ISIN numbers: Northern Ireland Electricity Networks Limited XS0085211315 and NIE Finance PLC XS0633547087
Northern Ireland Electricity Networks Limited (NIE Networks) has submitted its response to the Utility Regulator's draft determination on NIE Networks' Transmission and Distribution Price Controls 2017 - 2024. The draft determination is available on the Utility Regulator's website at http://www.uregni.gov.uk/
The Executive Summary of the response is provided below. The full response will be available within the next few days on NIE Networks' website at http://www.nienetworks.co.uk/RP6Response
NIE Networks is the owner of the electricity transmission and distribution networks in NI and is the electricity distribution network operator, serving all 860,000 customers connected to the network.
NIE Networks is a regulated company and its business activities are overseen by the UR in NI.
The role of the UR is determined under legislation and its statutory principal objective in relation to electricity matters is:
"To protect the interests of electricity consumers in Northern Ireland, wherever appropriate by promoting effective competition between persons engaged in or in commercial activities connected with the generation, transmission or supply of electricity." 1
In carrying out its functions, the UR should act in the manner best calculated to further the principal objective, having regard to (among other things):
(i) The need to secure that all reasonable demands for electricity are met; and
(ii) The need to secure that licence holders are able to finance the activities which are the subject of obligations imposed under applicable NI energy legislation.2
 Article 12(1) Energy (Northern Ireland) Order 2003.
 Article 12 (2) Energy (Northern Ireland) Order 2003.
RP6 Business Plan development
NIE Networks submitted its business plan for RP6 to the UR on 29 June 2016. Extensive planning, analysis and consultation were carried out to ensure that the plan for RP6 delivers benefits for current customers and sets the foundations for the future. Maintaining and expanding the network to meet customers' needs, now and in the future, requires continuous assessment, innovation and investment.
In developing the plan NIE Networks considered a range of factors.
- Delivering the required services at least cost. Throughout the process of developing the plan NIE Networks has worked hard to ensure that the allowances it is seeking only include work which is strictly necessary to enable it to carry out its transmission and distribution functions to an appropriate standard and to provide a network which is fit for purpose for NIE Networks' customers.
- Ensuring a safe and reliable network. NIE Networks' aim is not only to protect customers in respect of the cost of using its networks but also in respect of the safety and reliability of supply. The availability of a reliable electricity supply is important to business as well as domestic customers and enables NI to compete effectively for inward investment.
- Balancing the needs of current and future customers. It is important to balance the interests of different generations of customers, not to defer works which ought properly to be undertaken now, invest responsibly in innovation for the potential benefit of future customers and to balance the interests of different groups of today's customer (for example, rural and urban customers).
- UR guidance. The UR published detailed guidance on the extensive information it requires from NIE Networks to enable it to assess NIE Networks' plans and set allowances for its activities. Following this guidance has been central to NIE Networks' approach to preparing its business plan.
NIE Networks has taken a detailed and transparent approach to preparing its RP6 Business Plan. This has included reviewing the condition of the electricity network, carrying out detailed engineering studies, analysing costs, undertaking benchmarking, reviewing industry best practice, and importantly, considering the long term strategic issues facing the electricity network. The most important strategic issues are: ensuring the network is fit for purpose as the electricity sector faces the challenge of climate change through decarbonisation and how to manage an ageing network over the years ahead.
The NIE Networks Board of Directors was fully engaged in the design, development and preparation of the business plan. It met regularly during the development of the plan to lead and provide strategic direction to management, and to scrutinise and inform NIE Networks' proposals. Directors supplemented formal board meetings with frequent meetings with the management team and subject matter experts. The final business plan was reviewed and approved by the Board for submission to the UR.
The UR's DD
The overall level of engagement with the UR since NIE Networks submitted its plan in June 2016 has been positive, and a significant improvement from RP5. The UR established a process to lodge new queries with NIE Networks on a weekly basis, with the expectation of a ten working day turnaround for response by the company. More than 300 individual queries were raised across the eight month duration following the submission of NIE Networks' RP6 Business Plan in June 2016.
Where the UR did not fully understand NIE Networks' submission, NIE Networks sought to clarify, provide further information and explanations, often by means of face to face workshops, so that the UR is in a position to make a balanced judgement on the appropriate allowance or approach.
The UR published its DD for RP6 on 24 March 2017.
