The Challenges and Risks of Creating Independent Regulatory Agencies: A Cautionary Tale from Brazil
Prado, Mariana Mota, Vanderbilt Journal of Transnational Law
Between 1996 and 2002, the Brazilian government established independent regulatory agencies (IRAs) for electricity, telecommunications, oil, gas, and other infrastructure sectors as part of a very ambitious privatization program. Following the formulas advocated internationally, Brazilian IRAs have institutional guarantees of independence, such as fixed and staggered terms of office for commissioners, congressional approval of presidential nominations, and alternative sources of funds to ensure their financial autonomy. This Article analyzes the design of IRAs in Brazil and asks whether their institutional guarantees of independence were effective in insulating them from the political sphere. The Author's general conclusion is that these guarantees--typical of developed countries, especially the United States--failed to insulate Brazilian agencies. The Article indicates a number of episodes of political influence over agencies, and it applies detailed institutional analysis to explain what went wrong. The Brazilian experience illuminates the difficulties that many developing countries face in trying to realize the ideal of regulatory independence and the benefits that would supposedly flow from this. Thus, it might serve as a cautionary tale for policymakers and for developing countries contemplating similar reforms.
TABLE OF CONTENTS I. INTRODUCTION II. THE CREATION OF INDEPENDENT REGULATORY AGENCIES IN BRAZIL III. PRESIDENTIAL INFLUENCE ON INDEPENDENT REGULATORY AGENCIES A. Increases in Electricity Rates B. Increases in Telecommunications Rates C. More Recent Instances of Presidential Influence on Regulation D. Investors'Perceptions of Presidential Influence on IRAs E. Conclusions IV. THE POLITICAL ECONOMY OF THE CREATION OF INDEPENDENT REGULATORY AGENCIES V. THE INSTITUTIONAL DESIGN OF INDEPENDENT REGULATORY AGENCIES A. Appointment Process and Removal Power B. Chairmen C. Approval by the Senate and Partisan Balance. D. The Commission and Its Structure: Design E. The Commission and Its Structure: Effectiveness F. Financial Autonomy: Funding and Budgetary Allocations G. Institutional Guarantees of Independence in Brazil: A Summary VI. LESSONS FROM THE BRAZILIAN EXPERIENCE VII. CONCLUSION
Intuitively, it always seems better to have more options than fewer. There are many circumstances, however, in which this intuition is wrong. In Homer's Odyssey, for instance, Ulysses chose to tie himself to the mast of his boat, and to seal his seamen's ears with wax, so as not to succumb to the temptation of luring his boat to destruction by hearing the Sirens sing. Without tying himself, Ulysses would have had two options: succumb to the song of the Sirens and destroy his boat, or resist the temptation and sail safely to his destination. Ulysses knew that sailors on previous trips had not been able to resist the temptation and was afraid that he would meet the same fate. So, he chose to tie himself. For Ulysses, eliminating one of his options was the best strategy to reach his destination safely. (1)
During the privatization process, Latin American countries have encountered a situation very similar to the one faced by Ulysses. After a decade of negligible levels of economic growth and enormous fiscal deficits, Latin American countries were advised to sell their state-owned companies, especially those in infrastructure sectors. (2) Selling these companies would reduce spending of fiscal resources, increase efficiency in the delivery of infrastructure services, and attract much-needed private investments to these sectors and to the country as a whole. (3) Privatization of key infrastructure sectors would be an easy way out of the trap that Latin American countries found themselves in at the end of the 1980s, except for one important detail: private investors were not willing to sink large investments in fixed, unmovable infrastructure assets without having some guarantees that they would not be expropriated by opportunistic governments. (4) Thus, a successful privatization would be more likely to attract private investment to infrastructure sectors if governments were willing to tie themselves to the mast of their boats. The most important self-binding strategy for Latin American countries was to delegate their regulatory powers to independent regulatory agencies (IRAs). (5) The assumption was that IRAs (6) enjoy "autonomy" from elected politicians, thereby reducing the risks of expropriation, political manipulation, or short-term considerations related to the electoral cycle that could adversely affect private investment incentives in relevant sectors. (7) As a result, the creation of IRAs became one of the central institutional issues in the context of privatization reforms. (8)
This Article argues that this self-binding strategy has not worked. The Brazilian experience with IRAs shows that despite delegating regulatory powers to independent agencies, the government was still able to influence agency decisions. (9) Institutional guarantees that characterize IRAs in developed countries, especially the United States, were not enough to insulate Brazilian IRAs from the political sphere. (10) Based on a detailed institutional analysis, the Article explains why this happened and discusses the lessons that can be learned from the Brazilian experience.
