the regulatory agencies that have an important bearing on the introduction of new regulatory tools and whether or not they could be successfully implemented. The paper now turns its attention to the character of the present model of regulatory authority and then concentrates on some of the more important suggestions for institutional reform.

The Single-Person Regulator

Privatization of utilities from the early 1980s in Britain was combined with the introduction of new, specialized regulatory agencies. This development was piecemeal, and a criticism, reminiscent of the variegated regimes of the period before World War II, was that the regulatory agencies revealed no consistent pattern [Borrie 1995, 92-93; Foster 1995, 135]. The regulatory agencies are technically nonministerial government departments, and in each one statutory responsibility was put in the hands of a director-general who was to be remote from ministerial intervention [Carsberg 1995, 125; Odgers 1995, 7; Beesley 1995, xii- xiv]. In a comparative survey of four different models of regulation in various liberalized systems, D. Gillick [1993, 18] distinguished the U.K. model as the independent official supported by a small bureaucracy. He gave as example the Director General of Telecommunications and the Office of Telecommunications (OFTEL).

The idea of independent, sole regulators with discretion appeared to offer a less expensive, less rule-bound, less cumbersome, and more flexible alternative to U.S.style commission regulation at the time of privatization [Bishop, Kay, and Mayer 1995, 10]. It fitted in well with the prevailing ethos of light-touch regulation, promoting competition, and only substituting regulation where it was essential [Spottiswoode 1995, 60; Whittington 1995, 61]. A key objective of the regulator, as observed already in discussion of RPI-X systems above, was to "incentivize" the monopoly so that in the longer term "there would be the added bonus of the disappearance of the regulator" [McKinnon 1991, 95].

Resource Constraints on British Regulation

Recognition of the need for more or less permanent regulation coupled with a drift toward more regulatory intrusiveness within RPI-X regimes, noted earlier in the paper, has led to a questioning of the limited resources put into the regulatory agencies in Britain compared with the United States [CRPU 1996, 50-51]. A recent comparison suggested that there are only 500 or so staff attached to the three regulatory agencies concerned with gas, electricity, and telecommunications in the United Kingdom, few if any with long-term regulatory experience, whereas there are around 50,000 experts and support staff engaged in similar regulatory activities in the United States [Palast 1996].(8) Any change in the regulatory instrument, such as the adoption of profit- sharing schemes, would also have repercussions on the institutional form of regulation as noted previously. Already, "vast informational asymmetries exist between regulators and companies on the one hand and between regulators and consumer groups on the other" [Dee and Meek 1997, 118]. Lack of transparency plus knowledge-based problems, such as defining and measuring profits and distinguishing between regulated and non-regulated activities, puts additional pressure on the limited resources available to the regulatory authorities. Ian Byatt, the water regulator, recently attacked the water companies for paying "scant attention" to financial figures in their annual submissions to his office. They had failed to explain the way dividends between the main regulated utility businesses and the quoted holding companies were calculated [Godsmark 1997d]. Problems of regulatory control have intensified because of the blurring of boundaries between utility industries and increasing multinational ownership. Six U.S. utilities now control regional electricity companies in England and Wales, and in 1997 there were just two independent companies remaining from the 12 at privatization. French utilities have also made big inroads into the control of the U.K. water industry.

Plans to regulate profits in addition to prices will put additional pressure on the limited resources available to the regulatory authorities, which may face a subtle assault by cash-rich firms deploying the cleverest consultants to argue their case. The urge for the regulator to investigate more widely and deeply will, according to liberal critics like C. Veljanovski [1991, 25], eventually lead to a merging of regulator and industry interests. Fear of regulatory capture was a strong concern of the Conservative government at the time of privatization, as noted by D. Souter [1994, 74], and is still an issue [see, for example, worries recently voiced by the Consumers' Association in Dee and Meek 1997, 118-123]. Anxiety has also been expressed in Britain with regard to the danger of regulatory arbitrage - the process of targeting supposed weak regulators by stockbrokers and analysts and then steering investments into the industries they control [Ball 1995].

