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MD143
TO MANAGING DIRECTORS OF ALL
WATER AND SEWERAGE COMPANIES
AND WATER ONLY COMPANIES
15 January 1999
Responses to Prospects for Prices
I am pleased to say that there has been a large response to the consultation paper, Prospects for Prices, from a broad range of interested parties. I believe that it will be helpful for you to have an overview on the responses to the issues raised before my formal meetings with your company later this month or next month. I therefore enclose a summary of the responses. This summary has also been sent to all those who responded.
I will consider all responses carefully, together with what the companies say to me at our meetings. Obviously my draft determinations must be based on companies' Business Plans and on judgements about a number of issues which can only be made later this year. Nevertheless, where I can confirm changes to our stated methodology, or can indicate my likely approach to any of the issues identified in Prospects for Prices, I will do so early in March. This will be in time for you to take account of these in finalising your company's Business Plan which you are due to send to me by 9 April.
I C R Byatt
Prospects for Prices
A consultation paper on strategic issues affecting future water bills
Summary of responses
Prospects for Prices was published on 29 October 1998. It set out for customers and all other interested parties the key issues that will affect future water bills. The Director invited views on those issues by 4 January 1999. This paper summarises the views he received.
A total of 132 organisations or individuals submitted views. The respondents are listed in Appendix A to this paper. Copies of their responses will be lodged in the Ofwat library with the exception of responses from four companies (Anglian Water, North West Water, Severn Trent Water and Southern Water) and Prudential Portfolio Managers Limited who have stated that their responses are confidential. In the case of the companies this is because the responses contain information about them which they consider to be commercially sensitive.
Prospects for Prices set out the issues in the form of questions, on which views were specifically sought. Most respondents structured their replies around these issues. With the exception of the companies, few commented on all the issues. A few respondents chose not to address directly the key issues identified in Prospects for Prices but to raise other matters.
The responses are summarised below under each of the key issues.
The profile of bills - Should prices fall initially to the point where returns do not exceed the cost of capital (subject to any adjustments for incentives and past service performance)?
Many of the customer respondents express their desire for the initial price cut but have not addressed the specific issue that the initial price cut should reduce the returns to the cost of capital.
Water companies argue that there should be a glidepath for returns to fall to the cost of capital. They cite the view adopted by the MMC in the review of the 1994 price determinations for South West Water and Portsmouth Water (and more recent MMC decisions on BAA and Manchester Airport) that returns are allowed to converge to the cost of capital over a five-year period. The companies are concerned that an initial price cut would damage incentives particularly when coupled with a negative service performance adjustment (see later text for a summary of their responses on incentives and service performance adjustments). A combination of their suggestion to retain operating efficiencies on a five-year rolling period (for consistency with capital efficiencies) and a positive service performance adjustment would in effect create a glidepath. - If the combination of an initial price reduction and the costs of new environmental and quality obligations were to push bills up subsequently, would it be right to preserve a flatter profile of prices, leaving companies with greater revenues and profits in the early years?
Most respondents addressed this issue. Generally customers, customer representatives (including most Customer Service Committees (CSCs)) and MPs want as large a price cut as possible, at the earliest opportunity and with the smallest possible price increases to finance necessary investment thereafter. Their preference is for a "V" shaped profile. In contrast, the water companies and environmentalists want a smaller initial reduction – or no initial reduction - in the first year, with stable prices thereafter.
The water companies unanimously support the stable bill profile, which they believe has the unambiguous backing of customers. The main reasons cited are to preserve incentives to improve efficiency and to provide stability for the longer-term investment needs of the industry, including beyond 2005. Some companies, in areas where water resources are tight also argue that a large price cut will undermine their demand management initiatives by giving perverse pricing signals to customers. Many of the companies are concerned about customer, political and regulatory reaction to (and potential complaints about) price increases above inflation in the years following what they describe as an "aggressive" price-cut in the first year. They believe this could increase risk and the cost of capital.
