Private Finance Projects and off-balance sheet debt - Economic Affairs Committee Contents

Memorandum by Centre for Public Service Partnerships, College of Social Sciences, University of Birmingham

  1.  The Centre for Public Service Partnerships (CPSP) at the University of Birmingham welcomes this opportunity to submit evidence to the Committee's inquiry on private finance projects and off-balance sheet debt.

  2.  CPSP was established by and at the University of Birmingham to be a leading knowledge base for research in public service partnerships nationally and internationally; to be an international hub for the generation and dissemination of new insights and ideas (theoretical, methodological, empirical and practical) in the study and delivery of public service partnerships; to be the leading source of authoritative, evidence based advice on public service partnerships for governments, the wider public sector, international agencies, the third sector and the business sector, academics and other stakeholders; and to influence public policy and practice to enhance the outcomes of public service partnership working.

  2.1  As part of its programme, CPSP has recently engaged with key players in the market to determine the impact of the credit crunch on UK infrastructure projects.[1] The study covers conventionally procured projects, and public private partnerships including PFI in the health, education, defence, highways, waste, housing, and regeneration sectors.

  2.2  Another project[2] aimed at establishing the reasons for success, and causes of failure, in all types of public private relationships. It was particularly concerned with identifying ways in which these partnerships can be refreshed, and therefore sustained over the long term.

  2.3  CPSP has also recently undertaken a project on complex project management, with specific reference to PFI, for the National Audit Office.

  2.4  It has undertaken evaluations and other studies relating to specific PPPs, and related issues.

  2.5  Evidence from the studies has been used in the drafting of these responses.

  3.  The questions posed by the Select Committee address many of the issues associated with the PFI environment, particularly those prompted by the recent reduction of liquidity in the markets. There are, however, other challenges which impact on the debate about the future of privately financed infrastructure projects.

  3.1  There are issues to do with the sources of funding; debt finance from the Banks is currently more difficult to obtain whilst balance sheets and capital reserves are rebuilt. Such debt finance, as is available, is accompanied by higher margins. It is arguable that for the foreseeable future terms will be shorter, margins will be higher, and quantums will be smaller. This might provide an opportunity to explore and embrace new forms of funding. As interest rates have fallen the margins have grown and this has impacted on value for money calculations.

  3.2  There are differences between the requirements of capital intensive and service intensive projects; the Government recognised several years ago[3] that the procurement of Information Technology contracts, involving major software development, was difficult using the PFI model. Other service intensive projects, where the upfront capital injection is relatively small compared with the annual operating revenues, need a different approach again.

  3.3  There is a strong political as well as technical debate on the appropriateness and impact of PFI and PPP. For too long they were seen by government and others as the principal source of procurement and financing for infrastructure projects. This led to a failure for critical examination of the benefits and disbenefits of PFI on public services and public accountability.

  3.4  There would be consequences if the UK abandoned PFI; the rest of the world has followed the UK in the development of strong private finance industries.[4] They have paid the UK industry for sharing our knowledge and experience, and as the BRIC economies continue to expand, there is much more to come. We should build on the solid platform established over the past 17 years. The World Bank and other agencies promote PPPs as part of the development programmes for the emerging economies. CPSP has been involved in discussions with Brazilian public agencies, including the Federal Government, and this has reinforced the view that this is global phenomena with global potential for the UK. However, the Scottish Government has adopted a different model based on Public Services Trusts.

  3.5  PFI should be considered in terms of its social value; impact on service outcomes; the consequences for the workforce; and public accountability and transparency, as much as on any straight forward economic value.

  4.  The concept of PFI has been seriously challenged by many. It does not suit all types of project, it is not easy to make major changes in requirements, and we know that procurement costs are still far too high; it can take a very long time with consequential opportunity costs for all parties. Nevertheless, it is our contention that the procurement and servicing of public service assets, through the use of private finance at risk, is here to stay in some form or other. Clearly, a full evaluation of all alternative sources of finance and procurement should be considered, with decisions taken on the approach that will best deliver value for money over the whole life of a project, but private finance can be a valuable tool in the successful procurement of infrastructure projects; delivery of assets on time, to budget, and with the confidence that they will be "fit for purpose" over the whole of their lifecycle.

