Private Finance Initiative (Pfi) in Malaysia: the Need for and Issues Related to the Public Sector Comparator (Psc)

The Concept of Private Finance Initiative (PFI) or Public Private Partnership (PPP) has been Internationally implemented over the last two decades. In Malaysia, eventhough the involvement of the private sector in assisting with the provision of public services and facilities is not new, only recently under the Ninth Malaysia Plan the government officially announced the implementation of projects using PFI scheme in order to promote greater involvement of the private sector in delivering public services (Ninth Malaysia Plan, 2006). Consequently, a series of PFI projects is now being implemented including some already under construction. However, little is known on the real nature of the Malaysian PFI. One of the aspects considered critical in the implementation of a PFI project is the need for a public sector comparator (PSC) to demonstrate that the project can achieve value for money through comparing the public sector comparator (PSC) with the bid or bids submitted by the private sector. The study being reported herein focuses on the concept of PFI as practiced in Malaysia and the construction of a PSC. Given that under the Malaysian PFI, the PSC is yet to be established there is an urgent need for one to be constructed. In addition, critical issues concerning the transfer of risks and the determination of discount rate are also discussed. The study combines literature review on PFI and interviews with civil servants involved in the implementation of PFI in Malaysia.


INTRODUCTION
The terms of Private Finance Initiative (PFI), Public Private Partnership (PPP) and Privately Procured Infrastructure (PPI) have been increasingly used in many countries. Although different terms are used, the common general concept is about the collaboration between the private and public sectors with the private sector having significant responsible in delivering public services. This policy has been internationally implemented over the last two decades. It offers an alternative to the conventional procurement of public service infrastructure and services.
For a typical PFI/PPP scheme there are several unique characteristics such as: i. Service focus -the main difference is in the change from considering buildings and infrastructure as 'assets' to 'services' provided by the private sector; ii. . Ownership -the buildir gs are typically owned by the private sector during the period o f the contract and leased back to the public sector client; iii. .Risk transfer -some of the risk associated with the project must be transferred to the private sector. The determining factor o f risk transfer is to transfer risk to the party who could best manage it; iv. Innovation -an output specification is used in which public sector clients specify their requirements in terms o f the services required. Then, it is up to the private sector bidder to come up with a design that meets the public sector client's requirements. Thus, it gives greater flexibility to the private sector provider to adopt innovation which leads to value for money (VFM) optimization; v. Performance -the payment to the private consortium is based on the extent that the required service is delivered and the client's standard performance requirements are met (Ball et al. 2001 andTurner &Townsend Management Solutions 2002).
In Malaysia, eventhough the involvement o f the private sector in assisting with the provision o f public services and facilities is not new, only recently under the N inth Malaysia Plan the government has officially announced the implementation o f projects using PFI scheme in order to promote greater involvement o f the private sector in delivering public services (Ninth Malaysia Plan 2006). Even though the first PFI project is now under construction, little information is publicly available on the true nature o f PFI in Malaysia. This study therefore aims at exploring the concept o f Malaysian PFI by conducting in-depth interviews with the relevant officers who are involved in executing PFI projects.
The principal aim for implementing PFI is to provide an improved form o f public procurement which under right circumstances could yield improved efficiency savings and greater value for money than traditional procurement (Robinson 2000).
In other words, for a project to go ahead with a PFI option, it needs to demonstrate better value for money when comparing the private sector bids with a detailed public sector comparator (PSC) (Treasury Taskforce 1997). In assessing VFM o f a project, PSC is one o f the crucial elements to be considered. From Malaysian context, even though the government acknowledges the importance o f VFM assessment in implementing PFI projects, a robust PSC framework is yet to be established (Ninth Malaysia Plan 2006). Realizing the significance o f having a valid PSC to accurately assess VFM, this study also attempts to develop an appropriate framework o f PSC that suits the Malaysian environment. However, at this very initial stage the study only focuses on the principle components of PSC models for PFI projects established in different countries particularly the UK, Australia, and Canada. The information was obtained through a thorough review the official documents on PSC construction o f these countries.
This paper is structured as follows. Section 2 discusses the concept o f private finance initiative (PFI) in Malaysia. Section 3 offers information on the public sector comparator such as its definition, importance and also brief o f comparison PSC's components between countries. Then, the following section (Section 4) discusses the controversial issues concerning the construction of a PSC. A special reference was made to the situation experienced by the United Kingdom. Finally, Section 5 summarizes and concludes the findings o f this study.