The preference of environmental groups for a stable bill profile is based on similar arguments to those advanced by the water companies regarding stability for the longer-term investment in environmental and quality improvements. They want to see continuous activity on environmental improvements rather than peaks and troughs. Respondents from trade bodies and suppliers to the industry also prefer a flatter profile. Local government respondents who expressed a view also favour a flatter profile.
The majority of responses from customers, customer representatives and MPs express a strong preference for a "V" profile. They want to have an immediate resetting of the balance of benefits between customers and shareholders. They argue that customers should pay for investment only as and when it is incurred. Public Utilities Access Forum argues that if the profile is properly explained to customers, they are "unlikely to have difficulty understanding why, in order to finance new projects some bills might have to rise again subsequently, assuming that they accept the need for such projects." This view is shared by a number of other customer respondents, such as the Consumers' Association. Some of those in favour of a "V" shaped profile say it would be more transparent. The National Consumer Council wants to see the maximum price cut possible in 2000-01, but do not address the specific issue about the choice of profile.
The minority of customers who favour a flatter profile cite incentives for long-term investment, or argue that bill increases above the rate of inflation in successive years would lead to customer dissatisfaction. Age Concern say that older people would prefer a flatter profile because they find it easier to budget with stable bills. They question, however, whether a maximum initial reduction must lead to subsequent increases. One respondent is concerned that large price cuts will lead to job losses.
Incentives - Is it right to expect companies judged by the Director to be relatively inefficient to improve their efficiency at a faster rate than the more efficient ones? Should this mechanism be more powerful than in the 1994 Periodic Review?
The unanimous response to the first question is "yes"; relatively inefficient companies should improve their efficiency at a faster rate than the more efficient companies. Few respondents, however, apart from the companies, comment on whether the mechanism should be more powerful than in 1994.
Many of the companies express concern over Ofwat's ability to distinguish robustly between efficient and inefficient companies on the basis of econometric models. They say that uncertainties over econometrics mean no greater reliance should be placed on them at this review than was placed at the last review. Some companies argue that the efficiency targets implicit in a more powerful mechanism would be unrealistic. Many of these comments are couched in terms of the circumstances of the particular company.
Some companies, however, suggest that most future efficiency gains should come from the less efficient companies, and therefore the mechanism should be more powerful. Portsmouth Water goes further and suggests that companies at the frontier should have no efficiency target, or even a positive adjustment.
Southern Electric suggests alternative ways of setting targets but does not comment on the mechanism for assessing relative efficiency.
On the overall scope for efficiency the companies are of one view that the possible ranges set out in Prospects for Prices are too harsh. Several companies refer to the Stoneman and Bosworth work, commissioned by Thames Water, which concludes that the scope for further operating efficiencies is small. One respondent claims that too harsh assumptions will affect employees and restrict his salary. There is a repeated theme, again from the industry, that previous rates of improvement cannot be continued. This view is shared by some of the trade bodies. Other companies make comments more specific to themselves, but the common view amongst these is that the scale of efficiency savings proposed is unattainable, and could lead to the demise of small companies.
Respondents from outside the industry have less doubt about the scope for further savings. Wandsworth Borough Council, for example, says "companies should not rest on their laurels and assume that they have achieved some hypothetical level of maximum efficiency which rules out further savings. Wandsworth Council has experience of efficiency savings annually since 1978." Arun District Council also believes there is scope for significant savings. Central CSC says that the Director should set exacting targets. - Is it right to leave those companies which have outperformed the Director's assumptions and are considered to be more efficient, some of the benefits of outperformance beyond the price review by an adjustment to the initial price reduction?
The starting position for companies on this issue is that an initial price reduction, to the point where returns on capital do not exceed the cost of capital, would damage incentives. Water UK goes as far as to say that Ofwat's statements on this have already damaged incentives. Companies consider that an unadjusted initial reduction leaves them with an inadequate share of outperformance. A number of companies have said that this will affect future investment appraisal decisions. Any cost savings initiatives requiring capital expenditure would in future require very rapid pay back.
