ScottishPower plc includes a merger of water and electricity, plus development of competitive gas and telecommunications businesses, but there is no regional overlap between the water and electricity distribution businesses.

(ii) Dual fuel: electricity and gas supply businesses. A few have telecommunications licences but none are significant players:

CalEnergy	Northern Electric and Northern Electric and Gas Ltd
Texas Utilities Company	Eastern Electricity & Eastern Natural Gas
Dominion Resources Inc	East Midlands Electricity and Sterling Gas
Entergy Corporation	London Electricity and London Total Energy
Avon Energy Partners	Midlands Electricity and Midlands Gas
Central & South West Corporation	Seeboard and Beacon Gas Ltd
Southern Electric	Southern Electric and Southern Electric Gas
New Centuries Energies Ltd American Electric Power Ltd	Yorkshire Electricity and Gas and Yorkshire Electricity
Viridian plc	Northern Ireland Electricity and Gas licensee applicant
Centrica plc	British Gas Trading Ltd

(iii) Single monopoly service with competitive services in other utilities:

National Grid + telecommunications
The York Waterworks plc + gas
Dee Valley Water plc + gas
Cambridge Water plc + gas

There are no multi-utilities, at present, involving a telecommunications company with market power.

Apart from dual fuel companies, customers purchase each utility service separately and the development of a utility service brand has so far been limited.

Possible future developments

Looking ahead is never easy, and the pace of change can be underestimated. Much will depend on the success, or otherwise, of recent initiatives. Possible developments, however, over the next ten years, could include:

• more mergers of regional monopoly service providers ie water and electricity;
• growth of dual fuel companies, possibly with new entrants, increasingly operating at a national rather than regional level. There may be some restructuring in time;
• monopoly service company moving into competitive markets eg water company moving into gas supply or telecommunications (but market scope for this may be limited);
• greater prominence of telecommunications operators in multi-utilities;
• technical developments – possible use of local electricity distribution systems to deliver telecommunications services;
• development of branded utility services and creation of "one stop shop" for two or more utility services. The dual fuel companies are the first stage, but Hyder is moving quickly in this direction.

5. REGULATORY ISSUES FOR MULTI-UTILITIES

Although there are potential benefits from the development of multi-utilities, there are concerns that there may be adverse consequences for customers.

Many of the issues identified in this report in connection with multi-utilities are not exclusive to them. They can, and do, arise where the regulated utility company is a subsidiary of a holding company, or where there is extensive trading with associated companies. Competition issues, similarly, are no different in principle from those which have already arisen and are being dealt with by the regulators. Concern about multi-utilities highlights these issues rather than raises new problems. Some issues, identified in this report, for example separation of electricity Supply and Distribution Licences and improvements to the consistency and transparency of regulatory accounts, are already being taken forward.

There are, however, some regulatory problems which are specific to multi-utilities. These require regulators to work together, which goes beyond the general need for consistency, highlighted in the Green Paper. Handling these matters will be greatly assisted by more transparency about the activities and the internal financial relationships between companies that are part of multi-utilities. This will also facilitate the involvement of third parties, such as consumer bodies, in the regulatory decisions affecting multi-utilities.

The following paragraphs in this section discuss the concerns which have been raised about multi-utilities; the action taken so far; and the need for further action by regulators.

(i) Setting price controls: access to costs

In setting price limits regulators require access to information about costs. Establishing those costs becomes more complex when activities are placed outside the licensed companies; particularly where, as in the case of the multi-utility, the associate company provides services to more than one licensee. Historically, many regulated utility businesses have been members of groups where associate companies provide services to the regulated business. The issue for multi-utilities is not new, it is simply more pronounced.

Price controls are set on the basis of a forward looking view of costs which an efficient business would need to meet. In order to do this it is generally necessary to start from costs actually incurred in a base year. A particular concern for regulation of monopoly businesses is the need for the regulator to be satisfied that base year costs represent actual costs, not costs inflated by cross-subsidies to the parent, or to associate companies. Where multi-utilities undertake monopoly and competitive services, there is clearly a risk of loading costs onto the monopoly activities.

The treatment of joint assets raises particular issues in setting price limits to ensure they are not funded twice.

