All Hands on Deck

All Hands on Deck
Why Power Sector Reform is Everybody's
Business
Ophelia Cowell
Paper presented at workshop Electricity Sector Reforms in Asia. Experiences and Strategies
World Social Forum, Mumbai, India, 19 January 2004

In the decade to 2003, energy sector reform - as a component of the broader process of economic liberalisation and integration prescribed by the International Monetary Fund and the World Bank -
has gathered momentum in Asia. Their aim is to remedy crises-ridden electricity systems - upon which most other economic sectors depend - by replacing its' social goals and meddling political interests with the perceived competition, efficiency and objectivity of market rules. For many cash-strapped countries, the prospect of wringing a one-time windfall from the privatisation of otherwise burdensome power sectors is more to the point. Whatever the motivation, with US$1.5 trillion in energy investments up for grabs to 2020, hundreds of millions of people yet without access, and major social and environmental impacts already being felt, power sector reform in Asia promises to be a contentious affair.

The case studies of this edition describe how reform is varying the governance, finance, consumer price, function, quality, reach and accountability of domestic power services in Asia. By so doing, reforms review or renew past commitments to technology and fuels, be they principally of finite, renewable, domestic or imported sources. Together, these decisions augur the sector's contribution to public debt, rural development and livelihoods, natural resource consumption and the trajectory of Asia's
greenhouse-gas emissions for the next half-century. Responses to power crises and reforms so far have been as varied as are the implications. Would-be investors advocate deregulation and standard policies across borders. Mass job loss - or the prospect of it - rouses workers and their unions, while steep price-hikes have brought farmers, retailers and householders to their streets in protest. Power failures threaten economic disaster and rile all consumers while, outside Asia, deliberate power cuts have been countered variously by activist 'reconnection' teams and even the public reclamation of utilities. These are a few of the flash points signifying that power sector reform is every bit the business of the broadest possible constituency.

For years, the virtues and pitfalls of market-reform have been the subject of debate among international financial institutions and their alternative-seeking critics. Within many reforming countries, however, the public response has been comparatively restricted to one or another aspect of reform even though it affects the daily life of frontline mining and power project-affected communities, every power user or would-be user and a vast number of employees. Experience so far shows that reform raises governance and development issues that require much greater attention from in-country corruption, corporate, and multilateral development bank watchdog organisations; with the support of international environmental NGOs, development co-operation organisations and advocates of renewable energy; climate protection and sustainable development. In lieu of having an impartial umpire, objective oversight without public scrutiny is scarcely a credible goal and 'market objectivity' is a contradiction in terms. Especially in countries yet to begin or cement reforms, civil society collaboration for greater transparency, accountability, participation (1) and independent regulation is a must for the protection of public interests and sustainable development in Asia.

Costing Power and Reform

Rhetorically at least, market reform leads to cheaper power because efficiency results from the competition introduced when power generation and supply functions are split to operate as businesses with profit targets. Thus unshackled, according to the World Bank, "the private sector offers... power at lower cost, especially to consumers with low levels of demand". (2) The charm of the theory gave way to disappointment in Asia where, contrarily in such
countries as India and Indonesia, soaring prices prompted dramatic public reactions. To an extent, initial price hikes are the unavoidable result of adjusting prices to reflect what it actually costs to supply electricity - a process which can entail the controversial removal of subsidies often originally set-up to appease one or another constituency rather than to fill genuine areas of need. Unfortunately, price hikes in Asia have not been the consequence of rational resource allocation but more often of the notorious deals struck with privately-owned Independent Power Producers (IPPs).

'Sweetheart' IPP deals - which first gained currency in the late-1980s and early 1990s -
typically transfer market risks to the State, first by obliging it to buy all power generated regardless of
whether it can be used and second, by having it pay - in foreign currency - for all the fuel so consumed. Often the details were withheld from public scrutiny, but even when above-board, their terms locked state utilities into long-term financing for over-production. In this way, Indonesia came to pay IPPs an "embarrassingly" excessive US8.46 cents per kilowatt-hour (3), and Philippines power bills doubled to become the second-highest in Asia (4) even though nearly half of the power consumers pay for wasn't used. (5) The Indian State of Orissa - Asia's pioneer reformer - endured 15 percent tariff increases yearly for nine years straight. Malaysia too invested heavily in new generators when "much of the electricity had no real market, prompting the
Prime Minister to urge consumers to use more electricity". (6)