A few companies support the proposal in Prospects for Prices for an adjustment to the initial price reduction for those who have outperformed and are considered to be more efficient. Generally, however, these are the companies who might meet these criteria.
Most companies favour some sort of glidepath, which would be applied to all companies, which have outperformed the Director's assumptions in 1994. Some accept that there could nevertheless be some differentiation, according to the degree of outperformance. Many companies suggest a five-year rolling adjustment for opex outperformance. Points made in support of this include: - It would be consistent with the MMC's decision in 1995 on the current price limits for South West Water and Portsmouth Water.
- It would be consistent with the approach Ofwat proposes for capex outperformance.
- It would maintain incentives throughout the period between price reviews, whereas the proposal in Prospects for Prices would generally discourage efficiency initiatives in the years just before a price review.
- It would lead to a flatter profile for bills, which companies favour (as noted above.)
- It would provide an element of headroom for companies to manage uncertainty.
Views on this issue amongst other respondents are more mixed. Some CSCs support a positive adjustment reflecting past performance. Others, however, take the view that shareholders have had enough benefits. Wessex CSC suggests that such an adjustment should only come into effect in 2005.
Other customer representatives who commented on this issue are generally opposed to any adjustments, as are the few environmental groups and others, who responded. Some of these see outperformance as more a comment on the Director's decisions in 1994 than genuine efficiency savings. Gillian Shephard (the Shadow Secretary of State for the Department of Environment, Transport and the Regions,) on the other hand, favours enhancing incentives. - Should price limits be adjusted asymmetrically for past performance on services to customers and the environment, within a range of 0.5% to -1.0% per year?
Generally companies are opposed to an asymmetric adjustment arguing that symmetry is an important factor in the regulatory process. They are, however, split between acceptance of a symmetrical adjustment and the desire to see only a positive adjustment. Those in favour of the latter argue that as all companies have shown an overall improvement since 1994, a negative adjustment would be inappropriate. There is some anxiety that a negative adjustment will duplicate other sanctions and compensation payments. There remain some concerns (mainly from companies who compare unfavourably in Ofwat's assessment of performance so far) that the methodology is not sufficiently robust. There is also some concern that a negative adjustment will not allow companies to finance their functions within price limits.
Customer representatives generally favour an asymmetric adjustment but are split between support for the adjustment as proposed, and support for the view that as price limits contained sufficient incentive, only a negative adjustment should apply. Environmental groups generally hold the latter view.
The City believes that the service adjustment should be asymmetrical but would not necessarily expect the poorer performers to suffer the full 1% penalty unless there were major shortfalls in service. They are concerned that the consequent revenue differential between the best and worst companies might outweigh the difference in service.
Two companies argue that instead of a negative adjustment to price limits, the Director should allow remedial investment where performance is judged to be poor. Thames Water proposes that any penalty should be withdrawn if, and when, a company's performance improves. Two companies suggest that the performance adjustments and efficiency adjustments should be combined.
The cost of capital and financial indicators - In competitive markets, inadequate management or unexpected shocks may mean that, in a particular year, a company earns less than its cost of capital. In the water industry, should price limits be set such that the cost of capital is a floor for companies' returns in all foreseeable circumstances?
Most of the responses on this issue were from the companies.
Many responses make points concerning Ofwat's proposals on the cost of capital set out in Appendix B to Prospects for Prices as well as the specific issue posed. Some companies provide estimates of their view of the cost of capital. The mid-points of these ranges are all higher than Ofwat's mid-point, but in many cases not substantially so. A number of the ranges overlapped with the upper end of the Ofwat range. Key points made by companies are: - Business risks have increased, not decreased, since the last review – particularly competition, regulatory and political risk.
- The risks of the business are asymmetric and hence there should be headroom in the cost of capital to allow for these.
- No account is taken of the costs of existing debt structures, which cannot be refinanced or would be more costly to do so.
- Opportunistic use of 'spot' values runs counter to regulatory and MMC precedent and will force a mismatch between asset and liability lives, hence increasing uncertainty and risk.