These lessons are relevant because Brazil was not alone in believing that IRAs were the solution,n The World Bank and the Organization for Economic Cooperation and Development (OECD) recommended that countries promoting regulatory reforms and privatizations should create IRAs. (12) Advocates of these reforms believed that IRAs would create credible regulatory commitments, (13) thereby increasing the value of the state-owned companies to investors and attracting more private investment. (14) During the 1990s, U.S.-style IRAs were adopted in many European and Latin American countries, (15) becoming one of the primary means of regulatory governance worldwide. (16) In sum, despite this Article's focus on Brazil, the conclusions presented here should be relevant to policymakers and reforming countries around the globe.
Between 1996 and 2002, the Brazilian government established IRAs for electricity, telecommunications, oil, gas, transportation, and other infrastructure sectors. (17) These agencies were implemented as part of a very ambitious privatization program, in which the government was not only able to attract private investment, but was also able to sell state-owned companies for relatively high prices. (18) One could ascribe this successful outcome to the Brazilian government's credible commitment not to act opportunistically once investments had been made. In fact, many have claimed that the independence of Brazilian agencies has boosted investors' confidence. (19) Against this claim, the Author argues that the Brazilian IRAs are not as insulated from electoral cycles and the political sphere as they are perceived or expected to be.
Following the formulas advocated internationally, Brazilian IRAs were designed to have fixed terms of office for commissioners, Congressional approval of presidential nominations, and alternative sources of funds to ensure their financial autonomy. (20) These and other institutional features were implemented to guarantee that these agencies were not subordinated to the President's directive authority or to any other branch of government. (21) These features aimed to provide a high level of independence to Brazilian agencies. (22) This Article demonstrates that the aim went unfulfilled.
Because the Brazilian IRAs' design was inspired by the American experience, this Article will compare the effectiveness of IRA guarantees of independence in Brazil and in the United States. (23) In particular, the Article suggests that IRAs are not very independent in Brazil for three reasons. First, some institutional features of U.S. agencies were not implemented or fully transplanted to Brazil. (24) Second, some successful institutional features of the U.S. political and legal system were unsuccessful in Brazil. (25) Finally, some problematic features of the U.S. system were transplanted to Brazil, replicating many of the problems that have long existed in the United States. (26)
The Brazilian experience illuminates the difficulties that many developing countries face in trying to realize the ideal of regulatory independence and the benefits that would supposedly flow from this. Also, it replicates many of the challenges and obstacles in implementing development reforms around the world. First, the Brazilian case shows that political economy is often an impediment to institutional reforms in developing countries. Second, it illustrates the need to adapt legal transplants to the local conditions and particularities of the reforming country. Finally, it highlights the dangers of adopting an overly idealized view of the way the transplanted legal system operates in the country of origin.
The Article concludes that before starting the quest for an institutional design suited to the Brazilian context, the Brazilian government should ask if these agencies should, in fact, have high levels of independence. Brazil, and many other reforming countries, have yet to engage in a meaningful discussion about bureaucratic independence, its goals, and its limits. (27) Some of the cases discussed in this Article suggest that bureaucratic independence might increase investors' protection against opportunism, but that such independence might also impair the government's ability to control inflation or to protect legitimate consumer interests. Advocates of agency independence emphasize one single goal--investors' protection--and ignore the fact that some types of political interference with regulation might be guided by legitimate and justifiable goals. The assumption that all political interference with the regulation of infrastructure sectors will be opportunistic is the basic assumption behind all these reforms. This simplistic view of institutional reforms needs to be replaced with a more comprehensive analysis of the full-scale consequences of the institutional options third world countries can pursue.