  4.1  There is a volume of publicly available evidence which is positive about PFI. Over recent years—as the numbers of projects entering the operational phase has become statistically meaningful—studies and reports by the National Audit Office, Partnerships UK, the Office of Government Commerce, and by a number of private sector bodies,[5] have all concluded that PFI projects have been largely successful, and that public sector clients and users are generally satisfied with the outcomes.

  4.2  The accountancy issues are important,[6] but less so than ensuring that the overall deal represents good value. The Value-for-Money and affordability of a project should rank higher than whether a project is on or off balance sheet. HM Treasury's guidance[7] on the use of five business cases (Strategic; Economic; Financial; Commercial; and Programme Management) as the way to establish the value-for-money case, is an important step forward in this debate.

  4.3  The use of private sector funding can provide a viable means of renewing public infrastructure without placing additional strain on public borrowing levels. Ultimately, Government borrowings are supported by the taxpayer, and there are limits to the numbers of projects which can be sustainably funded at this lower (than private sector WACC) cost of finance. Moreover, it is often forgotten that the private sector costs sometime include management of risks which would otherwise be borne by the taxpayer. (In some circumstances, the ultimate risk will always be borne by the public sector as in the case of the London Underground PPP which failed.)

  4.4  The continuing backlog of poorly maintained public infrastructure, and the need for major new investment to stimulate and drive the UK economy, mean that Government cannot contemplate a lull—however temporary—in the commissioning of new projects.

  5.  Most organisations must take "make or buy" decisions; choosing between what they do themselves, and what they buy in. These decisions are known to everyone; automotive companies deciding whether to make or buy components; householders deciding whether to cook a dinner or buy a "ready meal". It was the elaboration of the "make or buy" decision, and its implications for the transaction costs and consequent size of firms, which secured the Nobel Economics Prize in 1991 for the British economist, Professor Ronald Coase.

  5.1  The ruling principle is one of "comparative advantage" ie specialising in what you can do better than others, and taking advantage of their "comparative advantages" by buying in what they can do better than you.

  5.2  The decision to use private finance should not be made in the ideological terms of social provision versus capital provision, or in terms that portray PFI as an example of private sector rapacity versus public sector naivety (or vice versa), but in "make or buy" terms.

  5.3  The calculation of costs and benefits of private finance schemes does not rest on simple generally agreed economic or accounting methodologies.

  6.  The value and benefits of PFI have been acknowledged in a number of studies and reports.[8] Although it has had its problems (equity returns, service delivery, cost of change, etc), these challenges have been met and overcome as the industry has matured; lessons have been learned; and the public sector has enhanced its procurement and client management capability and capacity and the underlying principles of transparency, accountability, and long term planning, have been strengthened. It is absolutely the right time to move on with further development and innovation of these models. Nevertheless, it is worth first reminding ourselves of the accepted benefits (over traditional methods of procurement) of the "conventional" PFI structure:

  6.1  Long term outcomes:

    — Public sector client satisfaction is improving;[9] this is largely attributable to the presence of equity at risk, which provides strong incentives to manage the long term performance of the project and hence to maintain good and trusting relationships with the client.

    — There is evidence of greater user and staff satisfaction;[10] it seems this is due to the building of stronger working relationships as operational issues are dealt with in a timely manner.

    — Long term performance of the project is incentivised through a payment mechanism, which incentivises the private sector partner to deliver what is required by the public sector and users.

    — Some projects now measure and reward the achievement of outcomes (such as an improvement in customer satisfaction, or a reduction in vandalism).

    — Operational phase problems are dealt with more effectively[11] owing to the long term financial exposure of equity to the risks of poor performance.

  6.2  Effective risk transfer:

    — There is an increased focus on risk; allocation of risks to those best able to manage them creates incentives to succeed, and transparency encourages proper risk analysis and mitigation.

    — Increased due diligence is evident at all stages of the project; this is directly attributable to the role of the lenders, monoline insurers, and rating agencies.

    — Projects that have failed during construction have been bailed out by equity.[12].

    — The public sector has been shielded from much of the financial impact of failed projects.[13]

  6.3  Value-for-money:

    — The integration of design, construction, maintenance, and operations, is encouraged by the long term presence of equity.

    — Design and service delivery are brought together for long term benefits; a "whole-of-life" approach to the procurement of facilities, with the attendant ability to compare costs of different approaches using Net Present Values.