The mergers of North West Water and NORWEB, and Welsh Water with SWALEC involved the establishment of facility management companies providing services to the regulated businesses. Northern Ireland Electricity has made a similar arrangement. Hyder plc has gone one step further and established Hyder Operations in which the core operational activities of the regulated water and electricity businesses have been combined. The effect is that the residual activity in the two companies which hold the licences is now very small.

Dual fuel companies may also share some activities, or make use of associates to provide services. The extent of concern will depend largely on whether the company is dominant, nationally or locally, in the supply of gas or electricity.

This issue does not arise in telecommunications at present, as BT's licence prevents them from using associate companies in this way and they are not involved in providing other utility services.

Principles

Where services are provided by an associate company, the regulated monopoly company should either pay market prices or prices based on cost. In some cases there may be a readily available market against which to establish a market price (for example the Pool price for electricity). In other cases, it would be appropriate for market prices to be established by competitive tendering.

To be satisfied that these principles are complied with, the regulators must have access to information about costs in the associate companies, as well as the licensed utility company.

Where, as in the case of Hyder plc, and to a lesser extent United Utilities plc, the operations of two regulated monopoly services have been combined, activity based costing systems should be put in place to ensure that costs are appropriately attributed to each of the licensees.

Action taken

Each of the monopoly service providers are under a statutory or licence duty not to cross-subsidise any other activity within the group. For electricity, any changes to the basis of allocating costs in the regulatory accounts of licensees have to be agreed with Offer. For gas, there is no explicit prohibition of cross-subsidy. Instead, costs are required to be properly allocated at the time of price control reviews. Between reviews the monopoly companies must comply with non-discriminatory provisions.

The table overleaf summarises the position regarding regulatory guidance to utility companies about the way in which costs are to be allocated between regulated and non-regulated parts of the business as well as requirements for establishing appropriate transfer prices. In the case of water companies which are part of a multi-utility, additional licence requirements have been placed on them requiring market testing of charges paid to associates and, where this is not done, for charges to be based on actual costs.

Licence conditions have been imposed on multi-utilities giving Offer and Ofwat, via the licensees, access to information held by associate companies including in relation to the costs of providing services to the utility companies.

Since 1995 Ofwat has employed independent consultants to test company compliance with the guidelines governing transfer pricing. Remedial action has been required from companies where activities are non-compliant. The role of the Auditors has been strengthened and they are now required to provide a narrative report describing compliance and highlight to Ofwat any areas of non-compliance found. During 1997 investigations were completed in respect of North West Water and Dwr Cymru (Welsh Water). Staff from Offer participated in these investigations and the results were shared.

In electricity, Offer employs consultants to scrutinise the base year costs as well as assessing how costs may move in future years.
 

	Offer	Ofwat	Ofgas	Oftel
Guidance on cost allocation between regulated and non-regulated businesses	CSC 194/195  Was put in place in June 1989. Guidance on cost allocation developed by Department of Energy in conjunction with the industry	Transfer pricing in the water industry (RAG 5.02). One of a series of regulatory accounting guidelines issued to companies	Issue covered in Ofgas' decisions on separation of British Gas Plc's transportation and supply business (February 1995) and Ofgas' price controls for transportation (May and August 1996) and supply (June and November 1996).	Accounting Documents
Guidance on transfer prices to associates	None issued	Included in above	As above	Accounting Documents

 

Future action

• Offer is reviewing regulatory reporting requirements, including principles governing shared costs and assets. This will assist in establishing base year costs in future price control reviews. A consultation paper will be published shortly.
• In the light of findings of investigations at North West Water and Dwr Cymru (Welsh Water), Ofwat is reviewing its transfer pricing guidelines.
• Consistency between regulators on the guidelines issued to companies needs to be reviewed as part of the wider review of regulatory accounts.
• Consider the need for a licence requirement on monopoly service providers which are part of multi-utilities, to have activity based costing systems for combined operational companies and associates providing services to both licensees.
• Establishing working practices that ensure that regulators can jointly monitor company compliance with the duty to avoid cross-subsidy. Offer and Ofwat consider that this will involve making joint requirements of company Auditors and seeking joint reports from them.
• Measures to ensure greater transparency, in particular a requirement on each monopoly service provider to declare in their published Regulatory Accounts: services provided to, and received from, other companies within the group; the prices paid; and the way in which prices were established. Some water and sewerage companies, that are not part of multi-utility companies, currently provide this information in their statutory accounts.