Notwithstanding the good level of engagement leading up to the DD, there are significant unjustified shortfalls in the DD allowances compared to NIE Networks' RP6 Business Plan.
The scale of these shortfalls is such as to give cause for very significant concern on the part of NIE Networks' Board of Directors. Under the DD, NIE Networks would be compelled to expend more than the allowances the DD envisages for the same scope, with resultant unfair detriment to NIE Networks' financial position and credit rating and adverse impact on the financial position of the shareholder. The aim of the Response therefore is to explain where these shortfalls arise and the errors in the DD which have led to these shortfalls. NIE Networks also identify areas where further engagement is required to clarify the allowances and price control mechanisms that will apply.
NIE Networks hopes that it can work closely with the UR as it prepares the Final Determination so that these issues are addressed by way of a mutually acceptable outcome.
The UR's revised timetable for the RP6 price control provides for the UR to publish its Final Determination on 28 June 2017, less than six weeks after the deadline for receipt of comments on the DD. It is important that the UR gives full consideration to the very significant concerns raised in this response within the tight timescale prior to the publication of the Final Determination.
In Summary - NIE Networks' concerns with the DD
The DD follows the same basic building blocks used by Ofgem in setting Great Britain ("GB") electricity price controls, except for market operations, an activity that is not carried on by the GB Distribution Network Operators ("DNOs"). The core building blocks are:
- Direct capex
- Indirect Costs and Inspections, Maintenance, Faults & Tree Cutting ("IMFT")
- Non-Network IT
- Market Operations
- Real Price Effects ("RPEs") and productivity
- Pensions and Rates
- Financeability and WACC
There are significant shortfalls in the DD allowances compared to NIE Networks' RP6 Business Plan.
A high level summary of the key issues is provided in the remainder of this Executive Summary. The detail is provided in Chapters 3 to 12 below.
1. Direct capex (Chapter 3)
There has been significant engagement with the UR on direct capex. There is agreement on many aspects of the plan, including on the need for major transmission asset replacement and the majority of the distribution asset replacement. However, there are shortfalls in the allowances proposed by the UR in the DD. These are primarily in the unit costs allowed for the work. The UR's errors in its approach to unit costs allowances arise from its failure to give sufficient consideration, across a number of capex areas, to the nature and scope of the work and the latest available RP5 outturn information as well as its reliance on inappropriate data sources. Further, there are errors related to UR's approach to setting allowances related to Electricity Safety, Quality and Continuity (Northern Ireland) Regulations 2012. The aggregate value of these shortfalls is £21.1 million compared to NIE Networks' revised proposals put forward in this Response. There is also a shortfall of £2.5 million in respect of the proposed allowance for severe weather events. The detailed explanation of these shortfalls is within Chapter 3 below and accompanying Annex 3.1 which should be read together. In summary, NIE Networks considers that the UR has no proper basis for these disallowances.
NIE Networks also addresses a number of issues relating to the structure of the price control and other issues associated with the UR's approach to provisionally determining direct capex allowances. In particular, the UR has agreed in principle that investment is required to address the low carbon transition and innovation, which are new cost categories. Unfortunately, the allowances proposed by the UR are inadequate and will not allow NIE Networks to address the changing demands customers are placing on the network. In addition, the requirements and conditions attached to proposed innovation projects are unreasonable and there is an inadequate allowance and price control mechanism to cater for low carbon technology growth.
NIE Networks hopes that the remaining issues identified in this Response can be resolved so that it has fair and reasonable allowances to complete the programme of work required.
2. Optional Investments and Stakeholder Engagement (Chapter 4)
As part of the development of its RP6 Business Plan, NIE Networks sought to understand the views and opinions of its stakeholders regarding the type and level of service they expect, and the prioritisation of delivery of these services within reasonable funding limits. This included establishing the Consumer Engagement Advisory Panel which comprised NIE Networks and representatives from the UR, the Consumer Council for Northern Ireland and the Department for the Economy.
Arising from the customer and stakeholder engagement exercise, a number of investment options were identified which would enhance the resilience of the network to severe weather and improve the quality of service for worst served customers. The options include:
- investment to strengthen the 11 kV overhead line network, costing £25.6 million;
- additional investment to increase flood defences, costing £2.6 million;
- accelerated tree cutting, costing £0.7 million; and
- investment to reduce the frequency and duration of unplanned power cuts with an emphasis on worst served customers, costing £16.5 million.