The highly personalized approach of the British system in appointing one individual as a kind of lone supremo with wide discretionary powers has raised questions concerning the accountability and control of the regulator as found in recent studies [Veljanovski 1991, x; Odgers 1995, 7; CRPU 1996, 55-56].

Unlike the United States, there are no public hearings, and regulatory decisions are made in a fairly secretive process. Whereas U.S. regulators' decisions can be challenged in the courts, there has been only very limited legal redress in Britain.(9) The National Audit Office suggested recently that there was scope for regulators to increase their openness to public scrutiny, although it warned against making the process "more cumbersome and legalistic" [Wighton 1996]. The Commission on the Regulation of the Privatised Utilities has called for greater transparency and accountability and has recommended that regulators should be required by law to give reasons for their decisions [CRPU 1996, 93-96].

The Commission Form of Regulatory Authority

A persistent theme in current reformist literature is a demand for some kind of commission or executive board to replace single-person regulators as found in recent studies [Corry 1995, 11-14; Souter 1994, 84-86; CRPU 1996, 12]. The commission form would be a way of depersonalizing the system and of creating a certain degree of anonymity; it has also been advocated as a means of achieving a broader balance of regulatory objectives. As noted above, RPI-X is mainly identified with efficiency considerations and the promotion of competition. In contrast, critics have insisted that there are multiple and sometimes conflicting objectives [Corry 1995, 10; Ernst 1994, 194-7], and that the aim of regulation should be to balance the interests of the various stakeholders including a public interest [Souter 1994, 35-54]. The commission form, rather than the single regulator, might provide a more suitable framework for monitoring the attainment of these wider objectives, although the British experience before 1939 suggests that other regulatory structures are also appropriate for the pursuit of social ends. H. E. Batson [1933, 4] gave the example of tramways, which were encouraged to discriminate against short-distance passengers in order to help the decentralization of the population in their area. Some of the current reform ideas, particularly ones favored by those associated with the Institute for Public Policy Research (IPPR), are close to the thinking of American institutionalists who support regulation [see, for example, Trebing 1995; Miller 1995, 1996].(10)

One criticism of the commission form is that, in order to achieve balance between the various stakeholders, unsatisfactory compromises may be reached in a process that is less speedy and less decisive than one headed by a single-person regulator [Carsberg 1995, 131-132]. C. D. Foster [1995, 137] has similarly argued that lack of clarity in decision making may also be prevalent where the commission is weakly chaired. Another fear, expressed recently by J. Dickie [1996, 16], is that if non-executive directors are appointed to a panel and called upon simply for their expertise or experience, power would still reside at the center and this would "institutionalise vested interests at the heart of regulation."

Some reformers have toyed with the idea of creating a superregulatory agency covering all the utilities. There is the need, of course, to ensure that regulation is consistent between utilities, especially in the light of cross-sector utility mergers, the first being United Utilities, which started business on January 1, 1966. However, Margaret Beckett, the Trade and Industry Secretary, has agreed that there should not be a super-regulator for all utilities [Beavis and Weston 1997].

Experimentation with different types of regulatory agencies was a feature of the British system before 1939. J. McEldowney [1995, 410, 419] has suggested that the system of inspectors and boards in the nineteenth century bears a strong resemblance to present regulatory structures. In both periods, it is argued, there was a similar combination of the enforcement of statutory powers, ministerial supervision, and independent regulatory agencies. Accusations of bias and favoritism were levelled at individuals involved in those earlier agencies just has they have been toward particular regulators in recent British experience.