THE PRIVATE FINANCE INITIATIVE IN MALAYSIA
PFI is an essential economic policy that has been globally adopted as it is the current trend towards greater private sector involvement in the management, delivery and financing of public services (Dixon et al. 2005). It is a means c f using private finance and skills to provide public services which were traditionally provided by the public sector. In the purest form o f PFI contract the private sector is responsible for designing, building, financing and operating facilities based on output specifications determined by the public sector. In effect, the public sector does not own the assets but has the obligation to make reguiar payments to the private sector providers for the use o f facilities throughout the contract period o f normally 25 to 30 years (Heald 1997;Hall 1998 andLaughlin 1999).
The involvement of the private sector in delivering public facilities and services is not new in Malaysia. It existed since mid 1980s as a result o f the adverse impact o f the world economic recession that caused government to seek assistance from private sector for the development and economic activities o f the country. Malaysian incorporated and privatization are among the economic policies introduced to foster the involvement o f the private sector.
Privatization is one of a vital component of the government's economic policies which aims at reducing the government's administrative and financial burdens. The M alaysian government officially embarked on privatization in 1983. The policy was aimed at fostering greater involvement o f the private sector in delivering public sector projects. Generally, privatization has been defined as the transfer o f enterprise ownership from the public to the private sector. Kay et al. (1986, 2) identified three interrelated policies under the umbrella o f the privatization program. These include: 1. Denationalization: the sale o f the public assets to the private sector; 2. Liberalisation or deregulation -the opening o f the state activities to private sector competition and 3) contracting-out or franchising -the contracting out of public provision to private firm. From the Malaysian context, the scope o f privatization is even broader (Jomo and Syn 2003). The various modes o f privatization applied in Malaysia include i) sale o f equity; ii) sale of assets; iii) lease of assets; iv) management contract; v) Built-Operate-Transfer (BOT) and vii) management buy-out (Economic Planning Unit 2006).
The government reported positive outcomes from privatization policy in helping the government to reduce financial and administrative burden and also to improve efficiency in the provision o f public services (Jomo and Syn 2003;and Siddiquee 2006). It was reported in the Eight Malaysia Plan that more than RM28 billion o f the government's capital expenditure was saved as a result o f privatization (Eight Malaysia Plan 2001).
Subsequently, in strengthening the role of the private sector as the engine o f growth, the Private Finance Initiative (PFI) scheme was unveiled in Malaysia under the recent Ninth Malaysia Plan (9MP). The PFI is formally defined in the Ninth Malaysia Plan report (2006) as:

'the transfer to the p riv a te secto r the responsibility to finan ce and manage a pa ck a g e o f capital investm ent and services including the construction, management, maintenance, refurbishment and replacem ent o f the pu b lic sector assets which creates a sta n d alone business. The p riv a te secto r w ill create the a sset an d deliver a service to the pu blic sector client. In return, the p riva te sector w ill receive paym en t com m ensurate with the levels, quality a n d tim eliness o f the service provision throughout the concession p erio d ' (Ninth M alaysia Plan, 2006)
In brief, under the PFI project, the private sector funds and builds the asset, while it is the obligation on the part o f the government is to purchase a flow o f services over time rather than the capital asset that provides the services.
The principal objective for embarking on PFI in Malaysia is to revise and to improve on the implementation process o f the existing privatization policy (Ninth Malaysia Plan 2006). As tabled in the 9MP, the PFI will be employed for infrastructure and services development projects in two situations. First, PFI will be utilized if it could make government projects more efficient, where risks and rewards are optimally shared between the government and the private sector. Secondly, PFI is to be used where government support enhances the viability o f the private sector projects in strategic or promoted areas (Ninth Malaysia Plan 2006).
In a speech by the Second Finance Minister, Tan Sri Nor Mohamed Yakcop at the Private Finance Initiative Seminar which was held on the 10th November 2006, he said that:

'..in the M alaysian context, w e view PFI in the broadest o f terms, as capturing a w ide spectrum o f options that lie between the tw o extremes o f priva tiza tio n s an d governm ent project
From the interviews with the government officials conducted by the researcher, it is understood that there are two formats o f PFI schemes in Malaysia. This similar information has also been announced by the Prime Minister o f Malaysia, Datuk Seri Abdullah Ahmad Badawi and was reported in the local news paper (The Star Online, 20th July 2006).
In the first format, the private sector would construct the asset or building and leases it to the government for a specified fixed period o f time. A special purpose vehicle (SPV) named PFI Sdn. Bhd. has been set up to take on the responsibility for implementing the PFI projects using this format. This SPV is wholly owned subsidiary o f the Ministry of Finance. The PFI Sdn. Bhd. is accountable for executing government's identified projects. Essentially, the projects are mainly the initial 425 projects that worth RM20 billion which have been identified by the government to be delivered via this format o f PFI under the 9MP.
In terms o f finance, the Employees Provident Fund (EPF) has been required by the government to provide loan to the SPV. The SPV (i.e. PFI Sdn. Bhd) will utilize this allocation from EPF to finance the selected contractors for the construction o f the assets. Once the assets have been built and ready for operation, the SPV will lease the assets to the Federal Land Commissioner (FLC) which acts as a middle man between the ministry which has requested for the project and the SPV. In return, the relevant ministry (i.e. the government) will pay lease charges to the SPV through the Federal Land Commissioner. Throughout the contract the SPV will own the assets and will service the loans given by the EPF. After the expiry o f the contract periods, the assets will be transferred to the government at no cost.
During the interviews the researchers were informed that in contrast to the first format, the second format requires the private sector to identify the projects that are deemed to be economically viable and would benefit the public to be executed via PFI schemes. Under this format the private sector concession is fully responsible for designing, building, financing and operating the public service facilities. In fact, this format o f PFI is similar to the purest form o f PFI that was predominated in the UK since 1992. An example of project carried out using this form is the Second Penang Bridge project which has been awarded to UEM Group. The 24 km bridge which will connect Batu Kawan in Seberang Perai and Batu Maung on the island with an estimated cost of RM2.8 billion is currently under construction (The Star Online, 3 August 2006). The bullet train between Kuala Lumpur and Singapore project which is currently under government consideration is another example o f project o f this PFI format.
Overall, PFI in Malaysia is a new and unique mechanism unlike other concessions that have been used in the past. As it is still at the early stage o f PFI implementation, a constant review and revision to the current PFI arrangement in should be welcomed to improve the government's approach to PFI in achieving the objective o f introducing the best o f private sector s'cills and practices to contribute to a higher sustainable level o f development and economic growth o f the country. Also, the government should seek advice from PFI experts both locally or internationally on the critical aspects o f PFI implementation that are still lacking such as the proper procurement procedures and the construction o f public sector comparator that is crucial for the assessment o f value for money o f PFI projects since. As Malaysia is yet to develop a PSC, the following section provides information about PSC together with a brief analysis on the comparison o f PSC between three countries (i.e. United Kingdom, Australia and British Columbia). Also, debatable issues on the reliability o f PSC are discussed in the subsequent section.

THE PUBLIC SECTOR COMPARATOR (PSC)
A PSC is defined as 'a hypothetical risk-adjusted costing, by the public sector as a supplier, to an output specification produced as part o f a PFI procurement exercise'. It is expressed in present value terms and is based on the recent actual public sector method o f providing the defined output which invoives the estimation o f the construction costs, running costs and more crucially the value o f risk to be transferred to the private sector (HM Treasury 1999).
The objective o f a PSC is to promote full cost pricing at an early stage in the procurement process. Also, it acts as a benchmark and evaluation tool in ensuring efficiency o f the procurement process. A PSC is required for the assessment o f the value for money (VFM) o f a PFI project. A project needs to prove as providing better before it can be delivered via PFI. VFM is assessed by comparing the costs o f the proposed PFI project against a public sector comparator (PSC). A project is considered to provide good VFM if the net present value o f the PFI bid is lower than the PSC. This is why PSC is needed. This importance o f PSC is pointed out by Jeremy Coleman, the Auditor General o f the UK National Audit Office (NAO). He states that:

'The Public Sector Com parator (PSC) is a key p a rt o f the finan cial evaluation o f p ro p o sed PFI project. The PSC is an im portant guide to ju dgm en t o f the overall VFM o f a PFI p r o je c t.' (H M Treasury, 1999).
More importantly, the derivation o f PSC is complex because it takes into consideration the qualitative factors such as risks involved and types and quality o f services provided rather than concentrating only on the quantitative factors (Treasury Taskforce  In other words, in seeking for a more analytically rigorous VFM appraisal mechanism, VFM should not be considered as a pass or fail test before all other non-quantifiable factors which involve both the benefits and costs o f the option have been taken into account (Treasury Taskforce 1999). A study on PFI VFM assessment by Mumford (1998) identified six sources o f cost saving that could be achieved from PFI contracts as compared to conventional procurement projects which might help to achieve VFM. These include: i. clearer definition and specification o f user needs; ii. more careful lifetime design and costing by the constructor; iii. speedier construction and commissioning; iv. More effective monitoring o f contracts; v. incentives that better align effort with risk and rewards; and vi. decision making that better exploits asset compatibility. Moreover, the study by Arthur Andersen and Enterprise LSE (2000: 18-19) which was commissioned by Treasury Taskforce identified six key drivers to VFM as follow: risk transfer, output based specification, long term nature of contract, performance measurement and incentives, competition and private sector management skills.
Despite the need to consider the qualitative factors, PSC remains crucial in undertaking VFM assessment. In Malaysia, the PSC is yet to be constructed. This was acknowledged in the Ninth Malaysia Plan report as follows:

"As the evaluation an d procurem ent p ro cess involved in im plementing PFI w ill b e more elaborate, particu larly the n eed to be clear about output specifications, maintenance, perform ance indicators and distribution o f risks, an ejfective enabling fram ew ork f o r im plem entation w ill be developed. In this regard, steps w ill be undertaken to establish the p u b lic sector com parator in evaluating the p roposals an d determ ining the value Jor money as com pared to the conventional approach" (Ninth M alaysian Plan, 2006: 230)
When constructing a PSC for Malaysian PFI project, the government should consider incorporating both the quantitative and qualitative factors so that a more reliable VFM appraisal outcome is obtained. In contributing towards the process o f establishing a model o f PSC for PFI projects in Malaysia, this paper briefly analyses the key components o f a PSC with reference to the PSC established other countries particularly in the UK, Canada, and Australia.
A comprehensive review o f relevant documents on PSC development in the UK, Australia and Canada revealed that there are three common core components o f a PSC. These include base costing, transferred risk and retained risk as indicated in Figure 1. For the PSC in Australia, competitive neutrality is explicitly considered as another key component. Competitive neutrality adjustments remove any net competitive advantages that accrue to a government business by virtue o f its public ownership. This is to allow a fair and equitable assessment between a PSC and PFI private bidders (PPP Victoria 2001). Examples of competitive neutrality adjustments are insurance costs for assets and services that are typically not insured by a public sector entity as it was deemed from a risk management perspective to self insure the facilities. For PSC in Canada, this is called hidden or assumed cost and considered as part o f an indirect cost element o f the base costing.
Based costing is the estimation o f the basic procurement costs which covers capital costs and operating costs. Capital costs are costs needed to construct or build the facility. These include costs incurred for the design, construction, purchase of land, material, and plant and equipment. Basically, capital cost represents a huge On the other hand, operating costs are the costs o f providing the services specified in the procurement over the contract period. These include full staff costs, raw materials and consumables, repairs and maintenance and administrative overheads. As the effect o f inflation throughout the contract period may be significant, all costs should be expressed in the prices o f the base year o f the comparison (the effects o f expected future inflation should be excluded).
Another crucial but controversial component o f a PSC is the risk element. Gallimore et al. (1997) state that the distinction between reality and possibility is an essential element o f risk. More specifically, from a financial perspective, risk is taken to be the variance of returns around the expected return (Gallimore et al., 1997). Pollock and Vickers (2000) argue that risks play a major role in determining the VFM o f a PFI project. Froud (2003) h is a similar view on the importance o f risk in verifying the VFM achieved from PFI. Besides, he also points out the significance of risk in the accounting treatment o f PFI projects.
There are seven principal risks relevant to PFI being identified by the Treasury Taskforce (1997: para. 3.21) in their publication, 'Partnership for Prosperity Design and construction risk; commission and operating risk; demand for volume/ usage risk; residual value risk; technology/obsolescence risk and regulation and legislation risk. These risks were also commented on in the Private Finance Panel publication (1996), ' 'Risk and Reward in PFI Contracts'. For each type o f risks, there are three possible choices to be made: i) To be retained by the public sector; ii) To be transferred to the private sector; and iii) To be shared between the two sectors.
The underlying principle behind the distribution o f risk among various parties under PFI schemes is that the risk should be taken by those most able to control it, and this will result in cost reductions brought about through increases in efficiency and innovations introduced by the private sector (Ball et al. 2000). In other words, a more efficient allocation o f risk between the private and public sector would yield a greater VFM in the provision o f public services (Hall 1998;Bing et al. 2005).
Transferable risks are those that are likely to be transferred to private sector bidders. The type and number o f risk which are to be transferred need to be assessed on a project by project basis. The value o f transferable risk in a PSC measures the cost government would expect to pay for that risk over the term o f the project in a public procurement scenario. Alternatively, retained risks are those risks that are managed more efficiently within the government. For projects where retained risk is included in the PSC, its value will also need to be added to each o f the private bids to allow a meaningful comparis )n.
As PSC is expressed in present value terms, another main issue in developing a PSC, particularly with the VFM valuation is the determination o f the hurdle rate to use for discounting the cash flows (Pollock and Vickers 2000). In other words, once all the components o f the PSC have been added up, they need to be discounted using an acceptable discount rate to reach at the net present costs before comparison with the net present costs o f the private sector can be made. From a review o f the official documents, it was realized that different countries apply different discount rates to work out the present value o f the clash flows. Furthermore, in Australia and Canada, various rates are used for the different sectors o f PFI projects available in their countries. Only the United Kingdom, applies a uniform discount rate across sectors though the rate has been changed from 6 per cent in the past to 3.5 per cent at present. Table 1 below indicates the discount rates use in the UK, Australia, and Canada. Generally, the selection o f the discount rate for the net present cost (NPC) is a subjective issue and it requires an understanding o f the relationship between risk and return. Due to the subjective justifications for selecting an appropriate discount rate, the reliability o f the PSC is always been a subject o f criticism. The key issues regarding the determination of discount rate as well as the transfer o f risks issues are discussed in the next section.

