A regulação no setor de saneamento: comparação entre França, Inglaterra e Brasil
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The article discusses the characteristics of the regulation of public services in the sanitation industry, presenting compared ways of providing adopted by France, England and Brazil - and how these countries discipline the private sector participation. While France follows a historical pattern of regulation marked by the role of local authorities, using contracts as an instrument par excellence of the service discipline, England introduced through ambitious privatisation process, regulatory framework in which agencies of the Central Government are the main actors. Even without a model defined, Brazil, through legal innovations, faces the challenges of attracting private investment for a sector under the presence of federative conflicts between states and municipalities about the ownership of these public services.