"European internal electricity market for consumers - opportunities and barriers to cross-border trade between Germany and Austria"

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1 Brunekreeft, Brandstätt, Friedrichsen, R. Meyer, S. Meyer, Palovic "European internal electricity market for consumers - opportunities and barriers to cross-border trade between Germany and Austria" Final report Customer: Energie-Control Austria (E-Control), the electricity and gas regulator, and Ministry of Rural Affairs & Consumer Protection, State of Baden-Wuerttemberg May 2012 (translated September 2012)

2 Authors: Prof. Dr. Gert Brunekreeft Christine Brandstätt M.Sc. Dr. Nele Friedrichsen Dr. Roland Meyer Sabine Meyer M.A. Martin Palovic M.A. Contact: Maps by ESRI Prof. Dr. Gert Brunekreeft Bremer Energie Institut College Ring 2 / Research V Bremen Tel.: +49 (0) 421 / Fax: +49 (0) 421 /

3 Registers Table of contents Table of figures... 4 Table of quotations Background Objectives Methodology Content Market analysis Initial situation Consumer behaviour Market situation Market rules Perceived barriers Differences in balance group management Supplier switching processes Fixed electricity price components Partial integration of retail and network stages Strong position of local and regional suppliers Potential barriers Procurement and own generation capacities Different consumer contact models Differences in handling green power Differences in metrology Market behaviour Strategic orientation of the companies Defensive strategy Offensive strategy Innovative strategy Competitive situation Market equilibria Stabilising effects Conclusions Explanations of the figures Literature

4 Registers Table of figures Figure 1: Correlation between potential savings and switching... 9 Figure 2: Development of switching rates comparing selected European countries Figure 3: Development of margins in Germany Figure 4: Price comparison of local vs. cheapest supplier in Figure 5: Comparison of gross margins in selected European states Figure 6: Willingness to switch supplier of Dutch electricity and gas consumers Figure 7: Self-enforcing market equilibrium Table of quotations Quote 1: Limited consumer motivation to change supplier... 8 Quote 2: Switching inertia in favour of established suppliers... 8 Quote 3: Regional solidarity relevant for customer loyalty... 8 Quote 4: Price increases drive switching... 8 Quote 5: Switching in Germany Quote 6: End customer retail margins Quote 7: Additional effort due to balance group management Quote 8: Effort of supplier switching Quote 9: Fixed electricity price components Quote 10: Communication of price changes Quote 11: Competitive imbalance due to unbundling Quote 12: Political influence Quote 13: Procurement in Germany and Austria Quote 14: Own generation capacity as a marketing argument Quote 15: Defensive behaviour of communal utilities (Stadtwerke) Quote 16: Compensating for lost market share by acquiring new customers Quote 17: Critical mass for market entry Quote 18: Costs of acquiring new customers Quote 19: Supra-regional supply and the home market Quote 20: Competition as a reaction Quote 21: Supplier switching after price changes Quote 22: Future benefits of regional presence

5 Background 1 Background 1.1 Objectives The present study, entitled "European internal electricity market for consumers - opportunities and barriers to cross-border trade between Germany and Austria", aims to present synergy potential and opportunities for companies to provide electricity across borders, and identify problem areas in order to offer a basis for further international and national (regulatory) work. The study's main focus is on cross-border electricity retail activities between Germany and Austria in the household consumer segment; note that for the purpose of this study, the term consumers always refers to the consumer group "household consumers and micro-enterprises". 1.2 Methodology The present study is based on a comparison of the (legal) framework and market design in Germany and Austria. As a starting point for the study, E-Control and the Federal Network Agency provided a common report on these issues. Based on this theoretical assessment, we were able to derive evidence of potential barriers to market entry. These findings as well as additional considerations regarding the strategic behaviour of competing companies were incorporated into a questionnaire, which in turn was used between October 2011 and February 2012 to interview the managers of energy utility companies which could be, are or were active in cross-border trade. A total of 12 interviews took place, of which 9 in Germany and 3 in Austria. Given the high level of correspondence between the interviewees' core statements, no further company interviews were deemed necessary. As a result of the thematic focus on cross-border supply between Germany and Austria, we chose mainly companies oriented towards Southern Germany among the German ones. In addition, in selecting the companies care was taken to ensure a mix of the following company types: 1. New suppliers: often suppliers with an environmental and/or discount focus 2. Proactive companies: companies which aim to acquire new customers from other markets 3. Defensive companies: companies which concentrate on customer supply and retention within their established supply area 5