While private-power became more abundant and more expensive, consumer subsidy reform often maintained or even amplified inequalities in prices and services. The newly revised Indonesian tariff
means domestic users paid 71 percent more than they did while bigger consumers only pay an extra 12.4 percent. In South Korea (7) and Philippines price disparity between regions and domestic and industrial user-types is expected to grow with reform. (8) "The
awarding of IPP contracts without a tender has become part of Malaysia's patronage process... where the IPP owners get richer and the consumers pay more". (9) In many countries, the
penalties soon "caught up with the initial euphoria... leaving taxpayers and consumers holding the bag". (10) The massive drain of IPP power and perverse subsidies is obstructing prudent investment and undermines the willingness of consumers to make sacrifices for genuine power sector reform. If the IPP experience has been a lesson in how not to usher private investors into the power sector, it should be possible to avoid similar experiences in countries now contemplating reform. But it is to the chagrin rather than accord of the World Bank, that instead of courting IPPs, Vietnam is mobilising
domestic capital to invest to meet its' power needs. (11)

Rigging the Competition

In Asia, reform has typically aimed for competition among private power generators but even in this very limited form, it has proved elusive. Against all the rules, Orissa's generation and distribution came to be dominated by just two companies. One company dominates the Luzon area of Philippines where three-quarters of power demand resides. In Andhra Pradesh, private producers constrain the freedom of transmission and distribution companies and in those spheres are "moving towards [the] replacement of public sector monopoly [with] private sector monopoly". (12) The Thai system is set to prevent newcomers entering the market and private participation in diverse and smaller-scale power projects in South Korea is unlikely to transpire. (13)

The reverse of competition resulted in Malaysia where privatisation is regarded as "a useful process... to transfer state assets into Party assets and to reward friends, relatives and supporters". (14) Indonesia hopes competition between power generators can rescue its ailing system but will surely be disappointed since privatisation without regulation has so far only compounded opportunities for corruption and inefficiency.

"The IPP experience in Asia offers a good example of ... institutional lock-in", with regulators, advised solely by international consultants who "influence how level the playing field is for different technologies... [and tend] to favour large generating plants. (15)

As a consequence, most three-quarters of the US$93 billion of private investments in Asia last decade went into constructing 286 fossil-fuelled power plants, while the rest went into existing
utilities, transmission or distribution. (16) Funnelling resources to dominant technologies and established grids narrows the odds for off-grid rural and decentralised power - a problem since 80 percent of people without access live in rural areas. According to the World Energy Council, "there are abundant resources in every region of the world to meet growing energy demand well into the 21st century", but for this to happen "it is essential for all regions and countries to diversify their energy portfolios". (17)
If those options are being foreclosed with reform, as they appear to be, so is the sustainable development
goal of bringing safe, affordable energy services to the 1.7 billion people that lack them.

In the decade that energy has been reformed in the image of 'competitive markets', the world paid well over US$2 trillion in fossil fuel subsidies. (18) Harder to
quantify are the benefits of indirect support via such avenues as the technical assistance provided by
publicly funded multilateral development banks that make oil, coal and gas projects possible. For comparison, just $1 billion was spent in the same period on clean energy projects through the Global
Environment Facility. (19) Whatever the full extent of the influence this radical bias of public spending has on downstream subsidies and investment in developing countries, it is clear enough that the emphasis of reform on competition hasn't levelled any playing fields.

A Waste of Energy?

New utilities will improve efficiency, the people of Orissa were told a decade ago, but today almost half of the States' power is still wasted. From generation to end-use, ten years after it embarked on reform, Indonesia wastes around a third of the power it generates at a likely cost this year of 31 trillion Rupiah, or around US$3 billion. Even in the face of looming power shortages, rather than tapping this vast resource, Indonesia is encouraged by the World Bank and the ADB to shelve its' efficiency policies in pursuit of US$1 billion in foreign investment annually in bulk new private power plants. Despite initial praise for Thailand's energy-saving programme, the IMF and the World Bank effected its closure via loan conditions that insisted on privatisation and, in effect, the construction of new generation capacity, which drowned the modest options out of the market. South Korean reform is similarly focussed on supply-side restructuring and large-scale privatisation, and so is geared to forfeit
the opportunity for demand-side efficiency. (20) Outside Asia, it's a similar picture. In Bulgaria, "the scope for energy efficiency is enormous... [but] progress has been slow... because greater end-use efficiency would have undercut the planned program of supply expansion". (21)