NIE Networks is disappointed that, in the DD, the UR has not considered these projects in any detail. In particular, NIE Networks' RP6 Business Plan highlighted the vulnerability of the 11kV overhead line network to ice accretion when weather conditions are extreme. The impact of ice accretion events on homes and businesses can be significant. For example, the time required to restore supplies to all affected customers after such an event may be of the order of a week or longer depending on the area affected. The impact of widespread power cuts like these is often felt not just by domestic customers but also by businesses in the worst affected areas. This can have a knock-on effect on the local economy.
The most vulnerable parts of the network are the high ground areas in South Down, on the Antrim Plateau and in the Sperrin Mountains. NIE Networks' RP6 Business Plan proposed strengthening the network in these vulnerable areas over a 15 year period. Exclusion of this investment, as proposed in the DD, would not allow NIE Networks to improve the resilience of network in these rural areas. Appropriate investment would be required to address the reliability of the network to severe weather in advance of the introduction of any changes to the Guaranteed Standards of Service ("GSS") regime for severe weather.
In addition, the UR has failed to propose an adequate allowance to fund the enhanced programme of stakeholder engagement put forward by NIE Networks to seek to satisfy the UR's requirement that NIE Networks adopt a stakeholder engagement programme in line with GB DNOs. NIE Networks submits that such an allowance should be made during RP6 (or, alternatively, a lesser programme of stakeholder engagement should be agreed that can be funded from NIE Networks' existing allowances).
3. Indirects and IMFT (Chapter 5)
In preparing its RP6 Business Plan, NIE Networks commissioned economic advisors, NERA, to complete cost benchmarking studies using the approach adopted by Ofgem for the most recent price control for GB DNOs. NERA also benchmarked NIE Networks using the models selected by the Competition Commission, now the Competition and Markets Authority ("CMA") for RP5. Those studies demonstrate that NIE Networks is among the most efficient DNOs in the UK.
In its DD, the UR has departed from the benchmarking approach adopted by Ofgem and uses bespoke benchmarking models to determine a 2% efficiency gap. There is no basis in principle for the UR to adopt this approach and the outcome for NIE Networks is irrational. The DD fails to give due consideration to NIE Networks' benchmarking submission. Specific errors in UR's modelling include:
- the incorrect inclusion of indirects costs for connections, incorrect treatment of wayleave payments and an inappropriate regional wage adjustment;
- a failure to account for any change in efficient Indirects and IMFT costs due to changes in the volume of required work, for reasons such as growth in NIE Networks' allowed capital programme, new regulations or the cost of meeting higher standards; and
- basing the RP6 allowances on forecast data for 2015/16 rather than actual data. NIE Networks proposes the baseline should be set by reference to the average of four years' historical data.
NIE Networks also seeks clarification regarding the treatment of indirect costs for D5 projects.
The aggregate value of the shortfall on Indirects and IMFT is £49.3 million.
The UR's analysis excludes the indirect costs associated with innovation projects which forms part of the shortfall in the direct capex allowance referred to above.
4. Non-network IT (Chapter 6 and Chapter 5, Section 5)
The DD proposes to disallow a number of IT projects set to deliver benefits during RP6 and future price controls. The projects which have been disallowed include:
- a robust IT system for Regulatory Instructions and Guidance ("RIGs") reporting, which would have clear benefits for customers to improve transparency and robustness of reporting;
- a condition-based risk management system which would be used to optimise asset investment decisions over the long term. This system has become the industry standard in GB for reporting health and criticality indices which the DD now requires from NIE Networks during RP6; and
- basic time recording systems that would help us to optimise the planning of staff to deliver an efficient service for customers.
In disallowing these projects in the DD, the UR is systematically and irrationally disadvantaging NIE Networks when compared to GB DNOs, the companies NIE Networks is benchmarked against. The UR should adopt a balanced approach and allow these projects in the Final Determination, enabling NIE Networks to deliver value for customers and providing a level playing field between NIE Networks and the GB DNOs. The aggregate value of the shortfalls in non-network IT capex is £8.9 million.
The UR also proposes to include non-network IT opex within the scope of aggregate benchmarking for Indirects and IMFT costs. In adopting this approach, the UR has effectively failed to provide a discrete ex-ante allowance for some cost line items that are not included in the benchmarking analysis.
