House of Commons - Business and Enterprise

Select Committee on Business and Enterprise Written Evidence

Memorandum submitted by Scottish and Southern Energy plc

INQUIRY INTO THE ENERGY PRICES AND STRUCTURE OF THE ENERGY MARKET

Scottish and Southern Energy (SSE) is grateful to have this opportunity to submit evidence to the Committee's inquiry into the structure of the energy market in the UK. SSE is the UK's second largest supplier of electricity and gas, with around 8.5 million customers, having been the fifth largest six years ago. It supplies energy as Southern Electric, SWALEC, Scottish Hydro-Electric and Atlantic Electric and Gas. It is also involved in the generation, transmission and distribution of electricity and in the storage and distribution of gas. SSE is listed on the London Stock Exchange and employs over 14,000 people in the UK.

KEY POINTS

This submission makes the following key points about the UK's energy market:

1. the market is competitive;

2. there are no significant barriers to entry;

3. price decisions are the result of many issues; and

4. there should be meaningful support for the fuel poor.

In the light of this, SSE believes the Committee should encourage progress to be made in the following key areas:

— securing additional transparency to increase market confidence in the European wholesale gas market and, indeed, the UK's offshore gas market;

— adopting the right principles to ensure there is meaningful support for the fuel poor;

— reinstating metering as a regulated product of the distribution business; and

— simplifying the industry arrangements, to the benefit of potential new entrants and existing market participants and customers.

1. THE MARKET IS COMPETITIVE

— The UK's energy market is the most competitive in the EU and G7—Oxera.

— All segments of the market remain highly competitive—Ofgem.

— Successful suppliers increase customer numbers.

— Responsible and fair pricing.

— Effective customer service.

— The UK's competitive market encourages innovation.

The UK's energy market is the most competitive in the EU and G7—Oxera

Multiple studies have been undertaken into the competitiveness of the UK Energy Market. In October 2007, Oxera, the independent economic consultancy, undertook an independent study examining energy market competition in the EU and G7. Its key conclusion was as follows: "On aggregating the electricity and gas markets, the UK is found to have the most competitive energy market in the EU and G7 in 2005—a position it has held since Oxera first analysed competitiveness of energy markets in 2001".[340] On a scale of 1 to 10, the UK's competitiveness score was 9.1, compared with 7.8 in second-placed Sweden and 6.3 in fifth-placed Germany.

As the Secretary of State for Business, Enterprise and Regulatory Reform put it: "Creating an open and competitive energy market has meant that UK consumers have consistently benefited from amongst the lowest energy prices in Europe. While it is true that wholesale energy prices are rising, greater choice and transparency are clearly the best protection against these costs being disproportionably passed onto consumers".[341]

All segments of the market remain highly competitive—Ofgem

In addition, Ofgem's Domestic Retail Market Report of June 2007 found that: "Our analysis shows that all segments of the market remain highly competitive and not just for customers who pay by direct debit or online".[342]

Ofgem's analysis hinged upon a number of findings, including that: price competition has led to the spread between prices shrinking and the most expensive suppliers being forced to become more competitive; how innovative products are emerging as suppliers seek to win and retain customers; how customer service is improving; and how switching rates are increasing.

Consumers have a wide choice of energy suppliers and they are exercising that choice. According to Ofgem's June 2007 Report, annual rates of switching were at the highest levels in four years. On average 30,000 more switches took place per month than in the previous year. This was an 11% increase in monthly switching rates over the year.

This trend is set to continue. Statistics published by Ofgem show that, between January 2007 and July 2007, 2.8 million customers switched their electricity supplier and 2.3 million switched their gas supplier.[343] This compares favourably to the figures for 2006 between January and July, when 2.6 million electricity customers and 2.2 million gas customers switched supplier. Energy suppliers will continue to compete heavily on price and service, strive for innovation and customers will continue to benefit from switching supplier.

In addition, Ofgem have found that of those customers who have not switched, the majority (more than 70%) say they are happy with the price and service they get from their supplier. Around 15% have not switched as they "do not see the point", while under 3% have not switched as they see it as too difficult, or were unaware of switching as an option.[344]

Successful suppliers increase customer numbers

SSE, which supplies energy as Southern Electric, SWALEC, Scottish Hydro-Electric and Atlantic Electric and Gas, gained one million customers during 2007 and now has well over eight million electricity and gas customers. This enabled it to overtake EON UK to become the UK's second largest energy supplier, having been fifth six years ago.