Selective Efficiency

While the costliness of waste has not been a major concern of reforms to date, the cost of labour certainly is. In South Korea, 7000 workers were laid off just to prepare for competition, and a further 30 percent-cut is anticipated with the imminent transfer of ownership of generation companies. (22) Similar, if not higher figures are likely to apply in Indonesia as reforms are resumed. The spectre of job cuts has drawn government assurances, for example, in Sri Lanka and Malaysia, that workers will be retained by the new owners or, failing that, by the state. But neither mass job losses, nor the artificial retention of labour would seem very stable arrangements, and both involve the transfer of substantial financial and social costs to the public sector. Where job cuts really do need to happen, coherent adjustment plans could surely deliver solutions of greater sustainability.

If the purpose of reform were to raise overall, as opposed to selective, efficiency, the need for new power capacity - and hence new private investment, public debt and risk - would be more objectively assessed and much reduced. If every power plant world-wide ran as efficiently as the best technology allows, US$80 billion per year would be saved and there would be "no need to design, finance, build and operate any additional capacity". (23) Asia's new and planned power plants aren't being designed to this level of efficiency, but even prudent management of older models would substantially reduce the need for new ones. Indonesia, for example, currently generates just 40 percent of the electricity its' existing plants are capable of yielding. Had Korea opted for further increasing efficiency and reducing energy intensity, it could feasibly spend "about $8 billion less building and operating new power plants" than it will under current plans. (24) As well as
maximising the yield from existing plants, demand for electricity can be drastically reduced through end-use efficiency, which means consumers look forward to cheaper power bills and hence a lower susceptibility to the tariff hikes that are otherwise bound to cause more strife and hardship in Asia.

The 'Trickle-up Effect'

South Korean observers apprehend "a possible leak of national wealth" (25) and they may be right to worry. Orissa owes four times what it did prior to reform
and the Philippines owed IPPs 230 billion pesos within a decade. Indonesia received US$47 billion, much of it on condition of privatisation, which further obliged it - through power-purchase agreements - to pay out US$135 billion to IPPs over thirty years. Now owing about 50 percent of GDP in external debt alone, rapid privatisation seems the only way to raise the necessary repayments and keep government liquid. It would have cost a comparatively tiny US$6 billion to electrify the remaining half of the population that lacks power access in Indonesia. (26) Though those 100 million people won't benefit at all from the loans or private investment, they will have to repay them.

A further drain on the domestic resources of several countries may prove to be the commitments they're making to import fuel for electricity. Thailand for instance, opted to import coal for the consumption of three of it's seven IPPs and Indonesia will begin to run out of coal and oil two decades before its' new and planned power plants will expire. In just ten years, the country will be a net oil-importer, and in twenty, a total oil-importer. From then on it must either pay US$11 billion every year for oil imports" (27) or, if the plants must be closed down early, billions in one-off compensation payments. Korea, if it opted out of plans for new coal power plants in favour of
increasing efficiency "could significantly reduce its energy imports, thereby improving its energy security". (28) Its too early to gauge the costs of premature or amplified energy dependency, but the International Energy Agency acknowledges that in Asia generally, even "a heavy reliance on local supplies of natural gas... is a wiser and probably a more economical choice than constructing new coal-fired plants". (29)

Power to Adapt

Research abounds on the probable causes and impacts of climate change on human health and livelihood. (30) Though the problem is attributable to the world's heaviest fossil-fuel users - generally OECD countries - the indications are that it will affect people everywhere. World-wide, economic losses due to natural disasters are doubling by the decade and approaching an annual $150 billion. (31) Droughts have already increased in frequency and
intensity in parts of Asia. Experience shows that a major factor in human survival amid rising sea-levels, higher disease prevalence and the type of extreme weather event that took 10,000 lives in Orissa in 1999, is the function of early-warning systems, emergency and medical services, transport, shelter and sanitation - each of which relies on electricity to some degree. (32) Reform could be mapping out the power sector's contribution to the so-called 'adaptations' of infrastructure that are urgently needed, as well as in supporting education and economic alternatives where upheaval is anticipated. Unfortunately, it is more probable that power sector restructuring is prolonging the causes of climate change.