6 Background The Bremer Energie Institut (BEI) documented each interview in a summary of findings, which the interviewee subsequently confirmed and approved. Since the respondent group was too small for a reliable statistical analysis, the interview findings were assessed qualitatively. The BEI interpreted and analysed the interview findings using theoretical insights from country-specific literature on retail margins and on the stability of the various competitive strategies. 1.3 Content The study as presented here essentially investigates three topics: 1. The initial situation as regards margins, switching rates and potential savings for consumers in Europe, with a special focus on Germany and Austria; 2. Market rules in Germany and Austria, with a special focus on those rules and crossborder differences which constitute market barriers or opportunities and/or are perceived as such; 3. The market behaviour of companies in electricity retail markets in Germany and Austria, as well as the resulting competitive situation. The first section of the study describes the markets in Germany and Austria and assesses similarities and differences. Based on this, the second section evaluates the administrative, technical and structural conditions of market entry. The market barriers and synergy potential identified in the interviews can also serve as a basis for further activities in the fields of regulation and consumer protection. Last but not least, the third section examines strategic behaviour in the market, thereby attempting to explain the current competitive situation based on the interviews. This analysis also offers suggestions for further regulatory activities, especially with regard to the upcoming changes in the market. 6

7 2 Market analysis 2.1 Initial situation The Austrian regulatory authority's annual reports reveal that the last time that a foreign supplier (namely EnBW) independently offered electricity to Austrian consumers was in 2004 [E-Control 2006]. There have been no foreign suppliers in the residential segment in recent years. Expert interviews show that several other German companies considered the option of entering the Austrian market, and finally decided against it. However, cross-border activity leads to opportunities, both for German companies in Austria and vice versa. Use of the same language makes cross-border activity between Germany and Austria more attractive than between many other neighbouring countries. Market entry is further facilitated by continuously advancing liberalisation in both countries, e.g. compared to another German-speaking market, Switzerland. Austrian companies could therefore gain access to a new retail market, whose size is ten times that of their previous market; German companies are tempted by the possibility of supplying Austria in the same manner as they would with an additional federal state. Even though there are differences in the details of the market rules, which will be discussed more closely below, the regulatory framework has been largely harmonised. As a source of short-term supply, the spot market crosses borders, and there are many cross-border suppliers in the balancing market, especially from Austria to Germany. In the industrial consumer segment, many companies already benefit from these opportunities in cross-border consumer supply, but in the household consumer segment, institutional barriers and the limited attractiveness of the market prevent such opportunities from being used. Across the board, interviews and research create the impression that currently, economies of scale, switching rates and related margins in Austria and also Germany are too low to promote active competition in the end consumer market Consumer behaviour Consumers willingness to switch suppliers is fairly limited both in Germany and Austria, as shown by the figures presented in The interviews carried out for the present study assumed that electricity s lack of tangible appeal causes consumers to remain fairly inert. Consumers interest in optimising their electricity costs is accordingly viewed as generally fairly low. 7

8 A lack of interest in optimising electricity costs on the part of household customers is attributed to the relatively low importance of the electricity bill for their budgets. Quote 1: Limited consumer motivation to change supplier Undiscerning consumer behaviour in the energy segment also results in a type of resignation, e.g. the consumer is put off by the complexity of their electricity bills or by the fear of power outages, which is factually unjustified. The consulted experts think that this gives established suppliers an advantage. Customers who are not well informed and who wish to avoid worrying about energy supply stay with their default supplier. Quote 2: Switching inertia in favour of established suppliers Whereas competition is generally perceived as strongly price-driven, some consumers choose their suppliers according to factors other than price. These include local and regional value-adding activities by the supplier, the supplier's environmental awareness, the positive image of suppliers with a communal ownership structure as well as identification with the supplier's media choices and multipliers. Often, regional solidarity, for example because a relative or friend works for the company or because of sponsoring in the region, prevents a switch to a supra-regional supplier. Quote 3: Regional solidarity relevant for customer loyalty In addition, the consulted companies experience shows that private consumers do not normally switch supplier by themselves but only in the case of an external impetus, such as personal requests in direct sales or public media campaigns. Our biggest successes in acquisition have been due to competitor price increases, because these seem to drive switching. Quote 4: Price increases drive switching The companies assign much importance to media and consumer protection, especially in terms of the provision of general information and independent price comparisons for consumers, which they consider to have a large influence on supplier choices. For instance, the transition to alternative energy sources and nuclear power phase out attracted significantly more media interest in Germany than in Austria, and consequently had less of an impact on switching behaviour in Austria. 8