This achievement in recent years demonstrates the highly competitive nature of the market: by offering lower prices and achieving the best performance ratings for customer service SSE has outperformed its competitors in this market, and customers have voted with their feet.

Responsible and fair pricing

SSE adopts a "fair pricing" policy: it seeks to be the last (or one of the last) of the major energy suppliers to increase prices if it has to, and the first (or one of the first) to lower prices if it can. At a time of sustained rises in wholesale energy prices and other upward pressures on domestic prices, SSE aims to protect its customers from the worst effects.

Household energy consumption is at its highest in the first quarter of the year, with the average household in Great Britain using around 40% of its annual gas consumption and around 30% of its annual electricity consumption in January, February and March. That is why SSE committed not to increase prices during this winter period. The company kept its electricity and gas prices for domestic customers at their pre-existing levels for the whole of the winter, when they are having to use most energy, and will not implement a price increase until after the start of British Summer Time, on 1 April.

In addition, SSE believes that the following displays further evidence of its fair pricing policy:

— During the period of rising wholesale energy prices, SSE passed on to its customers much less than the full extent of the increases in wholesale prices and environmental costs experienced in that period and it delayed any price rises for as long as possible.

345

— SSE was one of the first suppliers to introduce a social tariff to help its most vulnerable customers. Those qualifying for Energyplus Care are offered: a discount of at least 20% off their current tariff; a benefits health check, where appropriate; free energy efficiency measures such as loft and cavity wall insulation; and the loan of an A-rated fridge or fridge freezer if the existing one is inefficient.

— SSE has aligned its electricity prepayment prices with standard credit prices. However, given that only around 25% of customers on PPMs are classified as fuel poor, we are not certain that this decision was an optimal solution for helping our most vulnerable customers.

— SSE has tailor-made payment measures, used on a daily basis by thousands of people, in order to help them to pay their bills in a manner which suits their financial situation.

— As a result of its fair pricing policy, SSE's standard direct debit tariff is actually cheaper than the tariff British Gas claims to be their social tariff—"essentials". Essentials is a tariff designed to help fuel poor customers pay for their energy bills.

Effective customer service

While SSE attributes a significant amount of the credit for its customer growth in terms of attracting new customers upon its pricing strategy, it also retains customers by leading its sector in customer service and complaint handling. Suppliers are competing on complaints and customer service performance as well as price, so SSE considers service to be a primary part of its offering to customers.

SSE has consistently been the best performer in the energy sector because of its high standards in complaint handling and it continues to make significant improvements in its complaints handling procedures.

In the year to March 2007, SSE significantly reduced the total number of complaints referred to energywatch for resolution by 47%, to an average of 70 per month. This has been further reduced during 2007-08, with the number of complaints so far averaging just over 50 per month.

According to energywatch investigated complaints cases, SSE is consistently the best performer. See graph below taken from energywatch website which shows performance across the industry for November 07—January 08.[346] In contrast British Gas's complaints doubled.

In addition to the figures above, SSE had its reputation for providing the best customer service in the energy supply industry confirmed, by topping three independent surveys—J.D. Power and Associates 2007 UK Electricity and Gas Supplier Customer Satisfaction Study, uSwitch.com's Customer Satisfaction Report, and the quarterly supplier performance report by energywatch. This was the fourth consecutive year SSE had topped JD Power Customer Satisfaction awards.[347]

Furthermore, in the highly competitive GB market the ultimate safeguard for customers is their ability to switch supplier if they are dissatisfied with the service they receive. SSE's track record in customer service proves this, with its net gain of one million customers in the year to December 2007.

SSE will continue to work to ensure that the quality of service it provides to its customers is sector leading and that it responds effectively to its customers' concerns about products and services. In 2006, it implemented a new Domestic Energy Customer Charter, the first of its kind in the UK. It made a series of specific commitments in respect of customer service, such as a pledge to respond to letters from customers within five days of receipt. SSE intends to publish a revised and enhanced Charter later this year.

