[eccr] Comments invited on Draft Paper 'Making and Keeping Regulatory Promises'

Title: Comments invited on  Draft Paper 'Making and Keeping Regulatory Promises'

We are writing to ask for your critical review (or any other form of advice) on a draft paper:

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Making and Keeping Regulatory Promises by Warren G. Lavey,

The principal concern of this paper is that telecommunications carriers make less productive decisions on uses of resources because of uncertainties about future regulation. The effects of multi-year regulatory promises are considered through analysis of several regulatory actions involving telecommunications carriers in Mexico, Venezuela, Hungary, and the United States. Regulators have made and kept (more or less) bold multi-year promises under some conditions. The analysis considers the conditions leading to the making of these promises and the decisions to comply with them, often under market and political conditions substantially different from what was expected when the promises were made. Although multi-year plans may contain clear adjustment mechanisms for some possible future conditions, major macroeconomic downturns can swamp some of the rate and service commitments by both regulators and carriers. Conditions may not be conducive to multi-year promises in some areas
, but clarity in the standards and timing for some future regulatory actions can enhance the efficiency gains. The analysis is divided into two sections, the first discusses examples of multi-year regulatory promises made and enforced (more or less) in four countries; the second presents two conclusions about making and keeping regulatory promises.

Please let us know if you find this draft report to be on the mark or tell us what we should do to improve it.

The document is in PDF format on our Web page at http://pirp.harvard.edu/pubs_pdf/lavey\lavey-draft-02.pdf <http://pirp.harvard.edu/pubs_pdf/lavey/lavey-draft-02.pdf> . Please let us know if you prefer to have us send you a hard copy.

More information about our Program is available from our office or at our Web site http://www.pirp.harvard.edu <http://www.pirp.harvard.edu/> . You can communicate with us via on-line editing, e-mail, traditional mail, or any other means you prefer.  We would appreciate having your comments by April 25, 2002.

We look forward to hearing from you.

Anthony G. Oettinger
John C.B. LeGates
(617) 495-4114 - Phone
(617 495-3338 - Fax