主講人：台灣智慧城市發展協會理事長 林建元先生

1. PPP的哀愁與美麗
林建元 逢甲大學建設學院講座教授
周慧瑜 朝陽大學營建管理系副教授
張倩瑜 英國倫敦大學學院教授
2017/06/20

2. PPP的哀愁
• 大家都說 PPP很重要
• BUT，在台灣從事PPP的相關部門，
除了學術研究以外，幾乎都很不快
樂。
•Why?

3. 台灣推動PPP法令政策面
之關鍵課題

4. 台灣促參模式的理論與現實
• BOT模式的經濟誘因機制設計：
– 作用：使民間機構為求長期獲利穩定甚至成長，願意長期維持興建及營運品質。
服務
品質
硬體
品質
營運
收入
公
設
共
施
事業者
特許廠商/民間機構
依業主要求之設施
規格完成公共建設
之興建及營運
獲特許權營運該
項公共設施並以
此回收投資成本
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5. 台灣促參模式的理論與現實
Q：誘因機制有效嗎?
長期合約之下：
 設施會老舊…
 服務型態會過時…
 市場需求會變化…
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6. 台灣促參模式的理論與現實
A：先決條件有二
1.經營主軸能夠長期維持於主體設施上!
2.主體設施之營運收入對專案整體獲利具
有關鍵性影響!
Q：這是國內促參專案的共同特性嗎?
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7. WHAT IS THE ”PUBLIC” IN PPP?
7
遊戲規則
的制定者
與管理者
公共服務
供給產業
的驅動者
與扶植者
公共服務
的供給者
兼需求者
 政府能否積極
創造供PPP多
元健全發展的
制度環境?
 政府是否有能
力建立公平、
合理、互惠、
穩定且能創造
相同利益目標
的契約條件?
 政府在促參專
案中能否堅守
契約精神? 還
是常被挾持而
失去治理力量
或承擔原本責
任歸屬於民間
機構的風險?
 全生命週期整合
型服務在國內有
足以引導廠商上
下游整合的需求
市場規模嗎?
 不是防弊vs.興業
誰重要的問題，
PPP目的在創造相
同利益目標與利
害關係的正向循
環。
 公共服務效能的維繫與革新，必
須憑藉公共設施品質的與時俱進。
 公共服務的供給模式可以更多元，
政府與民間的角色互補關係可以
更彈性。