The UK's competitive market encourages innovation

In addition to stimulating competition in service levels, evidence also suggests that Britain's energy supply market drives new product development: 20% of the market is now served by new products such as fixed or capped rate products, online deals or green supply products.[348]

As a supplier SSE has responded to competition by launching a number of competitive innovative tariffs, catering for different customers' needs. Towards the end of last year, SSE launched the "better plan", a unique package which offers customers financial rewards for reducing their energy consumption. Customers receive 100% hydro-electricity at no extra cost and can earn cash credits by being helped to take a few steps to being more energy efficient. New joiners also receive a monitor displaying their energy usage.

SSE also offers a feed-in tariff called Solar Energyplus. It offers grid-tied photovoltaic solar system owners a market leading 18 pence/kWh export tariff. It is aimed at small businesses and households and SSE pays to install export meters, obtain Renewable Obligation Certificate (ROC) accreditation, and act as ROC agent for owners of solar energy systems. At 18 pence per kWh exported, a system generating 1500kWh per year (equivalent to half the UK average for household energy consumption) will earn £135 per year if it exports 50% of power generated. It is also important to note that tariffs such as Solar Energyplus and other flexible innovative tariffs would be aided substantially by the introduction of smart meters.

2. THERE ARE NO SIGNIFICANT BARRIERS TO ENTRY

— 150 licensed suppliers.

— Market entry by high profile names.

— Simplifying industry arrangements.

— Metering needs to be reinstated as a regulated product of distribution businesses.

As explained above, the energy supply market is vigorously competitive, with strong evidence of customer awareness of the competitive market, a switching process that is straightforward for customers, a wide range of offers from suppliers and large numbers of customers exercising choice to switch to alternative suppliers. SSE believes that on each of these counts the competitive energy supply market would compare favourably with other similar competitive markets.

150 licensed suppliers

Nevertheless, one criticism that has been levelled at energy supply is that it is "too difficult" for new entrants to break into the market. Again, SSE does not believe that the evidence supports this. It is relatively easy for any party to obtain a supply licence and sign up to the relevant industry agreements. There are, for example, currently 150 licensed suppliers and in the last 12 months alone there have been a total of 13 applications for supply licences (six applications for gas supply licences and seven applications for electricity supply licences).

It is true that, since competition began, a number of smaller players have exited the market, notably the insolvency of Independent Energy in September 2000 and the exit of a number of electricity and gas suppliers between December 2005 and February 2006 (Zest4, Utility Link, Reepham Limited, Elador and Team Group UK Limited). There has, however, also been exit and failure by "incumbent" generators and suppliers, including the Government intervention to prevent British Energy going under and the failure of the former Eastern supply business under TXU.

Market entry by high profile names

It is also important to note that there has been market entry by a number of high profile names, such as affinity deals with Nectar, Tesco Clubcard, Argos, British Heart Foundation, BA Airmiles and RSPB. In addition, a number of niche players have emerged in the electricity market such as Ecotricity and Good Energy, who specialise in green energy products. Good Energy has also recently been granted a gas supply licence.

Simplifying industry arrangements

SSE is, however, sympathetic to the view put forward by some that the industry trading arrangements at both wholesale and retail level are complex and are becoming increasingly so. It would not agree that at present those arrangements are an insurmountable barrier and the fact that there has been some entry into the market is evidence of that. Nevertheless, SSE does believe that more could be done to simplify the industry arrangements, to the benefit of potential new entrants and indeed existing market participants and customers.

There have been some significant steps taken in this regard, such as the recent supply licence review which halved the bureaucracy of the supply licence, for which Ofgem deserves praise. The remaining obligations were deemed necessary either to facilitate the smooth operation of the competitive market or to afford the most vulnerable domestic customers with additional—but necessary—protection and support.

There is, however, more that can be done. For example, SSE supports Ofgem's review of the industry governance arrangements and would hope that it would lead to a much reduced regulatory burden on the industry, as well as a more streamlined modification process. It also believes that Ofgem could do more to reduce the complexity of some of its reforms, for example in relation to the mind-bogglingly complex auctions for gas entry capacity which have, in SSE's view, reduced competition offshore. Similarly complex arrangements are now being introduced for gas exit capacity and, if Ofgem has its way, would be introduced in electricity. SSE understands the public policy reasons behind the introduction of these arrangements but would urge Ofgem to take wider account of the effect of its complex reforms on the market.