    — Independent rating of a project is possible, largely through the ability to shift risk from senior debt to equity or to government, as appropriate.

    — Transparency of the true cost of managing infrastructure and associated services increases accountability to the tax payer.

    — The use of private sector finance gives greater choice as to where to use limited public money.

  6.4  Environmental:

    — Environmental awareness is enhanced through the adoption of life cycle asset management. For example, the operating company is incentivised to use the best value equipment and technology, to seek continuous reductions in the amount of waste generated, and to carry out major capital replacements on a needs basis, rather than on a pre-planned cycle.

  7.  There are some arguments against the use of private finance which need to be addressed; since its inception in the early '90s, there has been a steady stream of complaints that PFI is not only not doing what was intended, but that it is also responsible for some of the more serious failings in public service delivery.

  7.1  There is concern that the system has not adversely affected the rights and conditions of the public sector workforce, but the TUPE legislation was in place a long time before PFI arrived, and other advances such as the statutory guidance on two-tier working, and the "retention of employment" model, are designed that the workforce should be protected.[14] The industry has evidence[15] to suggest that transferred employees have a wider range of responsibilities, better training, and better prospects for their future. However, there is also much contrary evidence. CPSP intends to undertake some further study on matters relating to the workforce practices and conditions, and their impact on service outcomes.

  7.2  "PFI costs more because Government can borrow more cheaply ..." Although it is certainly the case that Government debt is cheaper than the debt used to finance PFI projects, this is ignoring the position of taxpayers, who play the role of equity in this financing structure, and the consequent need to prudently manage the level of public sector debt. In other words, it is wrong to use the headline cost of government debt financing. Indeed, it is perhaps better to consider the (lost) opportunity to invest the cash in other projects, where the overall return—measured in macro socioeconomic terms—is greater. Whole life costs should be taken into account, and consideration given to the common problem of cost over runs on traditional procurements.

  7.3  "Credit crunch means no new PFI deals ..." Despite the difficulties, 30 new PFI and PPP deals have been signed since July 2008. The CPSP study identified a number of challenges attributable to the credit crunch, and in particular noted a prolongation of the financial close process while new sources of debt finance were identified and activated. The HM Treasury Infrastructure Financing Unit (TIFU) made additional funding available in March 2009, but has made only one investment to date. This is because the Banks and European Investment Bank (EIB) have responded positively to the opportunities still in the market. Certainly, we are seeing significantly different financing terms (more akin to the mid `90s environment), and these may find a permanent place in the new structures as we move out of recession. Overall, the market is still healthy, competition is still strong, and other forms of debt funding are emerging.

  8.  One common complaint from all parties has been the unacceptable costs of procurement. It is not uncommon for major projects to take 4 years from announcement in the Official Journal of the EU to "financial close". The CBI working group on "Procurement and PFI" recognised the shortage of procurement skills (in both the public and private sectors) as a major factor contributing to the lack of competition in some sectors; the cost of bidding outweighing the expected returns over the life of the contract. There is an argument for considering a change in the methods of training those in the public sector that are responsible for PFI procurement and contract management. A move towards a "learning by doing" methodology of training would lead to more efficient individual and organisational behaviour.

  8.1  Poor preparation of the project brief by the public sector client has been a problem since the inception of PFI. All too often, the brief is developed during the tender period, with consequent overrun of bidding periods and costs incurred by all parties.

  8.2  Poor advice from the "advisor" consultants can exacerbate the problem of getting the project to "financial close". In part, this has been caused by the tightening of fees paid by the public sector. There should be no incentive to "spin out"' the bidding and negotiation processes in order to increase the total fees earned. This can be overcome by incentivised consultancy contracts to ensure closure to a specified date for a specified price.

  8.3  There has been an insistence on very detailed drawings and specifications from all competitors, even in the earliest stages of the bidding process. In the `90s, this happened because many public sector procurement teams struggled to understand the difference between input and output-based contracts. Subsequently, it became a device to get all bidders onto the same level; permitting minutely detailed cost comparisons, and thus limiting the possibility of later criticism by local and central government auditors.

  8.4  Over-long negotiation periods, particularly after the introduction of the EU "Competitive Dialogue" process, are a major factor in the overall cost of procurement. Many Government departments have established their own procurement agencies (Homes and Communities Agency, Partnerships for Schools, Community Health Partnerships, Defence Equipment and Support), which are charged with supporting local project procurement teams. It is a difficult to strike the right balance between giving guidance and taking the lead, and the inevitable tensions between the "centre" and the project teams have caused unnecessary delays in decision making.