The Article proceeds in five Parts. Part II shows that regulatory commitment was the main rationale behind the creation of IRAs in Brazil, and that insulation from Presidential influence was the main concern in providing such commitment to investors. Part III presents examples of Presidential influence over agencies. This evidence indicates that regulatory agencies in Brazil may not be as independent as their structure might suggest. Within this context, Parts IV and V investigate how this could have happened by analyzing the institutional design of regulatory agencies in Brazil. Part IV develops a historical analysis and shows that despite having a common rationale (investors' protection), circumstantial factors led to different institutional designs for the IRAs in the telecommunications and electricity sectors. The different designs of these agencies will be explored in detail in Part V, which develops an analysis of the agencies' institutional guarantees of independence and shows that IRAs in Brazil are not as independent as generally perceived or expected. Specifically, the Author argues that the electricity agency has fewer guarantees of independence than the telecommunications agency. Part VI draws some policy lessons from the Brazilian experience. The general conclusion is that IRAs are not a strong mechanism to secure regulatory commitment in Brazil, especially in the electricity sector, but it is not clear whether reforms to make these agencies more independent would be advisable given the range of policy goals pursued by the government.
II. THE CREATION OF INDEPENDENT REGULATORY AGENCIES IN BRAZIL
In Brazil, the creation of regulatory agencies for the telecommunications and electricity sectors was largely informed by an interest in signaling the government's commitment to a stable, existing regulatory framework (also known as "regulatory commitment"). (28) The assumption was that political opportunism and concerns associated with electoral cycles may affect the application of the regulatory framework and the interpretation of statutes and contracts, thus undermining investors' confidence. (29) The agencies' independence would reduce this risk by insulating the regulatory framework from the political sphere. (30)
The Executive branch was the main proponent of IRAs in Brazil. It is not completely clear where the proposal to implement IRAs in Brazil actually came from, or even whether the proposal came from one single source or from different sources in the executive branch. (31) Despite its unclear origin, many people involved in the process of creating IRAs in Brazil frequently point to international influences. (32) Following the international discourse, the proponents of IRAs in Brazil believed that a decision by the Executive branch to create self-imposed limits on its regulatory powers by delegating them to IRAs would be interpreted as a signal of commitment and would attract investors. (33) Following this discourse, the executive branch sent bills to Congress proposing the creation of IRAs. (34)
There are at least three possible reasons why the Brazilian government decided to follow the international discourse and why governments around the world are increasingly relying on IRAs. (35) First, politicians are willing to improve the credibility of their policies and solve the problem of political uncertainty in order to guarantee the success of privatization reforms. (36) Second, regulatory agencies have now been taken for granted as the appropriate form for regulation, and politicians are just following the trend without asking whether there are any concrete benefits in doing so. (37) Third, there are network effects of implementing such institutions once a number of countries have implemented them. (38) That is, the shift to IRAs can be seen as an attempt to capture the gains of "positive feedback" or "increasing returns" created by the presence of IRAs in other countries. (39) It is not clear which of these three motivations, if any, prevailed in Brazil, but there is no reason to rule any of them out as plausible explanations of the creation of IRAs by the Cardoso administration.
The fact that the executive branch was the main proponent of IRAs in Brazil and was the entity conducting the reforms, shifts the focus of our attention to the President. (40) In the United States, the prevalent theoretical approach to regulatory agencies is to model a principal-agent relationship between the regulatory agency (agent) and the entity that delegates its power (principal). (41) In the American scenario, the principal is Congress, but in the case of Brazil it is the President. (42)
One could argue that this Presidential-dominance model does not necessarily rule out some sort of influence by Congress on IRA decisions; however, this is not the case in Brazil. In the United States, Congress can influence IRAs by changing (or threatening to change) the enabling act or statute, by limiting the agency's discretion through legislation, by monitoring agencies through oversight committees, and by imposing controls on the agency's budget. (43) The Congress, however, is not as strong in Brazil, where the Brazilian President has more control over the legislative process, thus reducing the Congressional power to change the enabling statute of agencies or to limit Presidential discretion through statutes. (44) In addition, the Brazilian Congress has no oversight power over the heads of independent agencies and has very few controls on IRA budgets. (45)
In sum, the Brazilian Congress has very little power to exert influence over independent agencies, whereas the President has significant powers to do so. Thus, in contrast with the United States, once agencies have been established, the biggest threat to their independence comes from the President, who can influence IRAs in many ways, including the imposition of controls on IRA budgets. (46)
The President not only has power to influence regulatory agencies, but may also have incentives to do so. If the President will be held electorally responsible for what the agencies are doing, for instance, the President has strong incentives to try to influence them to implement popular policies. For example, the President could try to make the agencies reduce the electricity rates for residential consumers, given that electricity rates have been historically determined by the executive branch and are likely to be perceived as the President's responsibility even after privatization. (47)
Also, the President might feel the need to avoid conflicts between regulatory policies implemented by sectoral regulators and other policies that are being implemented by the Executive branch. Thus, even if the President is not acting opportunistically, he may have strong motivation to interfere in some regulatory decisions in order to ensure that they will not conflict with the Executive branch's social or macroeconomic policies. For instance, the President might find a need to reduce telecommunications and electricity rates to control inflation. Because there are many different situations where the regulation of the infrastructure sector can affect or overlap with other governmental policies, it seems reasonable to assume that the President will often have incentives to try to influence the agencies.