During the late nineteenth century, some regulatory agencies in Britain appeared to adopt a court-like form of organization, similar to the independent, quasi-judicial commissions established in the United States. There seems to be some parallel between the Interstate Commerce Commission of 1887 and the English Railway and Canal Commission of 1888. Indeed, the American writer M. E. Dimock believed, perhaps in error, that the ICC, as well as many other state regulatory tribunals in the United States, "owed their germ idea" to the example afforded by the English Railway Tribunal of 1873 [Dimock 1933, 72].(11) According to Foster [1992, 164], the commission form of regulation was used to an extent in Britain, particularly from the 1870s, but was becoming less significant by the 1920s. In the early 1930s, the only regulatory tribunals that Dimock [1933, 58] could list comparable with U.S. independent commissions were the Railway and Canal Commission, the Railway Rates Tribunal, the Electricity Commission, and the Traffic Commissions. On the eve of World War II, however, PEP strongly recommended the transfer of regulatory functions in the gas industry "to a body of expert Gas Commissioners" [PEP 1939, 176].

The traditional argument regarding why the independent commission was not more favored in Britain focuses on the contrast between the U.S. system of judicial supremacy and the British tradition of Parliamentary responsibility. Certainly, these constitutional matters - and a dislike of legalism and formalism - acted as a deterrent to the commission form and do so today, although a certain legalism has crept into some recent proposals for reform. Evidence of the vulnerability of U.S. commissions to regulatory capture was another disincentive to adopt that form of regulation [Chantler 1933, 114]. A key reason for not finding more general acceptance of commission regulation in the United Kingdom before the two world wars was the extent to which public ownership and the development of new forms, like the public corporation, presented a viable alternative to the public control of utilities. "Great Britain is rapidly abandoning the administrative commission for what are considered to be more efficient instruments of public control," wrote one observer to his American colleagues [Cooper 1939, 7]. A common feature of the various models of the public corporation before 1939 was that there should be considerable freedom from political control and independent management. As such, they received wide cross-party support including that of opponents of socialism.(12)

Moreover, because much British utility regulation before 1939 took the form of price fixing or sliding-scale arrangements implemented by charters or franchises, often in a very local context, arguably the commission form of institutional structure neither fit nor was appropriate.

Now that public ownership has been abandoned in Britain and there has been a return to public control of privately owned and managed utilities, one significant reason for the neglect of the commission form - availability of a substitute in the form of public ownership - has been removed. As Dimock suggested, choice of a viable alternative in the form of the public corporation, rather than evidence that the commission form had been tried and found wanting, may explain why the independent commission was not more favored in Britain in the period between the two world wars [Dimock 1933, 59]. To some extent, rejection of the public ownership option by New Labour at the present time may explain the fresh interest in the commission form in Britain particularly as the existing system of individual regulators is becoming widely discredited. Pressure has indeed mounted to effect a change toward the commission form even from within the ranks of the existing regulators. The telecoms regulator Don Cruickshank recently urged the government to consider a switch toward a regulatory commission [Taylor 1997], and it seems that the government is prepared to countenance such a change [Beavis and Weston 1997]. In order to perform effectively, have a broad overview, and appreciate equity issues, which is sometimes lacking in the United States [Trebing 1984, 236-237], the commissions would need to be adequately resourced and monitored by statutory, independent, and publicly funded consumers' councils [CRPU 1996, 12]. Effective regulation requires the breakdown of the informational asymmetries not only between utilities and the regulator, but between regulators and consumer groups [Dee and Meek 1997, 123]. Trebing [1984, 237] found that the effectiveness of commissions in the United States was improved by better consumer participation through the public funding of consumer councils. That a move to such consumers' councils might have a significant impact is demonstrated by the recent submission of a formal "referral" by the Gas Consumers' Council to Ofgas, the regulator, under the Gas Act; this commits the regulator to investigate and then report back publicly on complaints that British Gas's recent round of price cuts discriminates unfairly against 3 million low-income families [Holberton 1997].