Metering needs to be reinstated as a regulated product of distribution businesses

Another example at a retail level is metering, where the introduction of metering competition has not produced the anticipated benefits, but has led to a fivefold increase in the amount of data that must be processed on change of supplier. Backing out metering competition and reinstating metering as a regulated product of the distribution business would not only simplify the industry change of supplier process significantly, it would also better facilitate the roll-out of new smart metering technologies (which would in turn bring competitive benefits).

3. PRICE DECISIONS ARE THE RESULT OF MANY ISSUES

— Wholesale markets.

— Delivering climate change initiatives.

— Network infrastructure costs.

— Bill breakdown.

— Other contributory factors.

— Wholesale gas market in Europe.

— UK wholesale markets are liquid.

— EU ETS was not a "windfall".

The Committee is concerned about what it termed "the continuing controversy over energy prices".[349] Whenever price rises (and falls) are examined, it is very important that people understand the reasons behind the decisions. In the sections below, SSE outlines some of the contributory factors to price rises (and falls) covering wholesale gas prices, network costs, and the costs associated with tackling climate change.

Wholesale markets

One of the key drivers to recent supplier announcements to raise prices is the recent rise in the wholesale gas price across the world. This is not the fault of suppliers and the effect of this on gas prices within a country importing significant quantities of its gas is obvious. However, it must also be understood that with much of the UK's electricity coming from gas power stations, it will clearly affect electricity prices also. Between 2003 and 2008 wholesale energy prices have increased by a factor of 2.5.

It is also important to understand that for entirely responsible reasons suppliers "hedge" their requirements by buying a significant proportion of their customers' energy needs in advance. When wholesale prices are going up, customers benefit as there is a lag before suppliers raise retail prices; similarly, when wholesale prices fall, it takes time for suppliers to see reduced purchasing costs and pass these through to customers.

SSE's ability to work effectively and efficiently in this area has helped it to succeed in this competitive market, and not pass on the full extent of wholesale price increases to its customers. As a result, its customers have paid an average of around £433 less for their gas and electricity between April 2004 and March 2008 than have customers of British Gas.[350]

The graphs below illustrate the relative change in wholesale prices and SSE's domestic prices[351] for electricity and gas since January 2004, clearly showing how SSE has prevented its customers from facing the full extent of wholesale price increases.

In addition to the above, there is often a misconception that suppliers treat businesses preferentially to domestic customers in terms of passing rising costs on to them. However, the following graphs[352] showing retail price trends for domestic and manufacturing customers tell a different story.

Taken in conjunction with wholesale price trends outlined above, they show that the upsurge in costs in recent years was passed through much faster to business customers than to domestic customers. This might be expected since business customers regularly contract for fixed prices on an annual basis and suppliers arrange short periods of backing accordingly.

Government data is not particularly timely so we can only get as far as Q3 2007 in our modelling, where we see the impact of falling wholesale prices bringing a rapid fall in business prices so that the gap with the domestic trend closes. Since that time however, wholesale prices have started to rise again and we can expect the next data set to show a gap opening up again.

Delivering climate change initiatives

In addition, Government policies to tackle climate change and improve energy efficiency, which command broad support, put an upward pressure on energy prices for all customers. The Carbon Emissions Reduction Commitment (CERT) for example, will add around £38 to the average energy bill for 2008.

Network infrastructure costs

Network infrastructure costs have also increased to support the delivery of new renewable energy and the upgrading of energy networks to ensure they are safe and secure for another generation.

The total costs to customers in delivering network infrastructure and environmental policies have risen by almost 50% in the last four years, from almost £170 on electricity and gas bills in 2004 to almost £250 in 2008.

In total, this additional investment in networks and environmental improvements has added at least £80 per annum to the typical household's[353] energy bills.

Bill breakdown

The below table indicates how all of the above affects the breakdown of a typical bill, showing the price of SSE's tariffs, the use of distribution and transmission costs (UoS); the costs of ROCs; the cost of EEC, now CERT; and metering and billing costs. These figures are then added up to make a "Non Energy Cost". In addition, the "Energy" costs are included, which include the cost of buying the energy (therefore wholesale costs) and include our profit margins.

It is useful to note the following:

— The portion of the electricity bill allocated to "Energy" has increased by a factor of x1.9. Wholesale energy prices have increased x 2.5 in this period.

— In addition, the portion of the gas bill allocated to "Energy" has increased by a factor of x1.7. Wholesale energy prices have increased x 2.4 in this period.