Finally, the Brazilian bureaucracy may facilitate Presidential influence over agencies. Before privatization, the regulations for telecom and electricity were under the Executive branch's jurisdiction (through Ministries). (48) After privatization, people inside the Ministry who previously worked under the former regulatory framework could continue to operate under the assumption that the new regulatory agencies are subordinated to the Executive branch. Institutional memory will not disappear overnight, and this may distort the way bureaucrats interact with the new agency. This phenomenon may be aggravated if the agency's staff is composed of people who used to work for the Ministry or for the former regulator before the privatization, as was the case in the electricity sector. (49)
In sum, the Executive branch's institutional powers, the Brazilian bureaucracy's traditions and habits, and the incentives that may affect presidential behavior, combine to make the President the most significant threat to the independence of agencies and the stability of the regulatory framework. Hence, an analysis of the actual level of independence of the Brazilian regulatory agencies should focus on the relation between these agencies and the President.
III. PRESIDENTIAL INFLUENCE ON INDEPENDENT REGULATORY AGENCIES
To set the stage for the analysis in the rest of the Article, Part III presents several concrete situations in which there are signs of varying degrees of presidential influence over regulatory outcomes. (50) Only cases in which presidential preferences (or Executive-branch preferences) were publicly known are discussed. (51) By contrasting the final regulatory outcome with publicly announced Presidential preferences, Part III will identify when these preferences were implemented by the relevant agency. An interesting aspect of the cases is that often the agency initially manifested a preference contrary to the Presidential preferences, but that the final outcome was closer to the Presidential preferences than to the agencies' preferences. (52)
Part III makes two points. First, concrete cases demonstrate that there is presidential influence on regulatory outcomes in Brazil. Second, these cases suggest that the telecommunications agency Agencia Nacional de Telecomunicacoes (ANATEL) is more independent than the electricity agency Agencia Nacional de Energia Eletrica (ANEEL). However, these interagency differences may be declining over time.
The cases illustrate the most important efforts by President Luis Inacio Lula da Silva's first administration (2003-2006) to influence the behavior of the electricity and telecommunications agencies. The Article will discuss two cases related to increases in the telecommunications and electricity rates and two cases regarding regulation in general. With one exception, (53) the publicly announced presidential preferences were implemented by the agencies.
A. Increases in Electricity Rates
At the time of President Lula's inauguration in January 2003, representatives of the new administration publicly stated their intention to halt electricity rate increases. (54) However, to avoid a decrease in investors' confidence in the sector, the newly elected government sought to halt increases without changing legislation or contracts. (55) In this context, the strategy chosen by the government was to influence the electricity sector agency (ANEEL), which was in charge of interpreting and applying the statutory and contractual provisions related to electricity rate increases. (56)
Following the government's announcements, ANEEL's first decision regarding electricity rates was to limit the level of the increases to which utility companies were entitled in that particular year. (57) To comprehend ANEEL's action, one must first understand the difference between electricity rate adjustments and rate increases. Distribution companies are entitled to annual rate increases composed of inflationary and non-inflationary adjustments. (58) These annual increases are called rate adjustment (reajuste tarifario). (59) Every four years, electricity distribution companies are entitled to a re-evaluation of the rate structure; during the re-evaluation, ANEEL considers the factors that comprise the rate and determine the inflationary and non-inflationary adjustments. (60) This special increase is called rate review (revisao tarifaria). (61) The system of rate increases was supposed to work as follows: after the rate review, distribution companies would continue to have yearly rate adjustments for four years until the next review. (62) Since the processes used to determine rate increases in adjustments and in reviews are different, normally the levels of increases also differ. (63) For some companies, the rate review would imply much higher increases than those that would occur if the government were merely making an adjustment. (64)
ANEEL decided to limit the rate increases by adopting whatever procedure (adjustment or review) that would bring the lowest increase. (65) More specifically, ANEEL limited reviews to a level of increase equivalent to a rate adjustment if the former was higher than the latter. (66) Whenever the rate reviews would yield increases greater than adjustments, ANEEL would grant an adjustment, not a review. (67) In contrast, in the case of utilities that would have a higher increase with the adjustment, ANEEL would only grant them the review. (68)