- Agree that interest cover is the key financial indicator, but believe that it needs to be somewhat greater than 2 times.
A number of these themes were brought together by some company respondents to consider the overall `bankability' of the proposals. They argue that the large capital programme will be generally financed by new debt financed at nominal (rather than real) interest rates and hence it is the accounting interest cover, rather than the cost of capital which will be the primary determinant of their ability to finance their functions. This places greater emphasis on levels of interest covers acceptable to providers of debt finance and consistent with involvement grade cost ratings.
In terms of the specific issue, the larger companies, who responded to this point, agree that price limits should not be set such that the cost of capital is a floor for returns in all foreseeable circumstances providing that the risk of the business are properly captured in the cost of capital. Many of the smaller companies considered that it should be a floor.
Other respondents who commented on this issue all considered that price limits should not be set such the cost of capital is a floor in all circumstances and that water companies should be in no different a position to companies in a competitive market. The National Consumer Council suggested that water was a significantly lower risk business than other utilities such as gas, electricity and telecoms.
One respondent commented that water companies had subscribed to a competitive market economy on privatisation and should not, therefore, be isolated from its effects. - Is there a need for, and if so what is the size of, any premium on the cost of capital for small independent water companies?
With one exception, only companies commented on this issue.
All of the water only companies support a premium on the cost of capital and many considered it should be widened to encompass all of them and not just small independent companies. Of the water and sewerage companies who responded, the majority did not support a premium believing it to lead to a sub-optimal structure of the industry. Some recognise the more limited access to capital markets of small companies.
One small water and sewerage company suggests that there should be a scale of premium depending on company size, which should also include the smaller water and sewerage companies.
One response takes the view that the case for a small company premium to the cost of capital needs to be supported by evidence before the Director should accept it.
Few respondents quantify the premium, but of those that do, the consensus is for a premium of between 0.8% and 1.25% on a pre-tax basis. This compares with the suggestion in Prospects for Prices of a premium for small independent companies in the range of 0.5% to 0.75%.
Maintenance of the serviceability of assets to customers - Is the Director right to focus on the serviceability of a water company's assets, leaving the company's management to ensure that the condition of the assets is sufficient to secure serviceability to customers?
Few respondents, other than the companies and trade bodies, suppliers and contractors commented on this issue.
Although companies generally accept that serviceability trends are relevant to assumptions in price limits about the future level of capital maintenance expenditure, many argue that it cannot be the only consideration. They argue that a forward look predictive approach should be used based on the condition or age of assets. A number of company respondents state that current levels of maintenance are insufficient and, without an increase, a backlog of problems will emerge. Some argue that although current performance of the assets is improving, the risks of failure in the future are increasing; and that asset failures could be catastrophic.
Several companies quote Raising the Quality: Guidance to the Director General of Water Services on the Environmental and Quality Objectives to be Achieved by the Water Industry in England and Wales 2000-2005 which, recommends that companies should take a strategic approach to the maintenance of their assets. These companies have interpreted this as an approach based on an engineering assessment of the future performance of individual assets.
Smaller companies have pointed to the "lumpiness" of asset renewal cycles, which may mean that recent levels of maintenance activity are an insufficient guide to future needs.
Trade bodies, suppliers and contractors, express similar views to those of the companies. They believe that Ofwat's approach to this issue is simply storing up problems for the future. One notes what it describes as the apparent paradox of "low" maintenance but improving performance. It nevertheless argues for a precautionary approach.
Environmental groups who commented generally support higher levels of maintenance to secure improved environmental standards.
Supply and demand - Is it right to allow for some increases in customers' bills to cover the costs of demand management, especially the installation of meters?
Most water companies responded "yes" to this issue. They argue that the free installation of household meters is likely to become a statutory obligation once the Government's Water Charging Bill is approved by Parliament. Increases in bills would, therefore, be needed to ensure water companies can finance this new obligation on them.
Some companies nevertheless express the view that metering, especially optional meters, is not a cost-effective option for balancing supply and demand and that the Government's proposals would increase the upward pressure on bills. Others take the view that metering has longer-term benefits for all customers through deferring investment in new resources and this reinforces the case for allowing increases in bills to meet meter installation costs.
