arrangement is dependent on the government paying its dues on time- something that has not happened in Senegal and Pakistan. How this will translate as we the new framework in implemented remains to be seen. As of the time of the writing of this paper, the government seems to be committed to raising tariffs and has done so every year since 2014.

On quality regulation, the new framework incorporates a number of established good practices such as requirements to meet quality standards (penalties for not meeting them), requirement for utilities to report technical data to the regulator on a periodic basis and making the reliability measurements public.

On market entry, also the regulator has been provided the requisite responsibility and power for providing permits to new entrants. However, EgyptERA is not legally required to approve all power sales contracts. Needless to say, given the state control of the sector, the regulator has not had a lot of scope to exercise its power in the past. However, with the country aiming to introduce significant solar generation through the IPP route, the regulator’s role will be important in the coming years.

Table 8: Formal regulatory substance in Egypt and comparators, 2015<sup>21</sup>

||**Egypt**|**India, AP**|**India, Odisha **|**India, Raj**|**Morocco**|**Pakistan**|**International**<br>**benchmark**|
|---|---|---|---|---|---|---|---|
|**Regulatory Substance**|**78%**|**76%**|**76%**|**79%**|**40%**|**83%**|**76%**|
|**Tariff Regulation**|**75%**|**75%**|**75%**|**75%**|**29%**|**83%**|**77%**|
|_Regulatory Frameworkfor Tariffs_|_100%_|_100%_|_100%_|_100%_|_33%_|_100%_|90%|
|_Determination of Tariffs_|_50%_|_50%_|_50%_|_50%_|_25%_|_67%_|64%|
|**Quality Regulation**|**83%**|**83%**|**83%**|**92%**|**33%**|**100%**|**75%**|
|_Quality of Service Standards_|_100%_|_100%_|_100%_|_100%_|_50%_|_100%_|82%|
|_Quality of Service Enforcement_|_67%_|_67%_|_67%_|_83%_|_17%_|_100%_|68%|
|**Market Entry Regulation**|**75%**|**71%**|**71%**|**71%**|**58%**|**67%**|**77%**|
|_Permitting New Entrants_|_100%_|_75%_|_75%_|_75%_|_50%_|_100%_|90%|
|_PPA Approvals_|_50%_|_67%_|_67%_|_67%_|_67%_|_33%_|57%|

Note: Scores based on index developed for the Rethinking Power Sector Reform Project. For more details go to project website at http://www.esmap.org/rethinking_power_sector_reform The new law governing the sector was incorporated in 2015 and all institutions are adjusting to the changes made under the law. At the time, when data was collected for the study, the new regulations and framework were being implemented and not enough time had passed to judge whether the new framework was actually being implemented in their true spirit. However, the perceived index gives us an opportunity to understand how regulation is being practiced in the sector as of 2015.

A very interesting picture emerges from the comparison of the de jure and perceived indices. The overall score on regulatory framework falls from 60 percent to 28 percent (table 9). On every indicatoraccountability, autonomy, tariffs, quality and market entry the regulator is seen to be not implementing all the practices that are part of the 2015 framework. The differences are extremely egregious in quality regulation and transparency practices. The regulator is unable to exercise its authority on tariff levels and

> 21For more detail about the material in this table, see the Annex.

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