8. PPP制度與市場是否完善之關鍵因素
1.政治穩定、
支持與誠信度
2.對公共設施
更新的計畫性
7.專案資訊紀
錄與績效追蹤
3.市場投資機
會的長期規劃
6.報酬連結績
效與社會影響
5.融資來源的
多元管道發展
4.長期專案融
資市場健全度
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9. 台灣推動PPP於法令政策面
之關鍵課題
1.民間參與模式漸趨多元、彈性是世界各國的共通趨勢，不僅需因地制宜、因時
制宜，還需各自擁有完整的法令規範。
– 國內促參法仍以特許權系統(Concessionaire model)為主
– 在世界各國屬應用大宗的Availability style model(英國系統稱PFI)長期缺乏完整
法源依據及支援體系(例如長期預算、長期契約承諾、成效式契約環境)
• 從公共預算融資來源創新的角度：
– 善用民間資金使政府得以突破財源壓力，將公共建設與服務之投資提前，也提前了經
濟發展環境的改善進程。
• 從公共服務革新的角度：
– 社會對基礎建設與公共服務的需求日益急迫。
– 公益性高、自償性不足的公共建設與服務，特許權模式適用性不足。
– PFI的重要精神，是將公共服務的供給形式與過程，給予民間廠商高度的自主發揮空
間，但也同時要求民間廠商必須自行承擔績效責任，以有效善用民間廠商之管理與創
新能力，改善公共建設專案的風險管理成效。
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10. 台灣推動PPP於法令政策面
之關鍵課題
2.國內須徹底檢視並排除執業管制與採購/促參系統所形成對產業跨業及上下游
整合的阻礙。
– 世界趨勢：
• 長期以來大型基礎建設專案之國際競標乃至於一帶一路的發展趨勢均顯示出：不具有全生
命週期整合執行能力者，便不具有競爭優勢。
• 由世界各國的經驗可得知，PPP之推動會促使民間廠商為提高專案執行成本效益，或基於
市場競爭優勢的培養而逐漸跨業並向上下游整合業務範疇。
– 國內現況：
• 公共設施多有「重新建、輕維護」心態；
• 公共建設上下游執行者長期處於分業執業狀態；
• 營建產業絕大多數屬中小企業；
• 公共工程低利潤、高風險；
• 廠商難投入管理系統化、人才培訓、技術研發，傳統產業色彩明顯。
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11. 台灣推動PPP於法令政策面
之關鍵課題
3. 「融資」是PPP的核心動能開關，國內需成立提供PPP專案融資來源的開發基金(for初期調研及
招商)及專責單位(ex.PPP融資中心)。
– 台灣推動促參迄今超過20年(含高鐵的獎參時期)，專案融資卻仍未能名實相符，有時政府預算可
得性也會成為促參案能否推動的限制條件。
– 亞洲開發銀行建議各成員國建立一個專案開發基金(PDF)
– 印度經驗案例：
• 成立有印度基礎建設專案開始基金(IIIPDF, India Infrastructure Development Fund)
• 最高可墊借整個開發費用的75%
– 印尼經驗案例：
• 也在亞洲開發銀行的協助下成立了基礎建設專案開發基金(PDF)，功能如同印度。
– 英國經驗案例：
• 2008年全球金融危機爆發，執行中之PFI專案多出現資金短缺問題，招標專案也常因融資困難而流標。
• 2009年3月，財政部緊急成立基礎設施金融小組(Infrastructure Finance Unit)，協助或直接提供PFI專案
融資。
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12. 從OBOR看見PPP的美麗
• What is OBOR and what is it for
• OBOR’s role in infrastructure development
– What infrastructure
– Who will build it
– Who will finance it
• Opportunities for collaboration
• Risks and challenges
• OBOR and High Speed Rail
• OBOR and Ports
• Update on OBOR in Europe

13. BACKGROUND TO OBOR
• China is now using its vast financial resources to acquire and
finance assets in the global market
• One of the main features of OBOR is its goal of using Chinese
finance to create demand for Chinese goods and services abroad
– Not only the services and goods require to build infrastructure
– Also about stimulating demand for Chinese imports
• OBOR’s (officially stated) central goal:
To connect China's economy to the developed economies of Europe
and virtually every country in between via a series of inter-related
economic corridors, involving:
the development of new infrastructure
removal of barriers to trade and investment
increased integration of financial systems; and
cultural and academic exchanges

14. WHERE IS OBOR

15. OBOR & INFRASTRUCTURE
DEVELOPMENT
• The part of OBOR of most interest to us is the development and
financing of new infrastructure
• More than 60 countries are located on one or other of these routes,
together accounting for over 60% of the world's population and
29% of global GDP.
• Many if not most of these countries suffer from severe infrastructure
deficits, so there is demand
• CDB (China Development Bank) estimates that over 900
infrastructure projects will be pursued under the OBOR banner,
involving investment of over US$890 billion.
• However there is no official list of OBOR infrastructure projects

16. OBOR & INFRASTRUCTURE
DEVELOPMENT
Who is in charge of OBOR?
• Several bodies appear to be involved, with no one government
department being given overall responsibility for policy or
implementation:
– The National Development and Reform Commission
(NDRC);
– Ministry of Foreign Affairs (MOFA);
– Ministry of Commerce (MOFCOM);
– China Development Bank (CDB); and
– China Export-Import Bank (China Exim Bank)
• Each body has made its own announcements to date, with the
only coordinated release being the OBOR implementation guide
released by the NDRC in March 2015.