Views amongst CSCs, and amongst all other respondents, who commented on this issue, are divided. Those who are opposed to customers generally meeting the costs of meter installation say it is unfair for such costs to be borne by existing metered customers and by those customers whose demands do not create pressure on the balance between supply and demand. Some suggest that the costs of installing meters for those who opt for meters should be reflected in their tariffs.
Strong concerns are also expressed about the potential scale of bill increases for unmeasured customers arising from free optional metering, especially from consumer groups representing disadvantaged groups.
Others, however, believe that there are long-term benefits from encouraging metering and that the costs should, therefore, be borne by all customers. - Should companies develop tariffs to ensure that those imposing increases in demand, particularly at peak times, provide the revenue necessary to secure the additional resources required, rather than increasing the margin between supply and demand at the expense of all customers?
Most respondents agree in principle that companies should develop their tariffs to provide the revenues to meet the costs of new supplies. Many highlight, however, that constraints, such as relatively low levels of household meter penetration and available metering technology, mean that this objective is only practical in the longer term. A number of water companies comment that the Government's metering proposals in the Water Charging Bill would restrict their ability to meet this objective.
The need to protect vulnerable customer groups with tariff design is also highlighted.
Some companies, however, consider that as improved margins between supply and demand benefit all customers, there is a case for reflecting the costs in price limits. - Is it right to increase customers' bills to allow for expenditure to reduce the frequency of emergency abstractions from rivers and streams where the benefits are clearly cost-effective?
Only a minority of respondents directly address this issue. For those that do, there is a broad consensus that the costs of reducing emergency abstractions and improving river flows should be reflected in customers' bills, but only where this is demonstrated to be of benefit to the environment and where it is identified as a priority by customers. Very few responses suggest that little or no regard should be shown to cost-effectiveness on these issues.
One response suggests that the Environment Agency should increase the price of emergency abstractions. This would provide incentives for the water companies to seek lower cost ways – financial and environmental - to meet customer demands, particularly in dry years.
Levels of service - What priority should be given to improvements in service, such as reductions in sewer flooding, where these would have to be financed through higher bills from customers?
Most respondents who have commented say that sewer flooding of homes is not acceptable and should be given high priority among proposed improvements. With the exceptions of the companies and the CSCs, however, few comment on whether or not an allowance should be made in bills for this.
Companies who are proposing improvements in service (including sewer flooding, water aesthetics and reducing discolouration) believe that customers are willing to pay for them and therefore that the improvements should be financed from customers' bills. Water UK also puts the view that such improvements should be allowed for in price limits. Some of the water companies have pointed out that levels of customer satisfaction are high and the need for further service improvements may therefore be limited.
A few companies have commented that the overall approach to price limits set out in Prospects for Prices could jeopardise their ability to maintain existing high levels of service. Northumbrian Water indicates that the environmental and quality programme for its region would leave it little scope for enhanced service levels.
Environmentalists concentrate their replies around the need for environmental, rather than service, improvements.
A recurring opinion among other respondents is that any enhancements in service should be widely supported by customers before they go ahead. Opinion is split, however, as to whether allowances should be made in customers' bills to pay for these. The CSCs generally accept that where priority improvements (sewer flooding in particular) are proposed they might reasonably be funded out of increases in bills. The only exception is the CSC for Wales, which supports a reduction in sewer flooding, but does not believe that there should be any extra cost to the customer in achieving this. Age Concern and the Consumers' Association believe that customers should not have to pay extra to receive improved services.
MPs have not generally commented on enhanced service levels, although three of them consider that price limits should only cover legally enforceable standards and environmental requirements.
The majority of local councils support improvements in general. Although three state that sewer flooding is not acceptable they do not comment on how its elimination should be paid for. One County Council states that good practice should be expected and the cost of providing this should be borne by the companies.
Business customers generally support the need to invest in improvements to sewer flooding, but are more sceptical about increasing bills to fund other enhancements.