9 2.1.2 Market situation Figure 1 suggests a relationship between the actual switching rate and potential savings resulting from a change of supplier, and enables a comparison between selected European states for This gives the impression that the switching rate in Austria should be much higher given the potential for savings, i.e. compared to Denmark, Finland and the Netherlands. Figure 1: Correlation between potential savings and switching [VaasaETT 2011, p. 25] Figure 2 shows the development of selected European switching rates between 2006 and The switching rate in Austria is much lower than that of the front runner, the United Kingdom. In contrast to Austria, many countries can also boast a steady increase over the years. In 2010, the switching rates of the front runner countries seemed to settle at a level that was still comparatively high, but below the peak values of the previous years. By contrast, the upward trend in Austria and Germany has not yet been exhausted, so that in 2010, a significant increase could be recorded relative to the previous years. 9

10 Figure 2: Development of switching rates comparing selected European countries [Figure from Bremer Energie Institut for data sources see Chapter 4] Our interview responses also estimated switching rates to be low overall. In Austria, the proportion of consumers switching appears to be even lower than in Germany. According to the Federal Network Agency, there were 147 different electricity suppliers in Germany in 2010 [BNetzA 2011], and E-Control listed 15 country-wide suppliers at the start of 2012 [E-Control 2012]. The number of different tariffs available to consumers is roughly twice this number. As a result, switching rates are low not so much due to a lack of offers but rather due to insufficiently attractive offers and to customer reticence. By now (compared when deregulation started), customers in Germany have become more sensitised to switching options so that competition is starting to gain momentum. Quote 5: Switching in Germany The interviewed experts were nearly unanimous in their agreement that price levels and related margins, as well as potential savings due to a change of supplier, are low. In addition, it appears that margins are slightly lower in Austria than in Germany and within Austria lower in the west than in the east. End customer retail of electricity as a commodity generally has fairly narrow margins. Quote 6: End customer retail margins 10

11 The details provided by the Federal Network Agency also confirm that margins in the German end consumer retail market are low. However, as shown in Figure 3, there has been a slight but consistent increase over the past few years. Figure 3: Development of margins in Germany [BNetzA 2011, p. 35, in German] Assuming that the best bidder s price roughly corresponds to the procurement price, the difference between that price and the energy price in Figure 4 shows the margins in the different regions of Austria. Figure 4: Price comparison of local vs. cheapest supplier in 2010 in /year for 3500 kwh/year [E-Control 2010, p. 8, in German] 11

12 Considering the shared spot market, and using Figure 3 for comparison, similar procurement situations in both countries can be assumed. As a result, the mark-up added to procurement costs by some (but not all) Austrian companies may, to all intents and purposes, be considered comparable to retail costs including the margins in Germany shown in Figure 3. As shown in Figure 5, a selective comparison demonstrates that gross margins, i.e. energy prices less procurement and network costs and net of taxes and fees, average at significantly below 100 per customer per year. Figure 5: Comparison of gross margins in selected European states [Figure from Bremer Energie Institut, for data sources see Chapter 4] Germany and Austria are located mid-range. The rather low margins result in a limited pricing range for companies. Regarding Figure 5, one should note that the data are only comparable to a limited extent due to the partial discrepancy in reference years. What is significant here is less a direct comparison than the impression that unadjusted margins generally do not exceed 100 per customer per year. A look at the Netherlands shows the kind of savings that would be required to convince consumers to switch supplier. Figure 6 shows the results of a consumer survey on this topic. Cumulatively, only 18% of the consumers consulted in this survey stated that they would be willing to switch supplier for savings of less than 100 per year. Willingness to switch of up to 60% is reached only with potential savings of approx. 500 a year. In addition, there appears to be a significant group of consumers, i.e. approx. 40%, who would not consider switching supplier on the basis of potential savings but for whom other factors, as described in 2.1.1, serve as a basis for choosing their supplier. 12