Breakdown for typical bill
£pa	2003	2004	2005	2006	2007	2008	2008	v	2004
							£pa		Change
ELECTRICITY
Tariff	238	251	267	298	382	436	185		x 1.7

UoS*	64	64	70	72	75	76	12		x 1.2
ROC	4	5	6	7	9	11	6		x 2.1
EEC	4	4	9	9	9	19	15		x 5.3
Metering & Billing	18	18	22	25	27	28	10		x 1.5

Non Energy Costs	90	91	107	113	120	134	43		x 1.5

Energy*	148	160	160	185	262	302	142		x 1.0

GAS
Tariff	319	348	380	500	495	584	236		x 1.7

UoS*	94	91	94	101	124	124	33		x 1.4
EEC	4	4	9	9	9	19	15		x 5.3
Metering & Billing	33	33	33	34	35	36	3		x 1.1

Non Energy Costs	97	94	103	110	133	143	49		x 1.5

Energy*	222	254	277	390	362	441	187		x 1.7

* UoS refers to distribution and transmission costs. Prices generally refer to levels at April for electricity and October for gas. Gas in 2008 has been kept at 2007 level.

* Energy includes supply profit/loss

To make this information easier to digest, the information is also translated into graphs below.

Other contributory factors

The above are not all the contributory factors to price rises and falls. Issues as diverse as Japanese nuclear plant problems, LNG supplies, Chinese coal demand, logistical and freight transport issues, Russian and Norwegian gas, and the oil price and its effect on the global economy, all play their part in influencing wholesale energy prices. Outside Britain, for example, the price of gas is linked to the price of oil.

It is against these contributory factors that a supplier must make its price choice and suppliers, of course, have their own internal company structure and cost variations. At the same time, however, the issue of the wholesale gas market in Europe looms very large.

Wholesale gas market in Europe

In recent years there have been a number of investigations into the wholesale gas market which have examined whether high gas prices were attributable to supply and demand fundamentals, or manipulation by producers or European interconnector effects. There has been no firm conclusion regarding the real cause of the problem, however the opacity of upstream information has been identified as a common concern with the market. In the downstream gas market there has been some improvement in the resolution of information available to market participants which has been beneficial, but it is not on a par with that available to participants in the electricity market.

For example, the transparency of a change in flow at an entry sub-terminal informs market participants in that it updates the overall supply position and allows an assessment to be made of short-term prices. On its own though, because the flows are aggregated, this does not provide sufficient information to allow the market to understand which party has suffered a loss and who is likely to come to the market to balance a position. There is no field-specific flow information which would be equivalent to the instantaneous individual power station data that is available in the electricity market.

In SSE's experience it is difficult to contract for long-term gas on fixed price contracts as the majority of contracts are sold on the basis of a floating prompt month index price, leaving only a small volume of gas to be sold prompt. This creates a market where a small volume of gas is being chased by a large number of buyers. Parties like SSE do not therefore have access to information relating to the entire gas supply chain, unlike in electricity. The lack of transparency in the activities of upstream players makes it difficult to understand the true picture in terms of the dynamics on prices.

In Europe, SSE firmly believes that additional transparency is a pre requisite to increasing market confidence which will lead to further trading activity and hence greater liquidity at the gas hubs.

A series of gas pipelines connects the UK with the continent, with the result that this country's wholesale gas market is inevitably affected by prices for gas in Europe. It is likely that dealing effectively with the wholesale gas market in Europe would make the cost of gas imported into the UK less than it otherwise would be.

This illustrates that what goes on in Europe is having a growing and major effect on energy in the UK. It has rightly been observed that Britain can no longer be regarded as an isolated and self-sufficient market for electricity and gas. As a result, the relative lack of competition which the Oxera report (above) identified in Europe is a source of significant concern, and needs to be addressed as a priority.

UK wholesale markets are liquid

Despite the well-documented issues with the wholesale gas market in Europe, it is generally recognised that the UK's wholesale energy markets are the most liberalised and competitive in the EU.

The UK's six leading energy suppliers all own and operate electricity generation capacity, but the wholesale electricity market is much more complex than that. With gas being used to generate over one third of the UK's power needs, rising wholesale gas prices have a follow-on impact on electricity prices. In addition, prices for coal, which is used to generate another one third of the country's power needs, have recently risen to record levels.

