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Monday, December 29, 2014

The Darker Side of Stabilization Clause in Investment Agreements



Till now (refer to above mentioned links), we studied only the advantages of having a stabilization clause in a PPP contract. However, we must not forget that a Stabilization Clause works the other way round too. For any investor, Stabilization Clause and Operational Predictability are two completely different aspects. There is no doubt that a Stabilization Clause certainly generates some amount of Operational Stability and Predictability. However, the states are becoming increasingly conscious about the use of their natural resources by the private entities. The Clauses relating to fairness and equity sometimes override the effect of the Stabilization Clause in an agreement.[1]

The concept of Sustainable Development and Human Rights also has a role to play in this respect. Stabilization Clause makes sure that laws relating to environmental norms and work conditions do not change with time. If an imprudent investors enters into a BIA with a Stabilization Clause and later on realizes the need to change the environmental standards or work conditions for increasing the efficiency of the project, the investor simply cannot do so if a Stabilization Clause is in place.

Another important issue in this respect is the use of technology. Governments usually enter into PPP because they do not have the technical know-how and expertise to carry out a complex project. Thus the governments expect that the private investors use the highest level of technology in their projects. Hence, if an investor for the sake of reducing the costs decides to use older technology without affecting the efficiency aspect, the stabilization clause would prohibit him/her from doing so.

The stabilization clause also plays a substantial part in increasing the paper work of the investor. There are hundreds of compliance reports that are to be submitted by the investor to the government.

Sometimes Stabilization Clauses also prevents alteration in the revenue sharing pattern. Hence, if an investor starts incurring higher costs due to some reason, he/she is left with no remedy as there could be no alteration in the revenue share that is to be received.

Stabilization Clause also absolves government of a lot of responsibilities. It ensures that free hand is provided to the investor to execute the PPP Project. Hence, extra caution needs to be exercised by the investor as in such cases as no laxity or slackness is tolerated by the Host country.

Conclusion

In the present series we understood the meaning of Stabilization Clause and its utility in a PPP Project. We also appreciated the darker features of Stabilization Clause and the negative effects that it could entail upon the implementation and efficiency of the project.

It is the humble opinion of the author that Stabilization Clause is a double edged sword for the investor. The investor derives immense utility from the existence of such a clause. However, imprudent and bad business decisions could lead to a poorly drafted Stabilization Clause in any agreement. Such a situation clearly needs to be avoided by the investor. The investor must conduct a thorough risk analysis before asking for insertion of Stabilization Clause in any BIA.

The wordings of the Stabilization Clause must be customized depending on the needs and circumstances of each PPP. Same goes true for the governments as well. The governments should make sure that by inserting a Stabilization Clause in the agreement, it does not jeopardize its own interests. Unscrupulous investors surely try to take advantage of the Stabilization Clause by interpreting the stabilization clause in such a manner as to ensure maximum profits. The governments must try to create a balance between the public interest involved and the profit generation incentive of the investor.





[1] Howard Mann, Stabilization in Investment Contracts: Rethinking the Context, Reformulating the Result, Investment Treaty News, October 7, 2011 available at http://www.iisd.org/itn/2011/10/07/stabilization-in-investment-contracts-rethinking-the-context-reformulating-the-result/

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