Each of the multi-utilities have stressed the potential for delivering synergy savings from shared activities arising from both increased economies of scale and economies of scope. This raises the question of how such benefits should be passed on to customers, and what account should be taken of the costs of delivering those benefits. In principle, these questions are no different from those confronting regulators at periodic price reviews in respect of efficiency gains made by single utility companies.

So far these questions, as they relate to multi-utilities, only affect water and electricity and will need to be dealt with at the forthcoming price reviews in 1999 for electricity supply and distribution, and for water and sewerage companies. Offer and Ofwat wish to establish consistent principles governing efficiency savings, and to share information about costs. Offer and Ofwat have already established working level links when dealing with the multi-utilities and these will be developed in connection with their respective price reviews in 1999.

(iii) Independence of licence holder

In competitive markets, if a company runs into financial difficulties, the customers can move elsewhere. But customers of monopoly utilities have no such facility. Regulators need, therefore, to be satisfied that monopoly utility licence holders have the appropriate financial and managerial resources to finance their activities and meet their licence and statutory obligations. Where the monopoly utility company is part of a larger group, whether or not a multi-utility, there is a risk that decisions will not be taken solely in the interests of the regulated company and its customers, but will be influenced by the wider ambitions of the group. There is a risk that a licensee will be denied the resources to meet its obligations.

These concerns have already arisen in connection with the take-overs of many of the public electricity suppliers. They were most recently examined by the Monopolies and Mergers Commission in connection with the proposed PacifiCorp take-over of Eastern Electricity (The Energy Group). The MMC was satisfied that the existing licence requirements, taken together with the existing powers of the regulator, were sufficient to meet these concerns.

The recent restructuring of Hyder plc, including the merger of water and electricity operations in an associate company, has required Offer and Ofwat to consider whether the licensees are still able to comply with their licences. The structure Hyder has put in place makes each of the licensees virtual utilities and prejudices their ability to act independently. On the other hand synergies are more likely to be secured by the combined approach implicit in the recent restructuring of the group.

A related issue to that of ring-fencing of the financial and managerial resources of the licensee, is ensuring that utilities have access to the assets required to deliver services. Many assets required to deliver utility services are unique to that utility service, for example, sewage treatment works, but as multi-utilities develop and technology advances the potential for sharing assets expands.

Regulators will need to ensure that they can identify assets that are required to deliver each utility service. Currently, licensees cannot transfer assets of monopoly businesses to associates without the regulators' approval.

If a company lost its licence and the regulator had to appoint a Special Administrator to take over the running of the utility company, the assets required to deliver that service would also need to be transferred. (This is not an issue in the case of competitive utility services, where a competitor could take over delivery of the service.) Should such an instance arise, regulators would need to determine if the separate utility services could be disentangled, to allow new licence holders to operate each utility service separately, or whether any new licensee would be required to provide a combined utility service, with a single multi-utility licence.

Principle

Each regulator should have sufficient powers to ensure that the holders of licences are able to fulfil their statutory and licence obligations.

Action taken

For each of the monopoly multi-utilities the Director General of Water Services put licence changes in place, at the time of merger, to secure that the licensee is able to act independently.

The additional requirements on the utility company in such circumstances include:

• A requirement that the regulated business is conducted substantially as though it were the licensee's only business and as if it were a separate public limited company. To fulfil this requirement:
• The composition of the Board should allow the licensee to act independently of the parent company or controlling shareholder.
• Board members should disclose, to the Director General, any conflicts between their duties to the licensee and any other duties.
• Where conflicts of interest arise, directors must have regard exclusively to the interests of the licensee.
• Directors of the licensee are precluded from voting on any contract arrangements in which they have an interest by virtue of other directorships.
• The Director General to be informed of any changes in the composition or responsibilities of Board members.
• The licensee requires the Director General's consent on the valuation and treatment in the accounts of any asset transferred to an associate.
• The Director General's consent is also required before the Appointee provides guarantees or loans to associated companies.
• A requirement on the directors of the licensee to ensure that all necessary processes concerning the standard of service to be supplied are included in contracts with associates.