13 Figure 6: Willingness to switch supplier of Dutch electricity and gas consumers [Moselle 2009, p.44] Insights into margin levels and willingness to switch therefore reveal that a new supplier offering a 100 incentive would only reach a small number of consumers, while significantly reducing its margins. 2.2 Market rules The limited attractiveness of the end consumer electricity retail market as documented in the interviews raises the question as to whether changes to the institutional framework, i.e. adjustments to the market rules, could facilitate market entry. It is possible to identify potential barriers to market entry, both cross-border and in general, by comparing the framework conditions in Germany and Austria. The interviews partially confirmed and added to these. Crucially, a few of the existing national market rules hinder market entry and restrict the sales volume to be expected in the new market. In addition, differences in the institutional and regulatory framework particularly result in higher costs for foreign suppliers and therefore limit economies of scale, and are thus often considered hindrances for cross-border electricity supply Perceived barriers Those structures which the interviews confirmed as barriers to market entry are presented below. 13

14 Differences in balance group management Balance group management rules vary in Germany and Austria, albeit only to a limited extent. Expert interviews showed that such differences hinder the companies' crossborder activities. It can therefore be assumed that an adjustment of these market rules could help cross-border market entry. Several German consumers in the Lake Constance area close to the border belong to an Austrian balancing group, and vice versa. Due to the additional complexity, supply to such consumers is left to companies experienced in the relevant balancing regime. Yet industrial consumers are supplied across state and balance group borders. It appears that the effort associated with setting up additional balance group management and/or joining an established foreign balance group carries less weight for more lucrative consumer groups. A customer base of between 5,000 and 10,000 would probably be required in order to make up for the effort of managing an additional balance group. Quote 7: Additional effort due to balance group management Supplier switching processes It is currently much easier to switch supplier in the end consumer segment in Germany than it is in Austria. This is mainly due to the fact that it is not (yet) possible in Austria to conclude an agreement for the supply of electricity to consumers online. While the price comparison tool "Tarifkalkulator" on the E-Control website allows for an automated and simple search for the cheapest supplier, and while it is also possible to prepare a contract agreement online, unlike in Germany, a handwritten signed contract must still be sent as a final step. It is common practice in both countries for the future supplier to process the supplier switch for the new customer. The exact processes required in Austria have been less standardised, making errors more likely. For instance, it seems that consumers in Austria must provide more detailed data than in Germany. In particular, suppliers in Austria normally ask consumers to state the 33-digit meter point administration number in order to simplify processing with the current supplier, which however decisively increases consumer effort and naturally constitutes a significant source of errors. An average of 2-3 calls to the customer are required during the switching process. Quote 8: Effort of supplier switching A reorganisation of supplier switching processes is currently under way in Austria and will result in a wide-ranging automation of the process. This would then significantly 14

15 simplify switching to another supplier, making the market more attractive for new suppliers. In view of this reorganisation, an extensive harmonisation of the processes would be desirable for cross-border suppliers in the end consumer segment. In addition to the potential obstacles that stem from Austrian market rules, cross-border differences in switching processes bear the risk that suppliers might be deterred by the effort involved in becoming familiar with the new processes Fixed electricity price components The increasingly complex collection and subsequent forwarding of electricity price components that cannot be influenced constitutes an ever greater strain on electricity suppliers. Suppliers in both Germany and Austria collect quantity-dependent energyrelated taxes and allocated costs with their electricity bill. In Germany, suppliers must additionally collect network charges and pass these on to the relevant network operator. This is not mandatory in Austria, but most suppliers nonetheless offer a joint bill for energy and network use. Only 33% of the end customer price can be influenced by retail. Quote 9: Fixed electricity price components Beyond this unpaid additional effort, frequent adjustments to the fixed components of the electricity price make customer retention more difficult. They result in price changes for the end consumer, which often lead to supplier switching. It is worth noting the consulted experts' unanimous view that price increases, as well as price reductions, trigger active switching on the part of the affected consumers. It is often difficult for companies to explain such price adjustments to consumers, and media reports are frequently biased. Private customers are often unable to understand the reasons for price changes. Quote 10: Communication of price changes The complex nature of electricity bills is directly related to this. The information that bills must contain is indeed similar in Germany and Austria, and the industry also boasts many good examples of clarity and comprehensibility. Nevertheless, studies repeatedly show that consumers struggle with their bills and are unable to understand for example the relation between the energy price and the additional fees and charges Partial integration of retail and network stages The interviews also revealed that the partial integration of retail activities and network operation makes market entry less attractive for foreign companies. In 2008, the Austrian regulatory authority stated that the lack of unbundling provided local suppliers 15