Over 50 parties participate in the UK power and gas markets: the major energy suppliers; other generators (such as Drax, British Energy and International Power) financial traders; foreign utilities (mainly European gas and power incumbents); other utilities; and gas producers (such as Shell, Conoco, Gazprom and BP).

This means that the virtual trading location for the sale and purchase of UK natural gas (the National Balancing Point or NBP) is a fully liquid and competitive market, in which active trading provides liquidity, risk capital and market direction. Traded volumes in the UK power market are good, although the lower level of financial interest in this market means companies like SSE make a greater contribution to the overall liquidity of the market.

EU ETS was not a "windfall"

In recent weeks, it has been suggested that the energy industry has received a windfall through the award of carbon emissions permits under the EU ETS. This is completely wrong. The fundamental point is that the permits did not represent a "windfall", but were carefully conceived and designed to ensure the smooth introduction of EU ETS. Moreover, uniquely, the UK electricity generation sector had to operate within tighter emissions limits. Where those limits have had to be breached—often to ensure the overall stability of the country's electricity system—generators have had to purchase permits. SSE, for example, has incurred significant costs in securing permits to make up for the shortfall in our allocation. This is in marked contrast to the position before the EU ETS was introduced, when power stations could emit carbon dioxide free of charge. All of this means that the UK has been a net buyer of permits to emit carbon dioxide.

The approach adopted by the UK government when EU ETS was introduced has ensured stable supplies of power while confirming that carbon dioxide should have a market price. It has, therefore, been very successful and a similar, measured approach to future phases of EU ETS should ensure a progressive move towards lower carbon power generation while maintaining secure supplies of energy.

4. MEANINGFUL LONG TERM SUPPORT FOR THE FUEL POOR

In Budget 2008, the UK government said that it wanted to see energy companies spend a total of £150 million a year to help tackle fuel poverty. SSE has published a draft Code of Practice for helping vulnerable customers that it believes should be adopted across the energy supply industry. This draft Code is founded on two key points:

— the single biggest contribution which suppliers can make to preventing fuel poverty is to keep prices as low as possible for as long as possible. On this basis, those suppliers who charge most for electricity and gas should contribute most to helping vulnerable customers. At the same time, account does need to be taken of the number of customers which each supplier has. The way to combine these principles is to base suppliers' contribution on the annual turnover of their domestic energy supply businesses—a simple and fair formula which reflects suppliers' total customer numbers and the prices they charge for electricity and gas; and

— suppliers should ensure that any "social" tariff which they offer to vulnerable customers is the lowest cost tariff that is made available by them to any type of customer, or any type of payment plan or sign-up method. This will ensure that the lowest-cost tariffs are available for the customers who have most difficulty in paying their bills. As an additional safeguard, SSE believes that suppliers should be required to ensure that their "social" tariff for "dual fuel" is lower than the average UK direct debit tariff.

SSE's voluntary efforts to assist our fuel poor customers have been founded on these two principles. Given the notorious difficulty there is in identifying and targeting fuel poor households, we firmly believe that our twin track strategy makes the greatest contribution in alleviate fuel poverty in Britain. Our determination to keep prices as low as possible for all our customers has prevented many thousands of families falling into the formal definition of fuel poverty.

This approach to general pricing is complemented by a deep and meaningful package of support measures through our social tariff "energyplus care". Eligible households receive at least a 20% discount from their energy tariff in addition to other help including benefit entitlement checks, free energy efficient appliances and homes insulation, where appropriate.

At the time of writing we are engaged in detailed discussions with the Department for Business, Enterprise and Regulatory Reform is devising a voluntary agreement where we will radically increase our voluntary contribution to target even more support to our fuel poor customers.

We will welcome however greater support from government in the future to help us identify the right customers with our programmes to assist the fuel poor. Without that help, we cannot be sure that our voluntary programmes are reaching the right customers.

SUMMARY

SSE understands why there has been so much attention focused on energy supply in the UK in recent months. There are clearly areas which would benefit from progress being made, and SSE has highlighted some which would deliver significant benefits going forward.

Nevertheless, the market is fundamentally sound, delivers for customers and represents the best prospect for the delivery of sustainable, reliable and affordable electricity and gas in the years to come.

SSE would be happy to supplement this written evidence with oral evidence to the Committee if that would be helpful and could be arranged.

1 April 2008