• Restrictions on the activities which the licensee may carry on;
• Requirements relating to the availability of resources. The licensee is required to act at all times in a manner calculated to secure that it has sufficient management and financial resources and financial facilities to enable it to carry on its supply business and its distribution business, and to comply with its statutory obligations and its PES licence.
• Restrictions on the ability of the PES to borrow, to give security or guarantees, to make payments or transfer other assets and to make loans to affiliates.
• Requirements to the provision of information by the ultimate parent company and affiliates.
• A requirement (for certain PESs only) to seek and maintain an investment grade rating for the licensee's corporate debt.

Future action

• Offer and Ofwat are taking a joint approach to the regulatory issues arising from developments at Hyder, in particular the merging of water and electricity operations. One of the key aspects is whether the electricity and water licensees can ensure that the combined operations company complies with licence and other obligations. A solution to this, to which consideration is being given, would be for the parent company to hold the licence for each utility service. Ofwat is currently able to secure the transfer of licences between group companies. Offer does not have this ability at present. Statutory changes to enable Offer to transfer licences would provide consistency of powers to the regulators and provide the facility for Hyder plc to hold the licences for each of the monopoly services.
• Regulators to give consideration to the principles they would wish to adopt, and the action they might take, in the case of a company which had its licence revoked by regulators, or found itself unable to provide utility services due to receivership/liquidation.

A number of competition issues are relevant. These are not exclusive to the multi-utilities, although there may be particular nuances to each of these issues, for those groups providing more than one utility service.

Potential problems relating to multi-utilities which have been identified, all concern the potential for using market power in one utility service (perhaps a service where the company enjoys a monopoly) in order to create advantage in other utility services (perhaps where the company is in competition with others). Such abuse might take the form of:

• cross-subsidy from the monopoly to the competitive business;
• predatory pricing;
• discriminatory treatment of customers; and
• anti-competitive flows of information.

The proposals included in the Competition Bill and regulators' current powers to deal with anti-competitive practices provide the statutory power to deal with issues that may arise. The key to establishing satisfactory approaches to anti-competitive practices will be having established processes and responsibilities for dealing with complaints and consistent application of concurrent powers with the Office of Fair Trading. Guidelines are being developed by the Office of Fair Trading and the regulators which will direct the way in which concurrent powers between sectoral regulators are operated.

Future action

• Regulators with responsibility for competitive markets will continue to keep the development of competition in those markets under close review, with a view to detecting possible anti-competitive practices.
• They will consider using their powers, either to amend licences, or under the new Competition Bill, if abuses are identified. The proposed separation of the electricity supply distribution licence will strengthen the ability to deal with competition issues.

Concerns

A number of issues have been identified which may potentially arise where customers are serviced by a multi-utility:
 

Clarity of bill	Customers should be able to identify the individual costs of each utility service and not receive a 'utility' bill. Gas and electricity must be itemised separately, for both legal and practical reasons.
Allocation of payments   When in debt	Where customer receive a single bill covering more than one utility service, and they make a payment covering less than the full amount, then it must be made clear to them how their payment is allocated (and in which service they are incurring debt).
Inconsistent debt   recovery procedures	Debt recovery procedures within multi-utilities should be consistent to the extent that their different legal positions allow. It would be inconsistent for draconian procedures to apply to one utility service, leading to high levels of debt elsewhere. Customers should not be confused by different procedures within the same supplier.
Different codes of practice	Should there be a single code of practice, which applies across a multi-utility, where standards of service and delivery requirements are broadly similar for example codes relating to the treatment of customers in debt.
Service standards	Ensuring that best practice within each of the utility services is adopted across the range of utility services offered.
Complaint handling	Customers should be clear where, within the multi-utility, complaints will be handled and that complaints will be handled in a consistent manner. Equally, where a customer is dissatisfied with a company's response to any complaint, they should be clear where to apply for redress. Regulators may need protocols agreed between them, that are clear to companies and complainants alike, for dealing with complaints that concern more than one utility service.