As regards metering data and registration services costs, the UR has failed to take into account the insourcing of business process outsourcing staff from Capita during RP5 when assessing manpower levels for RP6. This results in a shortfall in the proposed allowances of £1.7 million. There is also an incorrect assumption that £1.7 million of IT savings will be achieved with the managed service re-procurement. The actual costs from the procurement process are now available and were provided to UR. NIE Networks expects that the UR will correct these errors in the Final Determination.
5. Market Operations (Chapter 7)
NIE Networks' market operations activities relate to meter installation and certification services, meter reading and the provision of metering data and registration services to support the operation of the retail and wholesale electricity markets. This includes operation and management of major IT systems that are central to enabling wholesale and retail market competition.
The allowances proposed in the DD are insufficient to finance these activities. The UR has failed to recognise relevant trends in historic costs and market developments and has disallowed new costs. In particular:
- as regards direct metering capex, the UR has failed to recognise that RP6 recertification unit costs are directly comparable with RP5 certification unit costs;
- in addition, the UR has failed to have regard to the challenges NIE Networks faces in satisfying the unique meter type demands of the NI market and the associated impact that this has on its costs; and
- as regards indirect metering costs, the UR's comparison of data is not on a 'like for like' basis and no allowance has been made for new costs including incremental meter reading due to annual customer growth, the requirement for meter inspectors and incremental IT costs associated with RP6 IT capex projects.
The UR also does not take into account the significant benefits that would accrue to customers as a result of NIE Networks' proposed enhanced revenue protection incentive. In addition, as noted above in Section 4, there is also a shortfall in the proposed IT allowances for metering data and registration services costs.
The aggregate value of the shortfall in market operations costs is £14.0 million (including £3.4 million in respect of metering data and registration services costs).
NIE Networks believes that there is no objective justification for these proposed cost reductions and requests that they are allowed in full to enable NIE Networks to recover the costs of operating this part of the business.
6. RPEs and Productivity (Chapter 8)
In relation to RPEs, contrary to the approach adopted by Ofgem, the UR fails to take proper account of evidence that specialist electrical engineering staff, an important element of NIE Networks' workforce, have experienced wage inflation markedly higher than the economy as a whole. This is driven by high demand for specialist labour combined with a shortage of supply.
At RP5 the CMA's decision not to make a distinction between specialist and general labour followed its concerns regarding the accuracy of the distinction between the two categories. The CMA did not question evidence submitted both by NIE Networks and the UR that certain specialist labour indices for the electrical engineering sector grow faster than average wages in the private sector as a whole.
Since the CMA's RP5 Final Determination, NIE Networks has undertaken a detailed review of its workforce, assessing person by person and role by role whether they meet the criteria necessary to belong to the specialised indices relevant to the electrical engineering segment of the labour market. Based on this detailed assessment, NIE Networks found that 77% of its workforce can be classified as "specialist". This evidence was submitted to the UR on 10 March 2017 and should be considered by the UR in the preparation of its Final Determination.
In addition to NIE Networks' own work since the RP5 determination, Ofgem has completed its own RIIO-ED1 review, and concluded it is appropriate to place a 77% weight on these specialised electrical engineering wage indices when setting labour RPEs.
Based on the above, the UR should review the economic case for a premium when setting an allowed RPE for electrical engineering labour at RP6, in light of new evidence that has come to light since the conclusion of the RP5 process. Essentially, there is now clear evidence that wages relevant to NIE Networks' workforce have been rising more quickly that the economy-wide average relied on by the UR.
The UR's analysis in respect of materials and plant and equipment RPEs is also unjustified and inconsistent with the approach adopted by Ofgem at RIIO-ED1. The aggregate value of this shortfall in relation to RPEs is circa.£30 million.
The DD proposes a productivity factor of 1% per annum whereas the evidence points to long term productivity trends of 0.7% per annum. These long term trends have been widely used by regulators when setting efficiency targets for utilities, including the CMA at RP5 and Ofgem at RIIO-GD1/T1.
