Subject: Comments Re: File No. S7-30-99

    
     
     
February 3, 2000
     
Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth St., NW
Washington, D.C. 20549-0609
     
Ref.:  File No. S7-30-99, Registered Public-Utility Holding Companies and 
Internationalization
     
Dear Mr. Katz:
     
The European-American Business Council (EABC) would like to respond to the 
SEC's request for comments in the Federal Register on issues surrounding the 
acquisition of US utilities by foreign companies.  As an alliance of 85 US and 
European companies, the EABC is committed to open markets and the principle of 
national treatment on both sides of the Atlantic.
     
The EABC believes that allowing foreign ownership of US utilities will offer US 
consumers and businesses the benefits of greater competition -- lower costs, 
greater efficiency, and improved services.  We applaud the recent decisions by 
federal and state regulators to approve ScottishPower's acquisition of 
PacifiCorp. Because energy is a basic infrastructure requirement of every firm, 
actions that lower energy costs make businesses in the US more competitive 
vis-a-vis operations based overseas.  This is especially true for large 
industrial users of energy that employ millions of Americans.  
     
Further, restricting foreign ownership could result in retaliation by other 
governments in nations where US companies would like to invest.  Restricting 
foreign ownership also could subject the US to challenge under its 
international commitments to provide "national treatment," i.e., treatment no 
less favorable than that extended to domestic companies.  At a time when the 
European Union is working to deregulate and bring competition to its energy 
markets (e.g. the 1997 EU Electricity Directive), the US should continue its 
efforts to foster a dynamic and competitive market at home.  Foreign ownership 
is an important piece of that puzzle.
     
Thank you for your consideration of our views.
     
Sincerely,
     
     
Willard M. Berry
President
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Jim Sheire
Government Affairs Representative
European-American Business Council
1333 H St. NW
Suite 630
Washington, D.C. 20005
V: 202-347-9292
F: 202-628-5498