Actions taken

Joint billing of electricity and other services has been strongly discouraged by Offer, in order that electricity customers are not misled into thinking that they can be disconnected for anything other than electricity debt.

Links between the electricity and water customer service committees have been established, but these are informal at present. Offer, Ofgas and their respective consumer representative bodies have discussed how dual fuel complaints should be handled. Customer consultation committees have intimated that there may be some duplication of effort at present and there will be a need for improved joint working.

Generally respondents to the consultation paper did not favour a merging of the separate customer bodies to deal with these issues. Instead, they agreed with the suggestion in the Green Paper that the separate councils should develop effective working arrangements to deal with common issues. The Consumers' Association and The University of Hull Centre for Utility Consumer Law, however, took a different view.
 

Future action

• Customer representative committees might formalise their existing informal links.
• National customer representative bodies might establish a forum for identifying and establishing consistent approaches to customer related issues that arise in connection with multi-utilities.
• Clear jurisdiction over customer related issues, including customers' complaints, will need to be established.

(i) Data protection

The multi-utility raises a number of questions about the use of customer data in respect of the utility review for purposes related to another service. The Data Protection Registrar advises that the present position is unclear. On 25 March 1998 the Data Protection Tribunal issued its judgement in relation to the appeal by British Gas Trading Limited against the Registrar's enforcement notice issued in July 1997. The full implications of this decision will not be known until the Tribunal finalises the terms of a revised notice.

The Consumers' Association has commented that the data protection issues in respect of multi-utilities are of a particular kind and that over strict application of rules designed for other circumstances may not be in customers' overall interests. They recommend that customers' views should be sought. The regulators agree with this. It is, however, a matter that falls outside their statutory responsibilities, although they would be prepared to assist.

(ii) Compulsory power and rights by landowners

The Country Landowners Association has expressed concern that the merging of utility companies may lead to blurring of distinctions between rights versus responsibilities to third parties. They point out that the statutory framework is different for each.

The regulators' roles in this area vary. Ofwat has powers to deal with complaints about use (or abuse) of pipe laying powers from landowners. Ofreg and Offer currently have no powers in this area.

(iii) Operation of DSS direct payment systems

REGULATORY ISSUES ASSOCIATED WITH MULTI-UTILITIES

A Consultation Paper by the Directors General of Electricity Supply, Gas Supply, Telecommunications and Water Services and the Director General of Gas and Electricity for Northern Ireland

1 INTRODUCTION
1.1 In its Green Paper on Utility Regulation, "A Fair Deal for Consumers", published on 25 March, the Government invited the utility regulators to carry out and publish a joint study of the regulatory issues associated with multi-utilities, looking to likely developments over the next decade. They asked that, before undertaking the work, the Regulators should consult interested parties on the scope of the study and the particular issues it should address. The Regulators are invited to report by the end of May. The Government will then consider the adequacy of the Regulators' current powers to address these issues, and any need to strengthen them by legislation.

2 BACKGROUND
2.1 There are now a significant number of companies which offer more than one utility service to customers. In some cases, a company in one utility sector has taken over a company in another. Examples are the take-overs of NORWEB by North West Water (to create United Utilities), of SWALEC by Welsh Water (to create Hyder), and of Southern Water by ScottishPower. In other cases, a company in one utility sector has set up a business in another utility sector. For example, most of the Public Electricity Suppliers (PESs) are now also active in gas supply, and Centrica intends to sell electricity in addition to gas when the electricity market for smaller customers opens for competition. Some PESs also have telecommunications licences, and some water companies have gas licences.

2.2 Companies have said that involvement in more than one utility sector enables them to operate more efficiently and reduce their costs. They have also said that the possession of a customer base in one utility service may present opportunities for companies to sell other utility services (and perhaps other non-utility services also) to the same customers.