17. OBOR & INFRASTRUCTURE
DEVELOPMENT
Who proposes OBOR projects?
– Some OBOR projects were mooted before OBOR was official policy
• China-Laos Railway
– Some projects are part of the destination country’s own infrastructure
development plans
– Some projects are undoubtedly proposed by the Chinese side directly to
the destination country’s government
• China’s SOEs likely to be involved in doing their own analysis of
OBOR countries’ infrastructure needs and proposing projects
• Can be difficulties when local stakeholders aren’t consulted
– E.g. recent news of the Chinese and Sri Lankan governments
agreeing to build an LNG power plant
– Ceylon Electricity Board was not fully consulted and has raised
objections as they have their own plans for electricity generation,
which do not include an LNG IPP (with take or pay obligations
which would need to be budgeted for)

18. OBOR & INFRASTRUCTURE
DEVELOPMENT
Who will build the infrastructure?
• Given:
– the objective of stimulating demand for Chinese goods and
services;
– Chinese funds being the major source of investment in many
OBOR projects; and
– the large number of experienced and competitive Chinese
contractors in the market,
it is likely that such Chinese contractors will be the preferred
choice for the main contractor role when it comes to the building
out of OBOR infrastructure projects.
• Foreign participant roles likely to be:
– as joint venture partners where the technological difficulty or
scale of a project means that Chinese contractors cannot do it
alone; and
– acting as specialist subcontractors and suppliers to the Chinese

19. OBOR & INFRASTRUCTURE
DEVELOPMENT
Who Will Finance the Infrastructure?
• OBOR is primarily to be financed by loans, not development aid.
• Given the scale of OBOR, the amount of finance required will be
extremely large.
• A combination of domestic banks following Beijing's instructions and
multilateral development institutions operating within their own
frameworks will work together to deliver OBOR.
• Chinese export credit agencies:
– China Development Bank:
• original mandate was to finance nationally important infra
projects
• now a major provider of loans to foreign projects and asset
acquisitions by Chinese entities (non-concessional basis)
• Sovereign credit rating

20. OBOR & INFRASTRUCTURE
DEVELOPMENT
– China Import-Export Bank:
• Exclusive provider of Chinese government concessional loans:
– Government-to-government concessional loans
implemented by EXIM
– Preferential export buyer’s credit to employers/purchasers
• Export credits (mostly seller’s credit, but also buyer’s credit) and
import credits
• Credit insurance and guarantees
• Sovereign credit rating

21. OBOR & INFRASTRUCTURE
DEVELOPMENT
– Sinosure
• Provides export credit insurance for Chinese lenders
(including CDB, China Exim and commercial lenders), rather
than export credits themselves
• Mostly short term export credit
• Covers buyer’s credit (majority), seller’s credit and
refinancing insurance
• “Big Four” commercial banks also all provide infrastructure loans on
ECA terms (i.e. subject to Sinosure credit insurance):
– Bank of China
– Agricultural Bank
– Construction Bank
– Industrial and Commercial Bank

22. OBOR & INFRASTRUCTURE
DEVELOPMENT
• Silk Road Fund
– Set up by China in 2014 specifically for the purpose of investing in
countries along the OBOR routes, with a focus on infrastructure.
– To be run like a private equity firm. Currently capitalised in the
amount of US$40bn, open to investors from all nations but majority
of its funding to date has come from China's state-owned
investment entities
– Already active, has invested in:
• Karot Hydropower Dam in Pakistan (took equity in a Chinese
investor)
• Yamal LNG project in Siberian Russia (9.9% equity stake)
• Partnering with ACWA to invest in thermal power stations

23. OBOR & INFRASTRUCTURE
DEVELOPMENT
• China Investment Corporation (CIC):
– China's US$200bn sovereign wealth fund CIC has created a new subsidiary,
CIC Capital, specifically to invest in overseas infrastructure and agricultural
projects involving Chinese companies
– Expected to play a part in financing OBOR projects (equity)
– Seeking a listing, but post-Brexit it is probably going to list on a European
exchange, not London
– Investments include in Kumport, Turkey’s 3rd largest container port, and
acquisition of a portfolio of French and Belgian shopping malls
• Other Chinese banks have also announced their own plans to gear up for OBOR
financings:
– Bank of China issued a US$4bn multi-currency bond for the explicit purpose of
OBOR projects
– CITIC Group announced a huge commitment of US$155bn for certain OBOR
projects plus a RMB20bn OBOR fund