Fuelling Climate Change

The prevailing wisdom is that greenhouse gas emissions must be cut 60 to 80 percent from 1990 levels in order to avoid dangerous climate change but still, "with current trends... fossil fuels will supply 90 percent of demand" by 2030. (33) Electricity - the fastest growing use of energy - already accounts for 38 percent of carbon dioxide emissions and virtually all the projected growth in coal consumption world-wide. (34) Asia emits just one tonne of carbon dioxide to North America's nine (35) but its' emissions will almost triple to 2020, assuming current plans prevail (36) for new generation capacity from coal in India, South Korea, Taiwan, Indonesia, Malaysia, the Philippines, Thailand, and Vietnam. Apart from the problems of price, technology concentration, national debt and rural-urban inequality these are likely to entail, they will further commit the region to high outputs of local air and climate pollutants. What's more, the World Bank has applied pressure to remove scarce environmental protections for new mining and exploration in, for example, Ecuador and Indonesia. This exposes communities to the more immediate impacts of land acquisition, subsidence, mine wastes and gas flaring, as well as the plant emissions, of sulphur, nitrogen oxides, particulates, mercury and methane.

By default, power sector reform in Asia is contributing to the problem of climate change
because the dogmatic insistence on raising new foreign investment, with the help of inflated energy demand forecasts, almost invariably translates into the justification of new fossil-fuelled power plants. Compounding its effect, the by-products of this trend include the flagrant waste of energy, the over-supply of electricity from carbon intensive sources and marginalizing the modest options of efficiency and decentralised technologies. Benefiting neither development nor climate protection, excess power is generated and sold to satisfy the need of IPPs to recoup investment in power plants. Having invested in them so heavily, the prevalence of fossil-fired power plants is assured for their 25-40 year life, though in some cases a great deal longer. (37) Unless expensive retro-fitting and compensation of private operators is entertained before that time, the basic emissions profile for the sector is fixed for that period. The roads, pipelines and grids that grow up around power plants may peg development and subsequent energy plans to that centralised foundation for much longer.

Indonesia's reform programme, which is being aggressively revived following the financial crisis is a case point. With several large coal-fired plants verging completion, emissions from electricity are set to grow despite the availability of cheaper, climate friendlier options that could benefit those not currently served by the established grid. These extra emissions are not the inevitable by-product of economic development, or even the necessity of resources being too scarce for cleaner growth. On the contrary, this development path is the brainchild of years collaboration between government and World Bank technocrats who "worked... to pursue a long-term agenda of investment and reform to... expand capacity based on coal and hydropower... with no effort at assessing available supply options and their full costs". (38)

Korea too has numerous reform choices before it. Increasing efficiency nation-wide would conserve capital and reduce reliance on imported fuel while reducing carbon dioxide and sulphur output by 21 and 25 percent respectively. Or, if restructuring entailed the levelling of taxes, a shift to natural gas from coal could decrease carbon dioxide emissions 9 percent. But if reform favours new power generation fuelled with imported coal, carbon dioxide output would double to 51 million tonnes in 2015. (39)

A decade of international negotiations under the Framework Convention on Climate Change hasn't come close to limiting carbon emissions to levels thought to be safe, but this parallel process of reform has done a great deal to ensure future emissions growth. What's more, the pressure for this particular brand of reform originates from the same OECD countries and international agencies that in more
visible forums are wont to criticise developing country governments for their projected emissions.

Spending on carbon sequestration and storage methods is a concession-of-sorts to the seriousness of the climate change problem, but probably represents good money after bad since the
technologies are at an early stage of development, very costly, and hence unlikely to ever help most
people. More likely, the investment feeds hopes that there will be an 'end-of-pipe' technological fix for
climate change and eases industry fears that the world might hesitate to renew its' commitment to the most carbon intensive fuels. But with reform proceeding as it is within the world's most populous nations, it seems an unnecessary precaution for them to take.