16 with significant competitive advantages. [E-Control, 2008, p. 21] Organisational and personal links as well as insufficient and/or non-existent data management concepts are offered as the main reasons. In Germany too, independent suppliers lament the competitive imbalance of companies which are not affected by unbundling provisions due to the de minimis rule. In the case of online switching in Austria, network operators (which are not fully unbundled) insist on identification by signature. Quote 11: Competitive imbalance due to unbundling The determination of network charges at comparatively short notice is the reason for a particular imbalance in Germany. Those suppliers integrated with network operation are able to internalise the resulting uncertainty. For them, network charges are merely moved between two departments of the same company. By contrast, independent suppliers have no hedge against unexpectedly high network charges or retroactive adjustments Strong position of local and regional suppliers Market entry is also made less attractive for new and foreign companies because of the already strong position of established local and regional suppliers. On the one hand, some of these suppliers are subject to strong political influence and on the other hand they are able to establish a good position thanks to their regional proximity to their customers. Public sector links can be formal, e.g. via direct involvement in management or the supervisory board, or indirect, e.g. via mutual dependencies. In the eyes of the experts we consulted, political influence often means that purely economic considerations take a back seat in decision-making. Especially the prices paid by consumers are often kept low as a result of political pressure, even though price increases would be advisable from an economic standpoint. In the last few years, Germany has experienced a kind of 'irrational competition', involving participants who are 'refusing to calculate'. Quote 12: Political influence In addition, local and regional suppliers have access to numerous opportunities to retain customers which are not available to supra-regional, independent suppliers, or at least not to the same extent. Examples of such marketing activities with added local value could be gathered from the interviews. They involve, e.g, 16

17 sponsorships of local sports clubs and events, image cultivation using local multipliers, i.e. regional celebrities but also employees of the company, or opportunities for intensive support and interaction in local customer centres Potential barriers Some framework conditions appear to be barriers to market entry from a theoretical perspective, but they are not (yet) perceived as such in practice. Once cross-border activities intensify, it can be expected that they will gain in importance from the companies point of view Procurement and own generation capacities In the interviews, electricity procurement was not considered a barrier to market entry in Austria or Germany, even across borders. According to the experts' statements, electricity is largely procured on the common wholesale market or via traders. The example of the United Kingdom has highlighted the importance of own generation capacities as a hedge against illiquid markets and price fluctuations. However, the spot and futures markets in Germany and Austria are viewed as sufficiently liquid for own generation capacities to provide no competitive advantage in the form of lower procurement costs or a reduced procurement risk. A comparison of the auction mechanisms reveals possible difficulties for intraday trading because market clearing times between Germany and Austria are not fully harmonised; however, the consulted experts did not mention these. In addition, even companies with own generation capacities stated that they used these to obtain profits on the wholesale markets rather than to supply consumers directly. Cross-border procurement does not pose any problems. Quote 13: Procurement in Germany and Austria Nevertheless, the expert survey revealed that companies employ their own generation capacities beneficially in marketing and consumer communication. Especially in the green power segment, own generation capacities create consumer trust, even if the electricity produced in this way is not sold directly to the consumer but on the market. Own generation capacities strengthen the company's credibility. Quote 14: Own generation capacity as a marketing argument 17