  9.  The global financial recession has provided an opportunity for a major rethink in the structuring of private finance deals. We know that the cost of finance rarely dominates the value-for-money case,[16] so our current recession-fuelled desire for a "return to the good old days of 2007" is probably misplaced. In reality, it was back in 1995 when we saw the last `normal' year in terms of project financing; we are very unlikely to see again either a return of very high equity gains or, indeed, very low debt interest rates.

  9.1  Long term PFI loans have been increasingly "out of synch" with the Banks' much shorter term business models. Loan tenors of five or seven years are becoming the norm; this will raise questions about refinancing at the end of each term, and in particular who takes the risk. The Australians are experimenting with their so-called "mini-perm" arrangements, where there are contractual provisions for terminating the concession and refinancing at the end of an agreed short term.

  9.2  As the PFI market has commoditised over the past 15 years, so has the debt/equity ratio tightened; deals were being signed with as little as 7% equity commitment, and much of that was in the form of fixed coupon quasi-equity "loans". This has resulted in financial structures which are inherently inflexible, as the debt providers have made it increasingly difficult for either the public sector client or the private sector operator to react to anything out-of-the-ordinary. Already, we are seeing a return to more sensible debt levels, and consequently higher demands for equity; this will allow a much more business-like approach to the handling of future changes in user-need in the project.

  9.3  The lack of liquidity in the banking system has allowed Government to consider different approaches to allocating risk between the parties. Several initiatives are now running[17] wherein the public sector is retaining risks previously accepted (albeit reluctantly, and with a significant premium) by the private sector. This is resulting in much better value for money, as the risks are in effect "self-insured" (as a contingent liability) by the public sector. This has the added benefit that the public sector is incentivised to think about the impact of, for example, policy changes during the life of the concession.

  9.4  The long term nature of a private finance deal is much better suited to the investment criteria adopted by the Institutions. There is an opportunity to develop a range of approaches, which would make investment in infrastructure projects much more attractive to these Funds; tax incentives, underpinning debt, and accepting residual property risk, are three possible Government interventions.

  10.  However challenging the last 17 years have been, over 1,000 PFI projects have been signed,[18] and many billions of pounds of infrastructure projects are now in operation. Moreover, new models are emerging which take the best of private finance and combine this with the best of Strategic Partnering. Equity is being shared between the public and private sectors, and the resulting joint ventures are set up to consider and develop streams of projects, each tuned to the needs of the new location, the new technology, and the new user.

  10.1  Local Improvement Finance Trusts (LIFTs) were the first of these new ventures, and provide a variety of community health facilities. These structures are now relatively mature, and a secondary market has developed where equity is traded. The new "Express LIFT" structure has made good progress in reducing the costs of procurement, and the costs of construction, through the use of "project delivery organisations" and framework contracts.

  10.2  Building Schools for the Future (BSF) is a large programme designed to renew or refurbish much of the primary and secondary schools estate over the next 15 years. Here, there is a mix of private finance and traditional procurement. It will be interesting to see how this arrangement may impact on-going maintenance of those schools that will be funded out of the Local Authority's revenue budget. There is the negative prospect of a two-tier schools estate being created, if this dichotomy is not addressed soon.

  10.3  Waste Partnerships are the latest incarnation of this model. Here, the challenge is to manage risks associated with the different technologies of waste separation, treatment, and disposal, whilst accepting that future waste volumes are difficult to predict, given that society is becoming ever more environmentally aware, and that total volumes have reduced during the recession.

  11.  So, what about the future? Although there were various forms of "take or pay"-type contracts signed in the power industry in the `60s, and the world's first toll road has already been returned to the Spanish Government at the end of its 30 year concession, the UK really started the PFI ball rolling in 1992; to that extent, the rest of the world is still looking to us[19] to help them embrace the latest techniques and structures. Indeed, some countries—learning from our experiences (and incidentally providing us with much needed export revenues)—have "leapfrogged" the UK in the introduction of refinements to the basic model. In Japan, for example, increasing focus is on the procurement of "Project Delivery Organisations" (PDOs), which manage the procurement of the design and construction phases, and become the deliverers of the operational services to the public sector client once construction is complete. Certainly, the private finance model can be further improved, and the recent credit crunch has given us the opportunity to introduce new ideas and new structures:

  11.1  Central procurement expertise is essential to achieve the necessary standardisation of approach, rapid decision making, and value for money risk allocations. These teams could be area-based, and might employ incremental partnership techniques.

