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Airport Yardstick Reg.
Airport Yardstick Reg.
a b s t r a c t
Keywords:
Airport economics
Policies
Airport performance
Regulation
Privatization of airports
The European airport industry is subject to various forms of economic regulation and there is debate as
to which of the systems provides the best incentives for allocative and productive efciency. This paper
deals with the applicability of benchmarking as a regulatory tool for airports. This form of regulation
aims at evaluating the cost level of a rm by comparing it to the mean marginal cost structure of all other
rms in the market. The paper investigates the difculties arising from airport benchmarking as well as
the benets that might be derived from it by drawing lessons from benchmark regulation in other
industries and the few cases where it has been applied to airports. In particular, it assesses whether
yardstick regulation is a feasible alternative to the existing forms of economic regulation or whether
yardsticks are more useful for internal management purposes.
2009 Elsevier Ltd. All rights reserved.
1. Introduction
Regulation of airports ranks high on the agenda of air transport
policy in Europe. After many failed attempts in the nineties the EU
Commission has nally succeeded in getting the directive on
airport charges approved (Council of the European Communities,
2007). The draft on airport charges has caused a erce debate
between airports and airlines on issues of cost-relatedness of
airport charges, single versus dual till, fair prot margins and so on.
The role of incentives implied in different regulatory arrangements
has been largely neglected or has only been discussed as a side
issue.
This is in sharp contrast to the perspective emphasised by
regulatory economics. How to set incentives for cost efciency and
for an efcient price structure that allocates scarce resources efciently is the central topic of regulatory economics. It was doubted
in the seventies and eighties that the traditional organization of
public utilities either in the European type of a state owned and
managed entity or in the US type of a private but cost related
regulated industry provides strong incentives for efcient
outcomes. These types of public utilities were largely seen as being
x-inefcient and having a price structure based on an arbitrary
historic cost method.
In the airport sector, the infrastructure remains in many cases
the monopolistic bottleneck and regulation instead of competitive
markets has to set incentives for efciency. But the traditional form
of cost-plus regulation was seen as inadequate and should instead
be replaced by incentive regulation. This regulatory reform is progressing at different speeds in each of the public utility sectors and
in different jurisdictions. The UK took the lead and adopted a price
cap regime for all public utilities, sometimes combined with cost
control and yardstick regulation,1 as for example in water regulation. Continental Europe followed but very often only partially and
with long time lags. This is in particular the case for airports where
we observe a slow trend towards incentive regulation. The concept
of yardstick regulation has so far largely been neglected with a few
exceptions.
Airports are public utilities because they share the cost and
demand characteristics of other industries like energy, water and
telecommunications. The provision of these utilities goes along
with cost subadditivities, i.e. the cost of producing a certain
output or combination of outputs is lower with one rm than
with several rms. Furthermore, the investment in the network
to provide these services is associated with high sunk cost. Given
this common background most studies on the regulation of
public utilities have tended to conne itself to one or two
industries. While there are certainly economies in specialisation,
we also think that there are economies of learning from each
other. In this paper we would like to focus on the issue of
incentive regulation, and in particular how a certain form, namely
1
The terms yardstick
interchangeably.
regulation
and
yardstick
competition
are
used
75
Continental Europe has been fully privatized without any ownership restrictions (Gillen and Niemeier, 2008).
The start of the privatization process, however, has helped to
change the business model of public airports in mainland Europe. It
has also made these airports more prot-oriented. At the same
time, it shows the need for a more systematic regulatory structure,
because from the view point of the users, many publicly owned
airports are using their market power as much as their partially
private counterparts.
In Europe, airport charges have traditionally been regulated on
a rate of return or cost-plus basis, along with a single till (Fig. 1).
Charges should generate just enough revenue to cover total costs,
including the depreciation of capital and a normal rate of return on
capital for the whole airport. The structure of charges should also
be cost related, namely each charge should reect its costs.