Conclusions

The broad ranging review of utility regulation by the cross-party Commission on the Regulation of the Privatised Utilities [1996] demonstrated a widespread and growing lack of confidence in the existing system of utility regulation in Britain. From various viewpoints the system was seen as unfair, unstable, and in need of far-reaching reform. The Labour government, in initiating its own government departmental review, has promised "a very tough regime" as the outcome [Godsmark 1997b].

This paper has focused on key aspects of the reform debate, namely a discussion of pricing policy with a suggested need for alternative regulatory tools and a demand for changes in the nature and character of the regulatory agencies. Attention has also been drawn to likely interactions between the choice of particular regulatory tools and the institutional forms of regulation. Unlike the bulk of recent scholarship, the paper has located the regulatory debate not only in the present, but in a longer-term historical framework, taking into account the period before nationalization. The mixed system of control before World War II included private companies, and it may be, as Foster [1992, 4] has suggested, that there "is much in that experience that is still relevant to the design of a modern regulatory system."

This paper suggests that evidence from earlier British experience points to inherent difficulties in pricing regulation and does not necessarily lend support to some suggested reforms such as the adoption of a sliding scale. The variety of forms of regulatory agency was matched by a complexity of regulatory instruments, making it difficult to establish appropriate linkages. Commissions of the U.S.-type never gained a significant foothold in Britain, but this may have had more to do with the positive choice of public ownership as an alternative, rather than perceived weaknesses - real or imagined - in the commission form.

As more competition is introduced into the utility industries in Britain, sections of these industries will cease to be natural monopolies. Yet the remainder will still face the perennial problems of control. The installation of a tougher, more effective regulatory regime, however, calls into question reliance on the limited resources now available in Britain and the match between choice of regulatory instrument and agency. Widening the objectives of utility regulation to bring in, for example, an appreciation of equity issues, and making consumer interests the prime consideration of utility regulation, as promised by the government [Kampfner and Halligan 1997], has a bearing on both the form of regulatory tool and the choice of institutional structure. The alleged "simplicity" of the original RPI-X regimes was accompanied by the choice of the single-regulator form, and any move away from price cap regimes, and more focus on a "balance" of regulatory objectives, perhaps strengthens the case for the commission or "panel of experts." However, it would be misleading to focus too much on the interaction between ways and means. As noted above, even some supporters of RPI- X regimes, like the telecoms regulator, have given support to the commission form.

The advent of a Labour government has raised some fears of an increase in the regulatory burden. Kay [1996, 156] has warned of an increase in "regulatory intrusiveness" over the last decade in Britain, a problem that he believes is endemic in RPI-X as well as rate-of-return regimes. The Labour politician Herbert Morrison, one of the chief advocates and architects of public ownership of utilities before and after World War II, foresaw a possible danger in tightening the controls on private utilities, which is perhaps worth bearing in mind today. "What becomes of capitalist 'incentive'," he argued, "if dividends are limited? . . . regulation would tend to be meticulous, irritating and severe . . . the very evils of bureaucracy, red tape, interference . . . which the Conservatives advance against socialism as a general doctrine . . . would in fact tend to be greater" [Morrison 1933, 77].

Nearly a quarter of a century ago, Trebing warned that regulation in the United States had lost much of its legitimacy and that the existing system was poorly equipped "to meet the types of problems posed by market-structure considerations." He recommended the development of new regulatory concepts and tools while keeping the commission form [Trebing 1974, 209-228]. In the present political climate in the United States, these steps are out of favor "for the foreseeable future" [Trebing 1996, 568], but they clearly have a resonance in the British context. Having tried weak regulatory palliatives since 1984, effective utility regulation is now called for in Britain. The Labour government has adopted a reformist agenda and will retain some of the main planks of the existing regulatory system. Public disquiet with the utilities may thus be eased, but the regulatory authorities must beware because public dissatisfaction will fuel the case for more radical change, perhaps in the form of improved social control. In the longer term, the case for public ownership of the monopoly elements of the utilities may once again return to the forefront of economic and political debate in Britain.