3 POSSIBLE CONCERNS
3.1 Where mergers have been proposed between water and electricity companies, the water and electricity regulators have jointly sought views on the implications of the merger, before submitting advice to the Director General of Fair Trading on whether or not the merger should be referred. Among the concerns about multi-utilities which have been raised in these consultation exercises, or in other contexts, have been the following:
Access to Information

• whether Regulators will have the necessary access to information about the multi-utility, including both information about licensed utility companies within the multi-utility group, as well as information about non-licensed associate companies providing services to the licensed utilities;

• issues relating to the allocation of costs between different utility activities, including for the purposes of regulatory accounts and for revising price controls;
• how costs and benefits arising from the creation of the multi-utility should be assessed and treated in setting new price controls;
• the potential for cross-subsidy between one utility service and another, and between monopoly and competitive activities. These include issues relating to the allocation of capital and operating costs, and the potential for cross-subsidy where technological developments have opened up possibilities for multiple use of networks (for example, the use of electricity distribution systems for telecommunications);

• whether Regulators will continue to have adequate powers to enforce the conditions in the licences of utility licensees, for example, where the holding company of a multi-utility is not itself a licensee, or where the multi-utility sets up a new, unlicensed subsidiary to provide significant services to and on behalf of the licensees;
• whether the Board of the company holding the utility licence will be subject to pressure to act other than in accordance with the best interests of the licensee and of its customers;
• whether it is possible to put in place adequate ring-fencing of the financial resources of each utility licensee so as to prevent their possible misuse for other purposes to the disadvantage of customers;

• whether multi-utilities may be able to exploit market power in one utility sector (including linking the sale of different utility services) to the disadvantage of competitors and customers;
• whether multi-utilities may misuse customer information, or employ inappropriate selling tactics;
• how sector specific customer representation arrangements might be adapted to secure effective representation of customer interests;
• whether operations of multi-utilities are effectively transparent.

• issues of consistent treatment between different Regulators (for example, with respect to costs, or the valuation of assets; or the regulation of markets in which competition is emerging).

4.2 The situation however is continuing to evolve. For example, Hyder (the parent company of Welsh Water and SWALEC) has announced a restructuring which involves the merger of significant operational activities of the water and electricity licensees. The water and electricity regulators are examining jointly the implications of the restructuring.

5 SCOPE OF THE REVIEW
5.1 In the review which the Government has asked them to undertake by the end of May, the Regulators envisage examining the present extent of multi-utility activity and possible future development. They will want to consider what action has been taken to meet the concerns mentioned in this paper, and other concerns which may be drawn to their attention. It will not be possible to resolve all issues relating to multi-utilities by the end of May, and the Regulators envisage that it will be necessary to keep many of them under ongoing review. By the end of May, however, they will aim to advise the Government as to the adequacy of their powers in relation to multi-utilities, so that any legislative changes can be made at the same time as those needed to implement the Green Paper, and to set out the principles which should underlay the effective regulation of multi-utilities to secure the best interests of customers.
6 COMMENTS INVITED
6.1 The Regulators would welcome comments on the issues which they should address in carrying out the study which the Government has requested. Comments should be sent to:
Mr Mike Saunders                                            Tel: 0121 625 1334
Office of Water Services                                   Fax: 0121 625 1359
City Centre Tower
7 Hill Street
BIRMINGHAM
B5 4UA

to arrive by 1 May 1998.

It would be helpful if responses could be copied to the other regulatory offices involved:

Mr Nick Fincham                                               Tel: 0171 932 1652
Office of Gas Supply                                          Fax: 0171 932 1600
Stockley House
130 Wilton Road
LONDON
SW1V 1LQ
 

Mr Paul Campbell                                                Tel: 0171 634 8890
Office of Telecommunications                               Fax: 0171 634 8893
50 Ludgate Hill
LONDON
EC4M 7JJ
 

Miss Jackie Sellers                                               Tel: 0121 456 6244
Office of Electricity Regulation                              Fax: 0121 456 6361
Regulation & Business Affairs 2
13^th Floor, Hagley House
Hagley Road
Edgbaston
BIRMINGHAM
B16 8QG

Mr Charles Coulthard                                          Tel: 01232 311575
Office for the Regulation of Electricity and Gas    Fax: 01232 311740
Brook Mount Buildings
42 Fountain Street
Belfast
NORTHERN IRELAND
BT1 5AA

6.2 The Regulators wish to make public the responses they receive, by placing them in their Libraries. Please indicate clearly on your response if you do not wish it to be made public.
 