24. OBOR & INFRASTRUCTURE
DEVELOPMENT
• China Insurance Investment Ltd
– US$6bn fund set up by over 46 Chinese insurance companies, asset
managers and private companies to fund energy and infrastructure
projects
– Reported to be committed to funding CMHI's port investment projects in
Sri Lanka, Turkey and Djibouti (as well as Yamal LNG)
• China Everbright
– Large state-owned conglomerate operating in the environmental
protection industry (also owns a bank) – waste to energy, waste water
processing, water treatment, solar pv, wind power
– Set up a specialist European infrastructure M&A fund
– Will focus on port terminals and airports for the purpose of trans-
shipment of Chinese goods.
• Already acquired the franchise to run in Tirana Airport, Albania, via
a majority stake in a JV with a Hong Kong airport/aircraft investor

25. OBOR & INFRASTRUCTURE
DEVELOPMENT
• Asian Infrastructure Investment Bank ("AIIB"):
– Formally established in June 2015 as a multilateral investment bank to be lead by China
and co-invested by 57 other countries (25 more applying).
– Has an initial capital of US$100bn and will focus on infrastructure investments across the
Asia-Pacific region, likely to mean that many OBOR projects are amongst its investments.
– 1 year in: 9 projects on the books, 6 are co-financings with one or more of IFC, WB, ADB
or EBRD
– Recently confirmed that it will not be investing in new coal mines or power stations
• The BRICS New Development Bank
– Created in 2014 by Brazil, Russia, India, China and South Africa in order to create a fund
for new infrastructure investment and sustainable development in developing countries
(who are members)
– Will have a total capital of US$100bn when all contributions are made
– HQ in Shanghai, issued a RMB 3bn bond in China last year
– Self-styled as a “sustainable infrastructure bank”, first investments have all been in clean
energy projects (total 1500MW)
– Will be lending to projects in Russia soon (IMF, WB etc will not do that)

26. OBOR & INFRASTRUCTURE
DEVELOPMENT
Typical Chinese infrastructure finance methods
• Buyer’s Credit
– Chinese bank lends the money directly to a local entity/government
body to finance an infrastructure project on ECA terms
– Chinese contractor taking on the EPC contract is a condition of finance
– Money may not actually leave China, often have direct payment
arrangements where:
• Contractor applies to Employer for payment (monthly or milestone
basis)
• Employer certifies payment
• Contractor takes certification to bank in China and obtains money
– Usually involves a guarantee provided by the local government body to
the Chinese bank

27. OBOR & INFRASTRUCTURE
DEVELOPMENT
• Seller’s Credit:
– The EPC contractor (borrower) receives the loan from the Chinese
bank and uses this to finance the works
– Loan usually on ECA terms (insured or guaranteed by ECA)
– The EPC contract contains some form of deferred payment
arrangement where the employer doesn’t pay all/some of the price
until sometime after completion has been achieved
– Employer will need to provide some form of payment guarantee to
provide security to the borrower
– The borrower will need to provide a guarantee to the Chinese bank
to repay the seller’s credit loan

28. OBOR & INFRASTRUCTURE
DEVELOPMENT
• Contractor finance
– EPC contract contains deferred payment arrangements and a payment
guarantee from the employer to pay after completion
– EPC contractor obtains its own finance on non-ECA terms
• Could be “factoring”: selling the right to receive payments under the
EPC contract from the employer at a discount to fund construction
• Employer certifies payment application, EPC contractor sends to
factoring bank, factoring bank pays a proportion of the value to EPC
contractor
• EPC contractor repays factoring bank after employer pays the
contract price following completion
– Not particularly common as the risk for the factoring bank is quite high
• How do additional payments due to EPC contractor get funded?
• What effect will delays to the works have on the factoring
arrangements? Fixed repayment date, or extendable?