NIE Networks considers that it would be able to deliver on a 0.7% productivity factor if the Final Determination provided a balanced and reasonable outcome on allowances for the efficiency-driving projects proposed in its RP6 business plan. That would mean a 5.6% productivity improvement by the end of RP6 (31 March 2024) compared to the 2015/16 base year. However, NIE Networks cannot deliver this very challenging productivity improvement absent investment in efficiency-driving projects (which the UR has provisionally disallowed).
7. Reliability Incentive and GSS (Chapter 9)
The UR has proposed an incentive / penalty regime for network performance that would reward the company with c.£2.6 million per annum (plus or minus 1.5% of annual revenue) if a stretching target was achieved in full. Achieving a portion of this incentive would be very challenging to achieve and would require investment by NIE Networks. The calibration of this incentive is important to ensure that it is symmetric. It is still under discussion with UR and our detailed comments are set out in Chapter 9.
The UR has recently proposed a convergence with GB GSS for customers. The timing of the UR's review is problematic and is out of step with the RP6 price control process. NIE Networks developed its business plan for RP6 with regard to the existing GSS regime. There was no mention in the UR's Final Overall Approach document to RP6 of a review of GSS and the potential impact it might have during the price control. Therefore, NIE Networks has not been given the opportunity, in preparing and submitting its business plan, to take account of this potential material change to the GSS regime.
The GSS in NI and GB are broadly the same except for the length of time allowed to restore supplies after a fault (during normal weather conditions and during severe weather conditions). Out of a total of 14 standards, 11 are the same.
In relation to the supply restoration standards, it is important to note that over the last two price control periods the GB DNOs have had funding available to them of around £1.1bn to invest in improving network performance. No such funding has been provided historically in NI. By way of comparison, on a per customer basis, the £1.1bn figure in GB would equate to around £32 million of funding in NI.
NIE Networks has proposed an improved restoration time for customers in the event of a fault under normal weather conditions. This will tighten the restoration time from 24 hours to 18 hours. NIE Networks will continue to work with the UR on the timing of the implementation of this improvement.
In the case of severe weather, NIE Networks does not consider it reasonable to impose a GB standard without allowing appropriate levels of additional investment on the network and without allowing a reasonable lead time in advance of the change to allow this investment to take place. Investment in the 11 kV network, which was included as an Optional Investment, is considered in Section 2 above.
8. Pensions and Rates (Chapter 11)
The proposed allowance in respect of pensions is in line with NIE Networks' RP6 submission and is therefore acceptable to NIE Networks. Further discussion is required with the UR to address the concerns identified by NIE Networks relating to the Pension Monitoring Framework within which the RP6 pension allowances may be reviewed in line with principles adopted by Ofgem.
As regards rates, the UR has advised that it has not completed its analysis of rates and will require further information before the Final Determination. NIE Networks' rates currently account for c.10% of NIE Networks costs and, based on current charges, could amount to over £120 million during RP6.
NIE Networks' view is that the appropriate regulatory treatment is that rates should be allowed as pass-through on the basis that the rates liability is uncontrollable, in line with the approach adopted by Ofgem. The CMA RP5 Determination stated that the Ofgem approach would not be suitable for NIE Networks because of the "unique nature of NIE's rates revaluation process". However, this is no longer the case. The basis for setting NIE Networks' rates has changed since the CMA's RP5 Determination. The Land and Property Services changed its approach in the 2015 valuation from one specified by the Department of Finance and Personnel to a "conventional" assessment based on forecast income and expenditure. This change in approach followed the GB DNOs and National Grid, the transmission network operator who moved to conventional assessment in 2005. Therefore, since the valuation approach is now the same in GB and NI, there is no reason therefore why the regulatory treatment should be different in NI.
Given the materiality of NIE Networks' rates liabilities, small percentage changes in the rates charges can make a very material difference and it is important that an appropriate regulatory mechanism is adopted. NIE Networks is not seeking to gain from a different treatment of this cost - NIE Networks is simply seeking to avoid an unjustified economic loss or gain.
9. Financeability (Chapter 12)
NIE Networks has serious concerns with the UR's approach to assessing financeability, because it is inadequate and is not fit for the purpose of assessing financeability.
NIE Networks proposes funding the RP6 plan through a combination of operating cash flows from revenue receipts, issue of new debt and retention of earnings as required. NIE Networks estimates that borrowings will increase to £950m by the end of RP6 and it will require £500m of new debt.