This way of regulation changed with the new style of regulation
of UK airports. The Civil Aviation Authority (CAA) is an independent
regulator that is responsible for a few large airports. Like other UK
regulators it has adopted a hybrid price cap. The price cap is set for
the regulatory period of ve years according to the CPI-X formula
for the average of regulated charges based on the cost of the airport.
The single till principle is applied so that rising non-aeronautical
revenues lower charges via a higher X. Price cap regulation has also
been copied by some other European authorities. In 2000, the price
cap for Hamburg airport was the rst one to be set on a dual till in
Europe reecting the view that regulation should be conned to the
monopolistic bottleneck and incentives for developing the non-
Fig. 1. Type of regulation at European airports. Source: Gillen and Niemeier (2006).
76
Table 1
Comparison of DEA and SFA properties.
Attribute
DEA
SFA
Parametric method
Accounts for noise
No
No
Yes
Yes
Types of measurement:
Technical efciency
Allocative efciency
Technical change
Scale effects
TFP change
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
77
78
use this knowledge as a chance to further invest in their infrastructure and to aim to further increase their efciency. Otherwise,
using a biased benchmarking process poses the danger that the
benchmarked company will be judged incorrectly by this process
although its seemingly inefcient operations are due to other
reasons and to external effects, which the rm cannot inuence
(Coveney, 2006). If these inefciencies are translated into regulatory objectives by the regulator the danger of misallocation of
resources occurs. Therefore, it is important to analyze which of the
inefciencies are caused by managerial strategies.
Another issue is related to the missing link between the costs of
an airport and the prices it is allowed to charge. The detachment of
the airports costs from its revenues might not allow for a reasonable rate of return on capital that will give rms an incentive to
conduct further investment. If the regulator does not take this
relation into account, the policy recommendations on the basis of
a benchmarking analysis will therefore not be appropriate and
cannot be translated into meaningful efciency guidelines.
4.5. Examples of yardstick regulation in the airport sector
There are examples in the European airport industry where
benchmarking studies have been used in regulatory proceedings.
Dublin Airport Authority plc (DAA), for example, has been subject to
a form of yardstick regulation to determine the prices an airport is
allowed to charge. In 2001, the Commission for Aviation Regulation
(CAR) (2001) commissioned Infrastructure Management Group, Inc.
(IMG) to conduct a benchmarking analysis of Aer Rianta (ART),
a subsidiary of Dublin Airport Authority plc to assess the efciency
of ART from an operational and nancial standpoint. Therefore, the
collection of data, as well as the performance measurement that
were used in the analysis, aimed at identifying performance
targets for Dublin, Shannon, and Cork Airport. There was a group of
peers chosen for each airport according to volume of services (e.g.
annual passengers, aircraft movements) and airport characteristics
(e.g. terminal capacity, CAPEX levels, number of stands) and it was
also taken account of the fact that there would be no direct
comparability between the investigative airports in the peers.
The key performance indicators selected by the CAR to measure
the cost efciency included the operating expenses per work load
unit (WLU) and per employee, as well as the labour expense per
employee. Financial performance was measured by taking revenue
results and protability of the different airports into account
(Commission for Aviation Regulation, 2001). The benchmarking
study conducted in 2001 used these key performance indicators to
determine efciency guidelines for the three airports. For Dublin
Airport, the study identied an inefciency of about 30% concerning its OPEX per WLU. CAR in turn set an efciency improvement
target of 15%, which resulted in an efciency guideline of 3.5% per
annum for ve years.
The resulting criticism by the airport concerned the choice of
peers that it was compared against, as well as the translation,
although not direct, of the observed differences into efciency
guidelines. Due to that criticism, CAR requested international
comparative information on the performance of Dublin Airport in
2005, i.e. a further process benchmarking was conducted (Commission for Aviation Regulation, 2005). The results acquired from this
subsequent analysis were however not transferred into efciency
guidelines as was done in 2001. Instead, this was taken as informal
information supplement in the decision making process concerning
the determination of the price cap for the next regulatory period.