CONTROVERSIAL ISSUES ON PUBLIC SECTOR COMPARATOR
One o f the controversial areas o f a PFI contract lies in the transfer o f risk to the private sector. The process o f risk transfer is central to PFI schemes because a privately financed option is unlikely to represent value for money before risk transfer. This is because as risk is transferred to the private sector, ceteris paribus, the cost o f the transferred risk is added to the PSC (Wynne 2002). This adjustment will cause the PSC value to be relatively more expensive than a privately financed alternative. For example, an evaluation o f the NHS hospitals under PFI scheme by Froud and Shaoul (2001) shows that a greater VFM is achieved when some o f the risks associated with construction o f the hospital and its subsequent management is transferred to the private sector provider. The finding from Arthur Andersen and Enterprise LSE (2000, 53) study also reveals that 60 percent o f the average 'saving' is contributed by the transfer o f risk.
However, the amount o f risk to be transferred is a matter o f ambiguity. This is due to the complexities involved in the valuation o f risk. Risks need to be identified and their impacts on costs need to be assessed. It also requires the estimation o f the probabilities and the re-examination o f the estimates using sensitivity analysis. Moreover, risks should be appropriately allocated between the private and the public sector. An inappropriate risk transfer will reduce the VFM achieved as the party will seek to alleviate the impact o f the risk by charging greater premium (Treasury Taskforce 1999: para. 2.4.9).
According to NAO (1999e: 52), the policy o f risk transfer has shifted from an early recommendation o f 'maximum risk transfer' to an 'optimal risk transfer'. At present, the principle governing risk transfer is that;