The UR is required under legislation to have regard to the need to secure that licence holders are able to finance their licence obligations and NIE Networks has a Licence Condition to maintain an investment grade rating which is a rating of BBB- or above (Fitch or Standard and Poor's).
GB and European regulatory precedent indicates that a strong investment grade credit rating of A- to BBB+ is appropriate for a high performing network operator. NIE Networks is currently rated BBB by Fitch and A- by Standard & Poor's on a standalone basis. Achievement of at least a standalone BBB+ credit rating with both Fitch and Standard & Poor's is important to:
- enable NIE Networks to compete effectively for new funding in the market;
- ensure NIE Networks has ongoing access to debt capital markets to efficiently finance infrastructure investment at interest rates that are competitive compared to those of its UK network peer companies; and
- create a buffer above the minimum investment grade rating to ensure that NIE Networks' access to finance is resilient from adverse macroeconomic and market shocks.
This is further supported by evidence from the current credit ratings of electricity network operators in the rest of the UK, the majority of which have comfortable investment grade credit ratings of A- to BBB+ or equivalent on a standalone basis.
The financeability test in the DD suggests that the UR is targeting a company credit rating of BBB+. We agree that a strong credit rating is very important to enable future efficient investment during RP6. However, the net result of UR's financeability assessment is that the proposed RP6 cash flows are inadequate to maintain the necessary credit metrics consistent with achieving a BBB+ credit rating from Fitch (who currently rate NIE Networks). For the credit rating metrics outlined in the UR's financeability test to be achieved, UR is making an unrealistic assumption that a significant equity injection would be required and no dividends could be paid during the RP6 period. In order to meet the financeability tests, the UR assumed a gearing level of 40% without proper justification. It has not considered the significantly higher gearing used by UK networks' regulators, nor NIE Networks' projected gearing level for RP6. The level of gearing assumed in the RIIO-ED1 price controls for GB DNOs was 65%, which is consistent with the expected efficient capital structure of a regulated network infrastructure company.
NIE Networks views this outcome as entirely unreasonable and that the UR has objectively failed to secure that NIE Networks is able to finance its licence obligations.
10. Weighted Average Cost of Capital ("WACC") (Chapter 12)
NIE Networks' WACC proposal of 4.08% (real, vanilla) is the weighted average of the cost of debt and the cost of equity that debt investors and equity investors expect from NIE Networks based on returns earned by comparable entities with similar business and financial risk profiles. It is a key driver of the financeability and credit rating of NIE Networks.
In the DD, the UR proposes a WACC of 3.29% (real, vanilla) compared to NIE Networks proposal of 4.08% (real, vanilla), resulting in a revenue and earnings shortfall of circa £105 million over the RP6 period.
NIE Networks, supported by Frontier Economics, has identified a number of serious deficiencies in the UR's approach to setting WACC, including:
- factual errors in interpretation of regulatory precedent;
- the use of selective market evidence and lack of consistency with relevant regulatory precedent, most notably that of the CMA RP5 Final Determination; and
- cherry picking proposals made by NIE Networks.
In particular, the UR's assumptions in respect of the risk parameters (asset and debt betas) and gearing which feed into the cost of equity are not supported by the consistent application of regulatory precedent and the latest market evidence.
There appears to be a trend in the draft WACC determination that regulatory precedent or the latest market evidence is followed when that leads to a reduction in allowed WACC but ignored or side-lined when it has the opposite effect.
The overall package proposed by the UR in the DD would result in very significant and unjustifiable shortfalls in the RP6 allowances. Under the proposals set out in the DD, NIE Networks would be compelled to expend more than the DD envisages, with resultant unfair detriment to NIE Networks' financial position and credit rating and adverse impact on the financial position of the shareholder.
A theme NIE Networks has identified throughout the DD is that regulatory precedent or the latest market evidence is followed when that leads to a reduction in allowances but ignored or side-lined when it has the opposite effect. The net result of this approach is an imbalanced and irrational application of regulatory precedent and the latest market evidence which has a significant detrimental and unacceptable impact on NIE Networks' financial position.
Given that the UR intends to publish its Final Determination on 28 June 2017, NIE Networks would welcome further engagement with the UR so as to reach a balanced final outcome which protects the interests of electricity customers and secures that NIE Networks is able to competitively and efficiently finance its regulated activities.
Contact for enquiries -
NIE Networks Corporate Communications
Telephone 0845 300 3556