This example shows that efciency differences from a benchmarking analysis cannot always be easily explained and therefore
such results have to be treated cautiously when applying them to
regulatory decision making. Otherwise airports might end up
becoming loaded with objectives they are not able to full because
they cannot inuence some of the parameters that drive their costs.
In the UK, the Civil Aviation Authority (2000) also considered
a form of benchmarking analysis when reviewing the regulatory
framework for the BAA airports. The CAA issued rst a draft proposal
highlighting the use of benchmarking as a supplementary tool for
the setting of price caps for BAA airports that are subject to economic
regulation. By highlighting the benets and problems associated
with the use of benchmarking as a regulatory tool, the CAA tried to
give its own evaluation on how such an analysis might be applied.
One of the objectives of the CAA was to estimate a cost function and
thereby identify key cost drivers of an airport, an approach similar to
that used in other regulated industries in the UK. In addition to that,
the CAA highlighted benchmarking as a way of measuring relative
efciency and performance of the various airports and thus identifying inefciencies which can be eliminated by a more stringent
regulatory process. It also looked at the benchmarking of partial
processes such as the level of service quality as an area where such
a tool can prove to be useful (Civil Aviation Authority, 2000).
The approach CAA chose in its draft was similar to the one
applied in the benchmarking analysis by the CAR. For each regulated BAA airport there would have been a set of peer airports
against which the airport under consideration would be compared.
The CAA also highlighted the problems of choosing the appropriate
parameters for the analysis and the fact that there are external
factors that affect an airports performance and that cannot be
inuenced by the airport management.
Criticism of this approach by the airports includes the difculty
of properly benchmarking the costs of different airports as well as
the model chosen by the CAA (British Airports Authority, 2001a,b).
Furthermore, a statement by the International Air Transport Association (2001) argues that differences in quality of services,
investment cycles and planning processes rule out the effective
application of benchmarking as a regulatory tool for airports.
Nevertheless they would consider benchmarking to act as an
explanatory tool when it comes to identifying differences in
airports performance. Although the CAA did not make explicit use
of benchmarking in implementing its regulatory framework for the
four BAA airports in its decision in 2002, benchmarking still plays
an informal role when it comes to assessing the airports performance (Bush, 2007a,b).
5. Yardstick regulation in other network utilities
Yardstick regulation is more advanced in the electricity and
water sector in Europe. Although these sectors exhibit characteristics such as homogeneous products (Table 2) which make yardstick regulation easier to apply than in the airport sector, there are
some features within the regulatory framework that can be useful
for the airport sector as well. For example, economies of scale in
size play an important role as well, as does density of demand. In
addition to that, exogenous and endogenous heterogeneities are
also explicitly accounted for.
The approaches within the different industries outlined above
differ slightly as to what method has been applied and how the
benchmarking results were used within the regulatory framework.
In order to adjust for exogenous heterogeneities, the Norwegian
regulator NVE included factors that account for climate and
topography in the different regions. The same was done by the
Dutch regulator DTe which took account of regional differences
faced by the distribution companies. A major point that the NVE
plans to consider in the new regulatory period is the allocation of
costs to the different activities and thus to try to distinguish clearly
between those arising in the monopolistic sectors and those in the
competitive sectors (Bjorndal, 2006).
UK Adjustment by topography
and density of demand, different
catch up parameters
Differs from airport to airport,
decentralised regulation (regional,
local governments rate of return,
price cap, hybrid forms)
Heterogeneous product
(Multiproduct rm aviation
and non-aviation business,
differences in outsourcing)
Airports
Aviation side
(infrastructure runway capacity)
Homogeneous product
Water
Distribution
Methodology
Electricity transmission
and distribution
Product
Homogeneous product
or processes (i.e. transmission
with different voltage levels etc)
Industry Sector
Table 2
Yardstick regulation in three European public utilities.
Monopolistic Bottleneck
Regulation
Heterogeneity (adjustment)
79
2
Non-aeronautical services are often indirectly regulated by the single till
principle applied at most European airports.
80
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