ANEEL normally submits the proposed methodology for rate review to the public for notice and comment (audiencia publica) before implementing it. (69) In the case of this particular decision to limit increases, however, ANEEL did not submit the methodology to the public. (70) Instead, the decision was first announced in February 2003, when ANEEL submitted to public notice and comment the proposed rate increase of four out of seventeen electricity distribution companies (most of them privatized companies) scheduled for a rate review in 2003. (71) Despite the companies' complaints, ANEEL used the same criteria to propose four other companies' increases in March. (72) At least two companies had their increases actually limited by the agency. (73)
ANEEL stated that it was not refusing to grant the full increase as determined by the rate review process; instead, it was implementing a rollover. (74) The company would be entitled to recover the lost revenue (calculated as the revenue that would be obtained with the difference between the percentage of the increase in the rate adjustment and in the review adjusted to inflation) in the next three increases. (75) Enersul, for instance, was entitled to increase its electricity rates by 42.64% in 2003, but instead received an increase of 32.59%. (76) From 2004 to 2007, Enersul would have a rate adjustment plus an additional increase each year, which would grant a rate of return equivalent to the one the company should have had in 2003. (77)
The central question here is whether or not the Lula administration influenced ANEEL's decision to limit the electricity rate increases. Aside from never holding a notice-and-comment process to discuss its decision, ANEEL did very little to justify the limitation, stating only that the limits on the increases were imposed to reduce the impact of the increases on consumers. (78) This argument, however, was challenged by one of the most active consumer protection entities in Brazil, IDEC, which claimed that the additional increases to compensate companies for loss of revenue would hurt consumers in the long term. (79)
Another potential reason for the decision is related to inflation. As mentioned earlier, the Lula administration was planning to halt rate increases, and this decision has often been reported in the newspapers as an attempt to control inflation. (80) It is debatable, however, whether levels of inflation are within the scope of the regulatory agency's mission. ANEEL's self-declared mission is to promote favorable conditions for the development of the electricity market while balancing the interests of companies and society. (81) In addition, statutory provisions define the tasks under the agency's jurisdiction. (82) These statutory provisions do not mention inflation or any macroeconomic issues. (83) In fact, the Brazilian Central Bank and the Ministry of Finance are the entities in charge of this and other macroeconomic issues. (84) Thus, ANEEL was not justified in limiting the increases on these grounds. (85) In contrast, Lula's administration had strong reasons to halt rate increases and, as the initial declarations show, intended to do so. (86)
Although it is not possible to cite concrete evidence of presidential influence in the general decision of ANEEL to limit rate increases, there is at least one other episode that also suggests the existence of Presidential influence over regulatory outcomes. This episode involved a company called Centrals Eletricas de Pernambuco (Celpe), the electricity distribution company for the state of Pernambuco. In March 2005, Celpe asked for a 56.78% increase in its rates. (87) Celpe alleged that its costs had increased due to a power purchase agreement signed in 2005. (88) According to this contract, Celpe stopped buying electricity from hydropower plants for 62.8 reais (R$62.8) per mega-watt hour (MWh) and started buying electricity for R$137.3 per MWh from a thermal power generator (Termopernambuco) (89) that belongs to the same corporate group that controls Celpe (Neoenergia), and that started to operate in 2004. (90) Although Celpe's expenses had increased by R$254.5 million a year, that money turned into profit for the new thermal power generator, thereby staying within the same entity and in the pockets of Neoenergia shareholders. (91) Thus, an increase in rates to cover Celpe expenses would yield higher profits to Neoenergia, the group that owns Celpe and the thermal power plant. (92)
President Lula and the Minister of Energy tried to convince the agency to reject Celpe's request. (93) Public servants, who prefer to remain anonymous, said that the government asked ANEEL not to grant an increase of more than 25% to Celpe. (94) ANEEL declared that without the expenses incurred pursuant to the power purchase agreement, Celpe would be entitled to an increase of 21.05%. (95) In the end, ANEEL decided to (1) limit it to an increase of 24.43% in 2005 and (2) grant an additional increase of 12.5% in the next three years as a rollover of the adjustment to which it was entitled in 2005. (96) The first part of the decision is in line with governmental preferences, but it is unclear whether the second part could also be. If the government was merely concerned about meeting inflation targets in 2005, it might well be the case that it is. If the government did not want to reward a self-dealing arrangement, then the second portion of the decision would be contrary to governmental preferences.