'Risk should be a llocated to w hoever is best able to manage it. Although there m ay also be p o lic y reasons to encourage risk transfer, the aim is to achieve optimum risk allocation, not transfer risk f o r its own s a k e '
In practice, risk is not a simple uni-dimentional commodity that can be costlessly assessed and completely transferred to the private sector (Mavston 1999). The relationship between risk and VFM is that as risks are transferred to the private sector, VFM may rise until it reaches the optimum level, where any further risk transfer might cause a fall in the VFM. This is because risk transfer becomes inefficient since the private sector may be unable to absorb risk properly (Forshaw 1999).
A study by Broadbent and Laughlin (1999) argues that there are uncertainties in the issue o f risk transfer. The main qv^ries include the types o f risks involved in the PFI project, the risks that need to be transferred and the characteristics that demonstrate when a risk is actually residing with a particular party. Subsequently, the Treasury Taskforce (1997a: para. 3.23) concluded that; Landers (1996) agrees with the idea and similarly suggests that PFI requires an appropriate transfer o f risk to the private sector, both through the design, planning and construction phases and in operation and also through a combination o f payment mechanisms and specific contract conditions. Wynne (2002) also points out that there are two types o f risk often cited as transferred to the private sector contractor under a PFI project. They are risks related to delay in completing the project and risk o f cost overrun for a project. Nevertheless, according to Mayston (1999) a large part o f the risk which the PFI contract may seek to transfer to the private sector relates to demand risk.

'A s a general rule, PFI schem es should transfer to the p riva te sector risks where the supplier can influence the outcome. The supplier is able to influence the likely perform ance o f the building and its ser\>ices by the quality o f the design, construction and refurbishment work undertaken. The quality and frequ en cy o f maintenance also has an im portant bearing on on-going perform ance. Therefore, risks transferred w ill include design, build, financing an d operating risks
From the perspective o f the IPPR, design and construction risk and operating cost risk should be borne by the private sector. While political risks which involve policy changes should be borne by the public sector. But, certain risks which are difficult to specifically allocate between the parties, such as demand risk and obsolescence risk, need to be appropriately shared among the two parties (IPPR, 2001). Likewise, the research findings by Bing et al. (2005) suggest that the public sector should retain political risks as well as site availability risks. On the other hand, risks which are directly associated with the project itself should be transferred to the private sector. Akintoye et al. (1998) carried out a research project aimed at obtaining feedback from three different groups involved with PFI projects (Public sector (clients), contractors, and lenders) on the issues o f risk burdens and risk analysis and the management o f PFI schemes. The results from their questionnaire survey show that the respondents tend to rank most highly those risk factors that were highly related to their own business objectives. Also, the results show that all the three parties adopt different methods and techniques for risk assessment and approach risks in different ways. However, one thing they have in common is that all parties have insufficient knowledge o f PFI to ensure its success. Similarly, Gallimore et al. (1997) prove that certain risks are differently perceived by participants. They also emphasize that an attempt to measure and expose these differences is a difficult area o f study because it involves the quantification o f data that are frequently qualitative in nature. Froud and Shaoul (2001) and Wynne (2002) point out that even though issues of risk analysis and risk transfer are important in PFI, official guidance on how to calculate the risk transferred is insufficient. Moreover, publicly available evidence is also typically very limited. Their evaluation on a num ber o f FBCs suggests that no valid methodology for risk transfer has been applied. As a result, different business cases use different methodologies to transfer risk.
Recently, a research study carried out by a group o f researchers commissioned by the Association of Chartered Certified Accountants (ACCA) (2004) suggests that even though risk transfer is the central element in justifying VFM, their investigation indicates that risks have not been transferred to the party best able to manage it. The study which evaluates the operational performance of PFI scheme in roads and hospitals also highlights that;