  11.2  There is evidence[20] that collaborative working between public and private sectors is more effective than simple "arms length" transactional relationships. This is best delivered through business-like joint ventures, where aligned objectives are an essential ingredient for success, and where private sector profit motives can sit alongside social purpose.

  11.3  These "Good Partnering" techniques should be adopted during the tendering process, so that procurement times and costs are reduced to a minimum, the joint venture business starts as it means to proceed, and the prospects for a sustained high value relationship are high. The EU's so-called "restricted procedure" has many merits, and could ensure the selection of the preferred partner in three months or less.

  11.4  New forms of financing will bring added value; one solution is to obtain access to institutional funding. In principle, there is a close match between the funding requirements for PPP and PFI schemes, where affordable long term finance is required, and the investment needs for pension funds, which want long term, low risk investments. More effort might be invested in designing and facilitating a role for institutional investors in the primary financing role in public private partnerships.

  11.5  New tax sources might be used to provide finance. Supplementary Business Rates will be used to finance Crossrail and could be used for other projects.[21] The use of Tax Incremental Financing has been widely discussed in connection with Accelerated Development Zones. These approaches could help kick start redevelopment schemes in some areas, albeit at the risk of more public borrowing now; this will need to be repaid from future prospective tax income which would be unguaranteed and uncertain.

  11.6  Increased charging for services might be considered. New charges or higher charging could be introduced for a range of services. Roads and motorways appear to be the most suitable areas, where the increased use of road tolls and congestion charging (possibly linked with hypothecated spending) could provide income streams to finance new highways, motorways and river crossings. Issue of equity and economic impact would need to be taken into account when any charging was considered.

  11.7  Public sector bodies continue to be asset rich, and solutions based on accessing that wealth (subject to Treasury agreement...) to secure improved infrastructure might be sought. Precedents of successful redevelopment using asset leverage exist;[22] however, these date back to when the market conditions were different. To have real impact on infrastructure, the scale of redevelopment would need to be substantial, and the amount of assets transferred significant. Addressing this through area-based development companies or local asset-backed vehicles might be a way forward. Structuring such vehicles as real estate investment trusts or limited liability partnerships to facilitate tax relief—and thus secure outside investment—might be considered.

  11.8  In the past, enterprise zones have been established to stimulate investment in times of recession. In the case of development zones, investors were freed from paying business rates for 10 years, and tax benefits in the form of accelerated capital allowances and corporation tax benefits were put in place. Such schemes did create a focus for development, and the zones did achieve quicker development of areas of need. The use of tax policies to generate capital investment in infrastructure might therefore be considered.

  11.9  Our research highlights the desire for infrastructure provision that allows flexibility in revenue budget management. This requirement is at odds to the solutions provided by PFI solutions and conventional procurement which envisage long term asset ownership, long term financing and firm commitment to asset maintenance. The current arrangements for most if not all PPP and PFI contracts inhibit future flexibility rather than support it. This arguably suggests less long term ownership of non-specialist assets, more operating leasing, and effectively the development of more standardised multi-use buildings. The feasibility of such radical approaches would require careful analysis of need, and consideration of the merits of alternative buildings for service delivery.

  11.10  Area based solutions in respect of infrastructure development might be employed more commonly. There have been instances of joint procurement between public sector bodies, for example, in street lighting and between the NHS and local government, but they are not yet commonplace.

  11.11  The extension of prudential borrowing might be considered. Local authorities throughout Great Britain have had prudential borrowing powers since 2004. These powers have been used extensively; in 2007-08 over £3 billion of prudential finance was employed in England to support projects. This finance is readily available at lower rates of interest than private finance, and has been used to facilitate projects that would have otherwise been difficult to finance. The prudential borrowing regime has been extended to Foundation Hospitals from April 2009; however, this is a more restricted facility than that available to Local Authorities.