Given the special circumstances of Celpe's review, it is unclear if the outcome was determined by presidential influence over the agency, or whether the agency came to this decision on its own. In this regard, the sources' anonymity makes it hard to evaluate if the information is reliable. In fact, contrary to the information provided by the anonymous sources, the government has denied any involvement. (97) The chairman of ANEEL, in contrast, has indicated that the "administration has certain concerns as regards the levels of increase of regulated prices," but he has also denied that the Executive branch interfered with matters under ANEEL's jurisdiction. (98)
All these examples suggest that there might be Executive influence over ANEEL. To be sure, there is a fine line between determinant influence over the agency to implement Executive preferences, and an autonomous decision on the part of the agency to consider the government's preferences before enacting new regulation. The variables considered here do not allow a firm conclusion as to which side of the line ANEEL falls, but its position is in sharp contrast with the one taken by ANATEL, the telecommunications agency. ANATEL's reaction to the same proposal of halting rate increases is discussed below; it shows resistance on the side of the agency to cooperate with the Lula administration.
B. Increases in Telecommunications Rates
Similar to the declarations in the electricity sector, in April 2003 Lula's chief of staff (Chefe da Casa Civil), Jose Dirceu, declared that the government wanted to negotiate with telecommunications companies, settling on a reduced increase in their rates that would not violate contractual and statutory provisions. (99)
One month later, the Minister of Telecommunications, Miro Teixeira, formulated a proposal that would modify the inflation index used to adjust telecommunication rates. (100) The adjustment would be according to a consumer price index (IPCA) instead of a general price index (IGP-DI). (101) This change would generate a lower level of increase in telecommunications rates. (102) In fact, at the time the proposal was made, the consumer price index indicated inflation of 17%, while the general price index was indicating a rate of 32%. (103) The proposal, however, encountered fierce resistance even inside the government because some believed that it would imply breaching statutory provisions and concession contracts. (104)
The President then presented a new proposal limiting the 2003 increases to 17% and rolling over the remaining percentage to the next three years. (105) In other words, the government's proposal was similar to the policy adopted by ANEEL in the electricity sector. (106) ANATEL, however, did not accept the government's proposal. (107) In contrast to the case of the electricity sector, the final regulatory outcome was not the one proposed by the government. ANATEL granted rate increases by adjusting rates to inflation according to the general price index (IGP-DI). (108) As a result of this decision, telecommunications rates experienced an average increase of 28.7%, and some services had increases of up to 41.75%. (109)
Why did ANATEL resist the government proposal while ANEEL did not? On the one hand, these different reactions might be a result of two independent decisions by ANEEL and ANATEL to interact with the government in a cooperative and confrontational way, respectively. On the other hand, they can also be interpreted as a sign that ANATEL was better able than ANEEL to resist governmental pressure given its stronger guarantees of independence. Below, Parts IV and V argue that ANATEL has stronger institutional guarantees of independence and that this may have contributed to its differing reaction.
C. More Recent Instances of Presidential Influence on Regulation
The rate-increase cases suggest that the level of presidential influence over ANEEL and ANATEL is different, but this is not to say that the President has a weak influence on ANATEL. In fact, there are instances in which Lula's administration successfully interfered with a regulation's content in both the telecommunications and the electricity sectors. One such case in each sector will be analyzed below.
In 2005, the Lula administration began implementing a new system of public bids for the sale of "new electricity," or electricity produced by new power plants. (110) Before the public bids, ANEEL was in charge of issuing new …
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Publication information: Article title: The Challenges and Risks of Creating Independent Regulatory Agencies: A Cautionary Tale from Brazil. Contributors: Prado, Mariana Mota - Author. Journal title: Vanderbilt Journal of Transnational Law. Volume: 41. Issue: 2 Publication date: March 2008. Page number: 435+. © 1999 Vanderbilt University, School of Law. COPYRIGHT 2008 Gale Group.
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