'...rather than transferring risk to the p riv a te sector, in the case o f roads DBFO has created additional costs an d risks to the p u b lic agency, a n d to the p u b lic sector as a whole, through tax concessions that must increase costs to the taxpayer and/or reduce service provision. In the case o f hospitals, PFI has gen era ted extra costs to hospital users, both sta ff an d patients, and to the Treasury through the leakage o f the capital charge elem ent in the NHS budget. In both roads and hospitals these costs an d risks are neither transparent nor quantifiable. This m eans that it is im possible to dem onstrate whether or not VFM has been, or in deed can be, achieved in these or any other pro jects ' (ACCA, 2004).
In short, the process o f attempted risk transfer itself may lead to long and complicated PFI contracts, adding to the evaluation, transactions, negotiation and monitoring costs involved, which can significantly reduce the attractions o f privately financed projects.
The second controversial issue concerning a PSC is the determination of the discount rate for the purpose o f discounting the PSC costs to get the time value o f money o f the costs. In particular, the use of a single rate to discount both public and private sector schemes would mean that the risk of both schemes is equal. Broadbent et al. (2001) highlight that some people argue that this may not be the case. Implicitly, these people assume that the public sector has a lower risk. The analysis by Grout (1997) reveals that the public provision is valued from the cost side that is the present value of the cash flows o f the costs o f the project. Whereas the private provision is from the revenue side; the present value o f the cash flows o f the revenue o f the project. Revenues are generally perceived to be more risky than costs and this implies that the public sector should use a lower discount rate.
In addition, the time profile o f the expenditure incurred by the public sector might differ substantially between the traditional procurement and the PFI. The capital expenditure under traditional procurement is incurred as the investment project is undertaken, whilst under PFI the costs are spread over a 25 to 30 year period. When comparing the PFI against the PSC to determine VFM, the use o f a relatively high discount rate, places more weight on the near future as compared with the more distant future, and this will result in a lower cost for PFI hence a better value for money. On the other hand, a low rate o f discount tends to favour the PSC or the traditional procurement.
As in the case o f the United Kingdom, Wynne (2002) claims that the 6 percent discount rate used since 1992 does not reflect the actual current economic situation. This is because the same rate has been used despite the significant fall in general interest rates over the last few years. There are various arguments that have been put forward with regard to the discount rate issue. Wynne (2002) in his analysis shows that none o f the first 11 PFI schemes in the NHS would be considered to provide VFM if the discount rate used had been changed to 5 percent instead o f the normal rate of 6 per cent. Similarly, Gaffhey et al. (1999) use the case o f Carlisle hospital to prove the sensitivity o f VFM to the discount rate used. Their study indicates that at a 6 percent discount rate, the PFI scheme is slightly cheaper than traditional procurement. However, when the discount rate is reduced by only 0.5 percent, the outcome o f the appraisal is reversed to favour the traditional method o f procurement. In other words, both Gaffhey et al. (1999) and Wynne (2002) demonstrate that small changes in the discount rate applied will vary the outcome as to which scheme offers the best VFM Concerning this discount rate issue, Grout (1997) and Smith (1999) consider whether the use o f more sophisticated models such the Capital Asset Pricing Model or the Arbitrage Pricing Mode! could provide a better basis for deciding appropriate discount rate. Sussex (2001) claims that four per cent discount is a better reflection o f the time preference rate. Subsequently, in January 2003, the Treasury had agreed to reduce the discount rate for the purpose o f economic appraisal to 3.5 percent. However, there are still debates on these issues at present.
In light o f the above critics o f PSC, fundamental lessons should be learned from the experiences o f other countries and serious consideration must be given on the matters concerned when developing a PSC for the PFI projects in Malaysia.

CONCLUSIONS
The introduction o f PFI in Malaysia under the 9MP is the continuation to the existing privatization policy which has been implemented since the early 1980s. As the implementation o f PFI in Malaysia is still at the infancy with only several projects currently under construction or at the evaluation stage, the government should closeiy look into the critical aspects o f PFI that are still lacking such an effective enabling framework and mechanism for procurement and evaluation process. To be specific, a PSC which is a crucial element in VFM appraisal is yet to be established. However, in developing a PSC framework for PFI projects in Malaysia, many factors need to be scrutinized to ensure its suitability to the Malaysian context. Also, a special PFI regulation body is essential to be set up to regulate and monitor the progress o f the scheme.
Moreover, since a PFI approach is required to prove better VFM before it can go ahead, a great reliance will be placed on the technical judgments underpinning the PSC costings. The complexity involved in the development o f the PSC has led to a greater inherent uncertainty and subjectivity associated with aspects o f the PSC estimates (Audit Scotland 2002 andAudit Commission 2003, 34). Wynne (2002) highlighted the value o f risk transferred to the private sector as one o f the key subjective area in developing the PSC. Research by Pollock et al. (2092), Audit Scotland (2002, 68) and Audit Commission (2003 proved that a better VFM of PFI option was only achieved when adjustment for risk transfer has been made. This is because the cost of the risk transferred to the private sector is added to the cost o f the PSC and cause it to be higher. In addition, it was also claimed that the PSC has overestimated the finance cost o f public funding (Audit Commission 2003, 34). Subsequently, the reliability, accuracy and relevance o f the PSC have been the subject o f considerable debate (Audit Commission 2003, 37).