18 Different consumer contact models Consumer contact for electricity supply varies strongly between Germany and Austria. German consumers conclude only one contract with the electricity supplier (singlecontact model). The electricity supplier is an intermediary and interacts with the network operator in the background. In Austria, on the other hand, consumers conclude contracts with both the network operator and the energy supplier (dual-contact model). In the case of power outages or if the consumer moves house, both market participants might have to be contacted. However, consumers can, and often do, authorise the supplier to also collect network charges. Even though this issue was rarely mentioned during the interviews, especially the single-contact model could constitute barriers to market entry for new suppliers. For instance, German electricity suppliers find it more difficult to offer their product across the whole federal area because in a new network area (from the supplier's point of view), agreements with the relevant network operator must be arranged before even a single consumer can be supplied. Increased standardisation of the interaction between supplier and network operator might facilitate this step. New companies on the Austrian market suffer competitive disadvantages if consumers are charged by the established company not only for electricity but also for network use. In such a case, supplier switching would mean that the consumer would receive two separate bills in the future. In addition, many consumers using their established company's services do not realise that they actually have two separate contracts. Supplier switching would thus increase complexity from the consumer s point of view Differences in handling green power The green power segment is gaining in importance, especially for household consumers. Some formal differences could be identified between Germany and Austria, but the experts did not mention these as barriers to cross-border market entry. For instance, market rules vary regarding financial support and subsequent transfer of electricity from renewable energy sources. The requirements for certification of electricity from renewable sources are also not consistent. Nonetheless, most consulted companies offer special green power products. According to the experts, consumers are rarely aware of the sometimes significant difference in product quality. In spite of this, it is often difficult for companies which also offer electricity from conventional sources or which might even have a strong focus on conventional generation in other company departments to establish themselves as suppliers of green power. 18

19 Differences in metrology Clear formal differences between Germany and Austria apply in the area of electricity metrology. Whereas in Austria, network operators are responsible for measuring consumer energy usage and for passing on these data, commissioning third parties to carry out these activities is possible in Germany as part of the liberalisation of metrology. The survey demonstrated that this difference barely affects retail activities. In addition, metrology is not generally considered a starting point for innovation in electricity retail activities. Many interviewees were rather sceptical of the development of smart meters, and even companies active in the field of smart grids believed that the potential lies in company divisions other than retail activities. 2.3 Market behaviour On the one hand, this study holds an unfavourable initial situation with low attractiveness of electricity retail activities to household consumers as an independent business model and with a number of structural obstacles for potential new market participants liable for the limited interest in cross-border retail activities. On the other hand, the study also aims at assessing market behaviour, i.e. the companies' strategic focus and the resulting competitive situation, in order to explain the situation Strategic orientation of the companies It is possible to differentiate between the following strategies based on the interviews and the individual companies' behaviour on the market. The activities of companies with a defensive strategy primarily focus on maintaining their existing market share. By contrast, companies with an offensive strategy try to acquire new customers with varying intensity. o A passively offensive strategy merely tries to compensate for any lost customers with the minimum of effort. o A proactively offensive strategy, on the other hand, exerts much pressure and attaches much importance to gaining new customers, with the aim of setting up a new client base. Companies employing an innovative strategy position themselves in a market niche away from companies offering standardised electricity; e.g. they acquire customers for green power or energy-related services. Below, the individual strategies are presented in more detail and their consequences for competition are assessed. 19

20 Defensive strategy Companies with a local or regional focus (the majority of German and Austrian companies) mainly pursue a defensive strategy, focusing their activities on defending their local market. Such companies achieve customer retention by, for example, offering high-quality support and advisory services or local added value for consumers. For regional suppliers and companies with close links to regional politics and media, market share in their area is often more important than optimised margins. Communal utilities (Stadtwerke) cannot stand up to pricing competition. They are traditional full-service companies with a reputation of high service quality for citizens. In their own interest, they should not give up this competitive advantage. Quote 15: Defensive behaviour of communal utilities (Stadtwerke) If they hold a sufficient market share, e.g. as the main supplier of a region, these companies normally remain profitable in spite of their relatively low margins. This is the easiest and most convenient strategy for established suppliers. It is only when market share starts to dwindle because too many established customers are switching to competitors that these companies are forced to apply an offensive strategy Offensive strategy In addition to defending their customer base, electricity suppliers with an offensive strategy consistently try to acquire new customers. Passively offensive companies Originally defensive companies which have been forced to become offensive primarily employ customer acquisition in order to stock up the company's market share at a low cost. Customer acquisition outside the home market is usually carried out with only a limited marketing effort, e.g. using online advertising, and does not necessarily cover the entire federal area. New customers must be acquired in order to stabilise the company in a shrinking home market. Quote 16: Compensating for lost market share by acquiring new customers Often, it is not possible to offer the same high-quality services and price as in the home market to new customers outside the established supply area. As a result, many of the companies we consulted have set up a second brand with a different focus for the supra-regional market. If low prices are used to attract new customers to this second brand, tensions with the home market can result. It is often difficult to explain to existing customers that the company offers cheaper services outside the region. 20

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