For Public Interests' Sake

According to the World Bank, just 30 percent of all reforming developing countries achieved a reasonable level of regulation. (40) At least according to the World Bank reform 'template', borrowing countries are to establish adequate regulatory processes prior to reform but this prerequisite is sidelined in practice by lender and investor pressure for speedy privatisation. It is clear from Asia's experiences that privatisation without regulation is fraught with problems but, based on the experience of other regions, regulation is unlikely ever to be sufficient under the current model of reform. In Orissa - where a recent review concluded that no benefits from five-years and billions of rupees invested in privatisation-based reform (41) - the
regulatory mechanism wasn't well established at the outset. Its ten years since reforms got underway but
Indonesia plans to defer attempts at regulation still. Of its' reform objectives: financial stability,
transparency and increased private sector participation, only the latter transpired but, without accountable oversight, even that resulted in international litigation. Where it has occurred, regulation lacks independence and accountability to the public. Answering the grievance that procedures were scrapped so that "over a dozen agreements with IPPs could be signed in just one night", the Andhra Pradesh Regulatory Commission asserted that it is "duty bound to promote privatisation and competitiveness", apparently above impartiality. (42) Even privatisation's trailblazing evangelists were stung: bungled regulation "will cost Californians approximately US$71 billion or US$2100 for every man, woman and child". (43)

Where it failed even by its' own standards, the shortcomings of reform in Asia so far must be evaluated and understood but World Bank reviews "appear to be based on the sole criteria of achieving financial closure or bringing down... barriers to investment". (44) Power sector reform in the Philippines "is a resounding success in terms of meeting the ADB and World Bank's bottom line [of]... private sector participation, but it is a dismal failure in terms of serving the interest of the public". (45)

The verdict may be yet to be formed in South Korea, Lao PDR, Cambodia, Vietnam, East Timor and the Indian State of Karnataka where promisingly, "the early indications are that some improvement in transparency may be established. (46) But where public funds and public interest are so heavily committed and where corruption has plagued earlier-reformers, transparency is hardly something to hope for - it ought to be assured. Asia's IPP debacle demonstrates that the private sector, like government is prone to inefficiency and corruption when sheltered from public scrutiny, independent regulation and monitoring. It seems evident that merely super-imposing market logic onto established power sectors can't reasonably be expected to solve their inherited crises, let alone to make a success of new rural energy provision, subsidy reform or least-cost planning - for these, real reforms are needed.

Engaging Alternatives

As the authors in this edition point out, power touches all walks of life, but public engagement within reforming countries has been wanting. In Karnataka, even the price hikes got by an otherwise alert and vocal civil society. (47) Responses were somewhat livelier in Andhra Pradesh, where price-hikes had opposition parties on one side, the ruling party on the other, farmers' organisations bristling at the implications for irrigation and researchers and campaigners chiming in either as paid protagonists or voluntary antagonists. With the help of a peoples' movement, the price of power had become "a major issue in all elections". South Korean initiatives to unite otherwise disparate groups along the common lines of better policy processes and governance are promising. Orissa's went so far as to actually review power sector reform, with the input of concerned citizens, consumer and employee associations, industry forums and the World Bank. But still, the debate in Asia has mostly stuck to price issues and post-mortems.

The novelty of power sector reforms in some countries and its' opacity in others partly explains the deficiency of public engagement. The implications of reform for ordinary people are often at first not fully appreciated and the exposure of publics to the similar trials of their counterparts abroad is limited or non-existent. Energy issues, at the best of times, are painted and perceived as being too technical for the public to have credible opinions on. The absence of strong consumers' organisations in many countries means "the returns to an individual... from participating in regulatory processes are very small compared to the returns to electricity suppliers". (48)
Independent specialists, that could provide support for the public on technical issues are scarce and government tends to be advised solely by consultants imported through the development banks or energy and mining companies that are already pre-committed to privatisation-based reform. Orissa's imported 'experts' cost the State three billion rupees up front, but the expense of the ill-suited advice they dispensed is still accruing.

Striking a reasonable balance of interests through reform and energy planning will require the tapping of in-country expertise to support civil society to engage in planning, monitor implementation and tackle problems through regulatory bodies. Where institutional information disclosure standards are slack, they must be raised and where it is lacking, public know-how must be cultivated - in-country, as well as regionally - since key policy-drivers like the ADB are themselves regional in organisation. Exchange with independent organisations in Africa, Eastern Europe and Latin America can provide valuable comparisons of the problems and applicability of alternatives. NGOs in donor countries can challenge their governments for supporting and financing reforms deficient in accountability or efficiency. International development organisations will need to gauge the compatibility of reforms with development and poverty alleviation objectives and help narrow the discrepancies.