APPENDIX 2

RESPONDENTS TO THE CONSULTATION PAPER
 

Anglian Water Plc

Ashfield District Council

BEAMA Metering Association

BG plc

Binnie Black & Veatch

Bristol Water plc

British Gas Trading Limited/Centrica

British Telecommunications plc

Consumers Association

Country Landowners Association

East Midlands Electricity plc

Eastern Customer Service Committee (CSC)

Eastern Electricity plc

Electric Consumer Committee Chairman's Group

English Nature

European Commission

Federation of Small Businesses

Gas Consumers Council

Gas Technology Ltd

Institute of Hydrology

David Kinnersley

London Electricity plc

Major Energy Users' Council

Midlands Electricity plc

Midlands Region Electricity Consumers' Committee (ECC)

Monopolies and Mergers Commission

National Consumer Council

National Farmers Union

National Federation of Consumer Groups

North East ECC

North West CSC

North West ECC

Northern Electric plc

Northern Ireland Electricity

Northumbria CSC

Nuclear Electric Ltd

Office of Fair Trading

Office of the Rail Regulator

PowerGen plc

Scottish Advisory Committee on Telecommunications

ScottishPower plc

SEEBOARD plc

Select

Severn Trent Water Ltd

Sewer Renovation Federation

Slaughter and May

South Wales ECC

South Western Electricity plc

Southern Electric plc

Southern Region ECC

Andrew Stunnell MP

Matthew Taylor MP

Thames CSC

The Data Protection Registrar

The Royal Society for the Protection of Birds

The University of Hull Centre for Utility Consumer Law

The York Waterworks Plc

Three Valleys Water PLC

Unison

United Utilities

Wales CSC

Yorkshire Electricity plc

Yorkshire Region ECC
 

APPENDIX 3

CURRENT MULTI-UTILITIES
 

ULTIMATE PARENT	WATER LICENCE HOLDER	ELECTRICITY LICENCE HOLDER	GAS LICENCE HOLDER	TELECOMS LICENCE HOLDER
Hyder Plc	Dwr Cymru (Welsh Water Ltd)	South Wales Electricity (SWALEC)	SWALEC Gas
United Utilities Plc	North West Water Ltd	Norweb	Norweb Gas	Norweb Communications
ScottishPower Plc	Southern Water Services Ltd	Manweb Plc ScottishPower	ScottishPower Gas  Caledonian Gas Ltd  Manweb Gas Ltd	ScottishPower Tele-communications Ltd
Texas Utilities Company		Eastern Electricity	Eastern National Gas	Eastern Group Telecoms
Dominion Resources Inc.		East Midlands Electricity	Sterling Gas
Entergy Corporation		London Electricity	London Total Energy
Avon Energy Partners*2		Midlands Electricity	Midlands Gas
CalEnergy Co. Inc.		Northern Electric	Northern Electric and Gas Ltd
Central and South West Corporation		SEEBOARD	Beacon Gas Ltd  Southern Gas Ltd
Southern Electric		Southern Electric	Southern Electric Gas
Southern Company		South Western Electricity	Western Gas	SWEB Telecom
New Centuries Energies Inc;  American Electric Power Inc.		Yorkshire Electricity	YE Gas	*1
PowerGen Plc		PowerGen	Kinetica
Viridian Plc		Northern Ireland   Electricity	Gas Licensee Applicant
ULTIMATE PARENT	WATER LICENCE HOLDER	ELECTRICITY LICENCE HOLDER	GAS LICENCE HOLDER	TELECOMS LICENCE HOLDER
BG plc		Ballylumford Power Ltd	Premier Power Ltd
BG plc		BG plc	Phoenix Natural Gas   Premier Transco Ltd
Centrica Plc		British Gas Trading Ltd	British Gas Trading Ltd
National Grid		National Grid		Energis
The York Waterworks Plc	The York Waterworks Plc		York Gas Ltd
Dee Valley Water Plc	Dee Valley Water Plc		North Wales Gas
Cambridge Water Plc	Cambridge Water Plc		Cambridge Gas Company
Scottish Hydro Elctric Plc		Scottish Hydro Electric Plc		Scottish Hydro

*1 The printed version of this document does contain information that was incorrect and has been taken out of this html copy.

* 2 Cinergy (50% holding)
   General Public Utilities (50% holding