Regional bills - Is it right to limit further environmental improvements beyond what has so far been clearly defined (including EC obligations), so that bills do not rise excessively in some areas?
Not all respondents commented on this issue, and views are predictably divided.
Environmental groups are very clear in their views. Decisions on the extent of the environmental programme for individual companies should be determined solely on environmental criteria. They see no case for limiting regional programmes solely because there are concerns about customers' bills; and a number express concerns, shared by some companies, about a two-tiered approach to environmental standards. A few respondents believe that the costs in some areas are higher than they need to be because the companies concerned have deliberately sought to meet minimum standards only, in order to maximise profits, even though they knew that they would have to meet higher standards eventually. They contrast this behaviour with that of other companies that sought to meet the highest standards from the outset. They argue, therefore, that the higher standards should now be met at the companies' expense.
Local authorities who commented generally attach a high priority to environmental improvements and consider that limiting the programme because of concerns about bills would be a short-term view, and not in the interests of successive generations. Some do, however, have clear views on the priorities for improvements in their areas.
The majority of CSCs, including all of those where permanent reductions in bills may not be possible, are very concerned that Ministers' decisions on individual company obligations should take into account the effect on customers' bills. Some of these acknowledge local pressures for improvements beyond EC obligations, especially for improvements to secure guideline standards for beaches. They nevertheless argue that a phased approach should be adopted. The CSCs generally stress that it is important for every environmental scheme to be justified on sound cost-benefit grounds and they are concerned that there is no evidence that this is being done in a transparent way.
Other consumer bodies tend either to agree with the views expressed by the CSCs or to avoid answering the question directly. Some of the latter consider that it is wrong for Ofwat to pose a choice between environmental improvements and customers' bills, because Ofwat's analysis ignores the role "played by companies' financial behaviour" or the scope for future efficiency.
Some respondents argue that the government should devise some mechanism for equalisation of regional bills through taxation or other means.
There are a variety of views among the companies. Some express the opinion that customers are in favour of environmental improvements and, based on their market research, that customers are willing to accept the consequences for bills. Their view is that if environmental improvements are necessary then they should be included in the obligations on companies.
Other companies, however, are concerned about the effect on bills for customers and argue for a phased approach to environmental improvements.
A number of CSCs and companies are strongly opposed to the idea that environmental programmes should be enhanced in some regions solely to enable the realisation of national targets. Quite apart from the effect on bills in those regions they consider that this approach would offer poor value for money.
LIST OF RESPONSES
NO | COMPANY |
| | Water companies |
1 | Anglian Water Services Ltd* |
2 | Dwr Cymru Welsh Water |
3 | Northumbrian Water Ltd |
4 | North West Water Ltd* |
5 | Severn Trent Water Ltd* |
6 | Southern Water Services Ltd* |
7 | South West Water Limited |
8 | Thames Water Utilities Ltd |
9 | Wessex Water Services Ltd |
10 | Yorkshire Water Services Ltd (Annex A only)** |
11 | Bournemouth & West Hampshire Water Plc |
12 | Bristol Water plc |
13 | Dee Valley Water PLC |