No doubt, the scope and need for international NGO collaboration is great, but the essential basis for appropriate reform remains in-country where only a societal response can effect the change to more rational and sustainable energy systems that better reflect the public interest. Without that, the reform process will continue to be too easily obscured and captured by only the best-resourced and most attentive lobbyists. As the Orissa Review Committee put it so well, "what has taken place in the
electricity industry... is only restructuring [and] privatisation...The real reform, which brings in its
wake benefits to consumers, strength to industry and growth for the economy has yet to come".

References

1. Prayas Energy Group www.prayas-pune.org
2. World Bank, June 2002, Global Electric Power Reform, Privatization and Liberalization of the Electric Power Industry in Developing Countries, Energy and Mining Sector Board Discussion Paper series, paper No. 2, June 2002.
3. Kurtubi, US Association for Energy Economics (USAEE), opinion in The Jakarta Post, July 2002.
4. ADB Forum 2002.
5. Freedom from Debt Coalition, October 2002, 'Privatization and restructuring of the National Power Corporation and the Independent Power Producers.
6. See in this edition, Thomas B. Smith., Power and politics in Malaysia: infrastructure development in an era of privatization, Zayed University, Dubai, UAE. October 2002.
7. See in this edition, Yu-Mi Mun, Power Sector Reform in South Korea, Center for Energy and Environmental Policy, University of Delaware, USA. October 2002.
8. Ibid 4
9. ibid 5.
10. See in this edition, Nepomuceno A. Malaluan, October 2002, The Philippines electric power industry reform.
11. see in this edition Andrew B. Wyatt, Power sector restructuring in Vietnam: the construction and transfer of Risk, Australian Mekong Resource Center, University of Sydney. October 2002.
12. See in this edition, K. Raghu, M. Reddy, Overview of power sector reform process in Andhra Pradesh. October 2002.
13. ibid. 6.
14. ibid. 5.
15. World Resources Institute, 2002, Power Politics: Equity and Environment in Electricity Reform, page 167.
16. Data from International Energy Agency, International Energy Outlook 2002 and Power Sector Restructuring in Indonesia, Pelangi, Indonesia www.pelangi.or.id
17. Elena Virkkala Nekhaev, 'Sustainable energy development', Energy and Sustainable Development, World energy Council, August 2002.
18. Calculated from data of Global Green USA, Media Advisory and Climate Change report, August 27, 2002.
19. Mohamed El Ashry, CEO, Global Environment Facility, August 2002, 'Clean Energy: it's about time', Energy and Sustainable Development, World Energy Council, 2002.
20. Ibid 6.
21. Ibid. 19.
22. Ibid.6.
23. ibid. 21.
24. Jin-Gyu Oh et al, 1999, 'Developing countries and global climate change: electric power options in Korea, Kore Economic Institute and Pew Center on Global Climate Change, October 1999.
25. Ibid 6.
26. Pelangi Indonesia analysis 2002, www.pelangi.or.id
27. Pelangi Indonesia, 2002, Life After Oil,
28. ibid. 28.
29. IEA 2002 Energy Outlook
30. The Intergovernmental Panel on Climate Change, the 'umpire' in the science of climate change, noted the human contribution to climate change and the forecast impacts region by region in their Third Assessment Report, 2000, www.unfccc.de.
31. Finance Initiative of the United Nations Environment Programme, 2002, Climate Change and the Financial Services.
32. Friends of the Earth, 2000,Gathering Storm: the human costs of climate change
33. International Energy Agency, 2001, Key World Energy Statistics.
34. ibid 33.
35. ibid 37.
36. IEA 2002 Outlook.
37. In the Indian state of Karnataka, a century-old power plant is still operational.
38. ibid 19.
39. Ibid. 28
40. Ibid 1
41. Prayas Energy Group 2002, Lies, damn lies and statistics: a case study of power reforms in Orissa.
42. ibid 11.
43. TNI Energy Project 2002, Lights Off! Debunking the Myths of Power Liberalization, TNI Briefing Series No. 2002/5, The Transnational Institute, www.tni.org.
44. ibid.9.
45. ibid. 9.
46. See in this edition Y.G Muralidharan, A background paper on the power sector reform in Karnataka, India, Consultatnt for Consumer Advocacy, Karnataka Electricity Regulatory Commission, Bangalore, India. October 2002.
47. Ibid 50.
48. Ibid. 9.