MCC was involved with the early preparations for the RC2 price control, which were due to take effect from 1st January 2023. This involved a review of the multi-year, incentive-based price controls that have been applied to the water, wastewater, recycled water and electricity companies in the Emirate of Abu Dhabi (AADC, ADDC, ADSSC, TRANSCO, and EWEC). ​

MCC reviewed the price control model used in Abu Dhabi to set the Maximum Allowed Revenue (MAR) for electricity and water monopoly network services. Unlike most price controls in the UK, this involved a fixed and variable term for allowable revenues: which was designed to incentivize the growth of electricity and water services in the region.​

MCC’s role was to provide analysis of WACC calculations from previous price controls (RC1), and to guide WACC developments for the upcoming price control (RC2). MCC used both regulators’ benchmarks and bottom-up analysis to generate an anticipated WACC allowance.​

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In 2019, MCC, led by our director PJ McCloskey, delivered a comprehensive and actionable report to Citizens Advice (CA). The report was designed to equip CA and the Challenge Group (CG) with the tools and frameworks necessary to assess energy network companies’ business plans effectively for the RIIO-2 price controls.

Our contributions included:

1. Key Information Identification:
   PJ outlined six main categories of information that CA and CG should focus on when reviewing business plans, ensuring the evaluation process was thorough and aligned with regulatory objectives. These categories included:
   • Stakeholder Engagement
   • Finance Issues
   • Expenditure Bids
   • Outcomes
   • Customer Charges
   • Governance
2. Assessment Methodology Development:
   PJ conducted a detailed review of assessment techniques used in prior regulatory frameworks, including RIIO-1 and PR19, and identified lessons learned to inform the RIIO-2 process.
3. Traffic-Light Scorecard Approach:
   PJ recommended a practical, user-friendly assessment method in the form of a traffic-light scorecard. This approach allowed CA and CG to visually and systematically evaluate key aspects of business plans.
4. Guidance and Tools:
   The report provided a comprehensive list of questions for network companies, enabling CA and CG to extract the necessary information for informed evaluations. Additionally, PJ provided tailored recommendations on scoring and prioritisation to ensure alignment with regulatory expectations and consumer interests.

This work provided Citizens Advice with a structured framework to advocate for transparency, fairness, and accountability in energy network business planning, ultimately safeguarding consumer interests in the regulatory process.

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In 2022, MCC provided comprehensive support to the Civil Aviation Authority (CAA) in developing and refining their finance policy decisions for the H7 Heathrow Airport Price Controls. This included an in-depth analysis of regulatory precedents, financial policies, and market dynamics to ensure the CAA’s decisions were grounded in robust evidence and best practices.

Key aspects of our work included:

• Policy Development Support: We assisted the CAA in crafting finance policy frameworks for the H7 Price Controls, ensuring alignment with regulatory expectations and addressing key stakeholder concerns.
• Regulatory Precedent Analysis: Our team conducted a detailed review of prior appeals, including the CMA’s RIIO-2 network appeals from 2021 and the water sector PR19 redeterminations in 2020. This helped identify relevant precedents and anticipate areas of potential scrutiny in future appeals.
• Expert Witness Contributions: We leveraged the expertise of our director, Mr. PJ McCloskey, whose prior witness statements were extensively cited in the CMA’s Energy Licence Appeal Final Decision. This allowed us to provide authoritative insights and prepare the CAA for potential appeals.
• Appeals Preparedness: In anticipation of challenges to the H7 decisions, we supported the CAA by identifying issues likely to be appealed and developing counterarguments grounded in financial and regulatory analysis.

Our preparatory work proved instrumental during the subsequent 2023 CMA appeals by Heathrow, British Airways plc, Delta Air Lines Inc., and Virgin Atlantic Airways Ltd., positioning the CAA to navigate these challenges effectively.

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MCC assisted the Consumer Council for Water (UK) by peer reviewing Ofwat’s indicative WACC for the PR24 price control.​ This work included extensive analysis of Ofwat’s historical WACC allowances, positions, and decisions. MCC also took into consideration approaches by other regulators (e.g. Ofgem, CMA) and best practice guidance.​

To provide a robust evaluation, MCC undertook an in-depth examination of each WACC parameter, focusing on critical elements such as:

- Cost of equity

- Cost of debt

- Financing and gearing

- Risk-free rate

- Total market return

- Equity beta

In addition, we reviewed Ofwat’s financial models, such as their balance sheet cost of debt model, and built alternative and complementary models to enhance our analysis and provide additional perspectives. The insights from this work were compiled into a detailed final report, which has been published online (May 2023).

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Our Approach and Methodology

1. Structured Thematic Coding

MCC developed a comprehensive coding framework to categorise over 50 responses from varied sectors, ensuring analytical consistency and uncovering common themes across data points.

2. Evidence Strength and Quality Assessment

Each submission was systematically reviewed for relevance, depth, and credibility. MCC applied a three-dimensional framework assessing evidence type, source robustness, and alignment with key policy questions.

3. Integration of Multi-Channel Data

Responses were consolidated from both CCC’s online portal and email submissions, ensuring no data was excluded. This created a single, centralised dataset - the foundation for a transparent and replicable analysis process.

4. Identification of Market Gaps

MCC’s analysis uncovered significant data and governance gaps - including a lack of price transparency, inconsistent credit registries, and limited visibility into project ownership and quality assurance.
These findings directly supported CCC’s recognition of the need for stronger market integrity and regulatory frameworks.

5. Comparative Market Insights: UK vs Global

The report contrasted the UK’s emerging voluntary carbon market with established international systems (e.g., Verra, Gold Standard, REDD+). It identified differences in standards, monitoring rigor, and land-use implications - particularly in peatland versus forestry-based offsets.

6. Policy-Aligned Reporting

MCC delivered structured summaries addressing 13 questions across topics such as:

• Market regulation and standardisation
• Harnessing private finance for climate goals
• Corporate transparency and offset credibility
• Integration with Article 6 of the Paris Agreement

Each summary provided balanced, evidence-based insights to support CCC’s policymaking and communication efforts.

7. Balanced View of Risks and Opportunities

MCC identified both market vulnerabilities, such as greenwashing, double counting, and weak monitoring and emerging opportunities, including private finance mobilisation, biodiversity enhancement, and scalable net-zero solutions.

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Results Delivered

✅ Comprehensive stakeholder analysis across 56 respondents
✅ Transparent, replicable analytical framework for consultation evidence
✅ Identification of data gaps and policy-relevant insights
✅ Publication of findings in CCC’s official report
✅ Contribution to the UK’s evolving carbon offset governance approach

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For the past two years, we helped this regulator with their regulation of district cooling, with a focus on the economic clauses. This involved analysis of financial and levelised cost models submitted by three district cooling service providers (PAL Cooling; Tabreed; and Manazel).​

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For this engagement, our team:​

• used district cooling benchmarks, for capex, opex and the cost of capital, to assess the efficiency of ~30 district cooling plants in Abu Dhabi;​
• calculated the Internal Rate of Return (IRR) for the concession period and compares it with the WACC benchmark at the date of construction;​
• reviewed charge structures and escalation rates;​
• compared the levelised costs of conventional cooling with the levelised costs of district cooling, to advise whether customers are getting a good deal from their DC provider.​

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