14 | Essex and Suffolk Water plc |
15 | Folkestone and Dover Water Services Ltd |
16 | General Utilities |
17 | Mid Kent Water plc |
18 | North Surrey Water Ltd |
19 | Portsmouth Water plc |
20 | South East Water plc |
21 | South Staffordshire Water plc |
22 | Sutton and East Surrey Water plc |
23 | Tendring Hundred Water Services Ltd |
24 | Three Valleys Water PLC |
25 | The York Waterworks Plc |
26 | Water UK |
| | |
| | Quality regulators/environmentalists |
27 | Alton's River Campaign |
28 | Countryside Commission |
29 | English Nature |
30 | Environment Agency |
31 | Eye on the Aire |
32 | Friends of the Earth Cymru |
33 | Marine Conservation Society |
34 | Royal Society for the Protection of Birds |
35 | Surfers Against Sewage |
36 | The Wildlife Trusts |
37 | Yorkshire Wildlife Trust |
| | |
| | Organisations representing customer interests |
38 | Age Concern England |
39 | Chartered Institute of Purchasing and Supply |
40 | Chemical Industries Association Ltd |
41 | Consumers' Association |
42 | Major Energy Users Council |
43 | Mencap |
44 | National Consumer Council |
45 | National Farmers' Union |
46 | National Federation of Consumer Groups |
47 | National Federation of Small Businesses |
48 | National Union of Residents' Associations |
49 | North Eastern Purchasing Organisation |
50 | Ofwat Central CSC |
51 | Ofwat Eastern CSC |
52 | Ofwat Northumbria CSC |
53 | Ofwat North West CSC |
54 | Ofwat Southern CSC |
55 | Ofwat South West CSC |
56 | Ofwat Thames CSC |
57 | Ofwat CSC for Wales |
58 | Ofwat Wessex CSC |
59 | Ofwat Yorkshire CSC |
60 | Public Utilities Access Forum |
61 | Waterwatch |
| | |
| | Trade bodies, suppliers and contractors |
62 | British Water |
63 | Chartered Institute of Water and Environmental Management |
64 | Sewer Renovation Federation |
65 | Society of British Water Industries |
66 | The Water Industry Suppliers Group |
| | |
| | Members of Parliament (in addition to 2 Page briefing note) |
67 | Peter Bottomley MP |
68 | Angela Browning MP |
69 | Ann Cryer MP |
70 | Rt Hon Stephen Dorrell MP |
71 | Roger Gale MP |
72 | Nick Harvey MP |
73 | Rt Hon Michael Jack MP |
74 | Brian Jenkins MP |
75 | Jenny Jones MP |
76 | Bob Laxton MP |
77 | Richard Livsey CBE MP |
78 | Humfrey Malins CBE MP |
79 | Lembit Öpik MP |
80 | Diana Organ MP |
81 | James Plaskitt MP |
82 | Mel Read MEP |
83 | Dari Taylor MP |
84 | Matthew Taylor MP |
85 | Dennis Turner MP |
86 | Joan Walley MP |
87 | Phillip Whitehead MEP |
88 | David Winnick MP |
89 | Shadow Secretary Environment, Transport and the Regions |
| | |
| | Local government organisations |
90 | Angmering Parish Council |
91 | Arun District Council |
92 | Bognor Regis Town Council |
93 | Durham County Council |
94 | East Midlands Regional Local Government Association |
95 | Great Yarmouth Borough Council |
96 | Knowsley Metropolitan Borough |
97 | Northumberland County Council |
98 | North Yorkshire County Council |
99 | Redcar & Cleveland Borough Council |
100 | Ryedale District Council |
101 | Wandsworth Borough Council |
102 | Wansbeck District Council |
103 | West Wiltshire District Council |
| | |
| | Others |
104 | Aqua Resources Group Ltd |
105 | BCN Data Systems |
106 | British Medical Association |
107 | H & B Bruder |
108 | Campaign Against Monopoly Abuse |
109 | Mrs Janet Cuff |
110 | Mrs Linda Doyle |
111 | Jean McLeod Forbes |
112 | Mrs M T Foster |
113 | Colin F Goodall |
114 | Peter Knowles |
115 | Mr C G Lamb |
116 | M & G Investment Management Limited |
117 | Mr & Mrs J F K Morey |
118 | Atamjit Niber |
119 | Oxford University |
120 | Terry Plume |
121 | Prudential Portfolio Managers Limited* |
122 | Liz Reason |
123 | Mr C E Richards |
124 | Mr S H Ruck |
125 | Deborah Sacks |
126 | Southern Electric plc |
127 | G T & S R Stride |
128 | Transco |
129 | Dr Neil Watkinson |
130 | Anthony E Webb |
131 | Richard B Webb |
132 | J Wild Investments Limited |
List as of 15 January 1999
Total number of responses: 132* | 
Letters to Managing Directors