29. THAR BLOCK II
• The Thar II project is a particularly
important project in the Belt and Road
Initiative context:
• A major project in the China Pakistan
Economic Corridor (“CPEC”), and one
of the 1st OBOR projects to achieve
financial close in April last year
– Open-cast coal mine and
associated 660MW mine mouth
power plant (1st integrated coal
mine and power plant in Pakistan)
– Two SPVs set up, one for mine and
one for power station

30. – Equity investors included the Chinese contractor CMEC, Sindh
provincial government, Engro Corporation, various Pakistani and
Chinese strategic and financial investors
• CMEC hold 4% equity in the mine SPV and 35% in the power
station SPV
– Project finance loans, including conventional RMB and Rupee Islamic
tranches, are provided by syndicates of Pakistani and Chinese lenders
including Habib Bank, United Bank, China Development Bank,
Industrial and Commercial Bank of China and Construction Bank of
China
• Chinese funding totalled over US$820million
– Sinosure credit insurance provides cover to Chinese lenders for
political risks such as currency and remittance restrictions,
expropriation and nationalization, sovereign breaches of contract
and war
• Could kick-start Chinese-financed BOT model in other OBOR countries
THAR BLOCK II

31. OPPORTUNITIES FOR
COLLABORATION
• The opportunities for Chinese businesses, local and non-Chinese
businesses to get involved in Belt and Road projects vary from region to
region:
– For example UK businesses are more familiar with certain markets
that Chinese businesses
• Local participation in particular depends on:
– Type of infrastructure needed
– Capacity of local firms to participate
– Political pressure to require local participation
• For non-Chinese businesses, much will depend on the extent to which
Chinese contractors take on the design and construction work and/or
take on the role of investor.
• There are likely to be opportunities for legal, financial and technical
consultancies, and the potential for joint ventures with Chinese partners
with complementary skill sets.

32. OPPORTUNITIES FOR
COLLABORATION
• PPP projects in particular will need significant consultant input:
– Financial experts to design the financial model for the project – needs to show
that the projected income stream from the facility is capable of covering:
• Operation and maintenance expenses (incl. lifecycle maintenance funds)
• Debt repayment and interest
• Equity distributions
– Engineers and technical experts to ensure the technical aspects and
performance outputs of the facility are properly designed and reflected in
documentation
– Lawyers to:
• ensure the many contracts needed for these projects all work properly;
• document the security package for the lenders
• carry out due diligence into the local legal regime for infrastructure
concessions, labour laws, environmental laws, import/export regime etc

33. OPPORTUNITIES FOR
COLLABORATION
• Tendering and project management professionals are also likely to be in
demand on OBOR projects
• Planning and environmental consultants may also be in demand in
certain OBOR locations
Supply chain
• Important to remember China doesn’t yet have a complete domestic
supply chain for all types of infrastructure
• Companies with high-tech products will do well out of OBOR, e.g.
– GE selling wind turbines
– GE and Siemens selling gas turbines
– Honeywell selling control systems for gas processing plants
• Power transmission, automation and building services suppliers likely to
be the biggest recipients of contracts

34. OPPORTUNITIES FOR
COLLABORATION
What about finance?
• Likely to be opportunities to invest in OBOR projects, most likely via equity
investments in SPVs
– This could be something UK investors become interested in, but of
course those projects will be scrutinised very carefully
• May also be opportunities for UK banks to participate in financing of OBOR
projects alongside Chinese banks who are not experienced with project
financing
– Is significant financing expertise and deep capital markets in London
– HSBC has already funded an OBOR power station project in
Bangladesh

35. OPPORTUNITIES FOR
COLLABORATION
• Wider opportunity of increased connectivity and trade between OBOR
countries:
– As OBOR infrastructure creates new trading opportunities UK trading
businesses will be well placed to take advantage, particularly after
Brexit actually happens
– China is the top trading partner of 123 countries, compared to 64
for the US
– UK-owned/co-owned factories in China could also benefit, counter-
acting the slowdown in China’s own economy
• OBOR is already stimulating an M&A boom:
– 242 projects outside of Asia worth $171bn announced in 2016
– UK advisors well placed to assist Chinese buyers
– Chinese investors are already investing in UK infrastructure and
purchasing UK companies