  12.  Other issues that need to be addressed:

  12.1  Public confidence in private enterprise and market systems has been severely dented by the spectacular mismanagement, governance, and regulatory failures in the financial services sector. This makes it even more vital that companies providing public services and involved in PFI are transparent about their financial and operational performance in their public sector contracts and, indeed, in their wider business activities. They will need to publish performance results in real time and in an accessible form. They will also need to accept greater public scrutiny—both by Parliament and local authority scrutiny committees.

  12.2  Contracts need to embrace ways of gauging public and/or customer satisfaction and make some elements of the suppliers' payments subject to this.

  12.3  Commercial confidentiality should not stand in the way of openness—it needs to be carefully defined and applied only in exceptional cases, and only at specific times. This could prove more difficult for public sector clients than for business sector providers.

  12.4  Contractual terms could be published; "Commercial confidentiality" should not be applied to avoid political discomfort. An extension of the Freedom of Information Act to cover more explicitly contracted providers could have a beneficial impact.

  12.5  The industry and the public sector should define and agree accountancy standards for financial reporting and "open book" processes. Companies and their public sector clients should expect these to be subject to external audit.

  12.6  It is essential that the workforce and their representatives including trade unions are engaged more fully not only in procurement decisions but also in the monitoring of performance. There is an opportunity to consider offering staff a form of equity in schemes.

  12.7  There is a need for a review of the impact of current regulatory arrangements designed to provide support and protection to staff affected by PFI and PPP schemes. The aim should be to ensure that workforce practices enable effective and efficient service delivery in ways that are reasonable and fair to the employees concerned. There has been considerable trade union concern that this has not been the case. An evidenced based analysis is required and any shortcomings addressed.

  13.  Summary

  13.1  PFI and PPP have made a significant contribution to public infrastructure development and investment in England and the wider UK. This is also the case internationally and the application of PFI is growing globally.

  13.2  However, it is essential that the model be recognised as one of several sources of finance and procurement. It should be applied when it demonstrates the best value for money and not for ideological reasons or "because this is what we do".

  13.3  There are and have been some legitimate questions raised about PFI and these should be addressed through evidence based analysis.

  13.4  There is a stronger case for applying PFI to infrastructure than to complex services which will by their nature require the flexibility to change over time in response to users needs choices; technological advance; and changing public policy and public finance conditions.

  13.5  There are issues of transparency and accountability that are being addressed but which require greater urgency. Similarly, the engagement of the workforce and the various measures introduced to provide protection to employees need to be reviewed—not to reduce protection but to ensure that good workforce practices support good public service outcomes.

  CPSP would be pleased to discuss and or amplify any of the points made in this submission.

September 2009

1   CPSP: The impact of the credit crunch on UK infrastructure projects, forthcoming. Back

2   CPSP: Public Private Partnerships-sustaining and refreshing relationships, May 2009. Back

3   HM Treasury: PFI: Meeting the Challenge, July 2003. Back

4   CBI: Going global; the world of public private partnerships, July 2007. Back

5   CBI: Building on success: The way forward for PFI, June 2007. Back

6   PriceWaterhouseCoopers: The value of PFI: Hanging in the balance (sheet)?, 2008. Back

7   HM Treasury: Public Sector Business cases using the Five Case Model, July 2007. Back

8   CBI: Building on success: the way forward for PFI, June 2007. Back

9   Treasury: PFI: strengthening long term partnershipsBack

10   Treasury: PFI: strengthening long term partnerships Back

11   PartnershipsUK Investigating the performance of operational PFI contracts, 2008. Back

12   Jarvis plc; Ballast plc; National Physics Laboratory. Back

13   Metronet Infracos transfer to Transport for London, May 2008. Back

14   National Audit Office: Protecting staff in PPP-PFI deals, March 2008. Back

15   KPMG: Effectiveness of operational contracts in PFI, 2007. Back

16   HM Treasury: Value for Money Assessment Guidance, November 2006. Back

17   Homes and Communities Agency: Private Rental Services Initiative, July 2009. Back

18   PartnershipsUK: PFI: State of the Market, 2007. Back

19   Partnerships UK's international desk. Back

20   Global Business Partnership Alliance: Organisational issues in Outsourcing Partnerships, 2007. Back

21   HM Treasury, CLG: Business rate supplements: a white paper, October 2007. Back

22   Croydon Council Urban Regeneration Vehicle (CCURV), June 2008. Back

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