While most monopoly utilities are private operators many cities still retain public ownership of their key infrastructures. In energy policy, the US does not have national laws that constitute a competitive national wholesale and retail market model. Instead energy policy is largely left to individual states and policies can differ between cities even within the same state. In Texas, for example, although policy makers claim they have one of the most deregulated energy markets in the world several cities (such as Austin and San Antonio) still have energy and water utilities publicly owned by the cities themselves. California largely operates a competitive market system while cities elsewhere may use investor-owned-utilities operating under a monopoly contract.

For many infrastructures, the federal government sets national regulatory standards to be met and provides funds (grants and loans) for their policies to be carried out. The choice of how to meet the standards and regulations is largely left to the individual states and local authorities. The federal government cannot force its policies on unwilling state authorities. Instead it acts as an incentivising state with a carrot (loans, direct grants) and stick (regulations, financial penalties) approach. Examples include the Transportation Investment Generating Economic Recovery (TIGER) federal discretionary grant program which can be used for local public transportation schemes. Similar programmes exist for energy (such as the Department of Energy’s State Energy Program (SEP) to encourage states to contribute to national energy goals and the Energy Efficiency and Conservation Block Grant (EECBG) to manage energy efficiency and conservation. Direct central government intervention in state or city matters is unlikely. While a key Reaganite approach in the 1980s was to deregulate the telecommunications industry and promote competition in local state markets, nearly half the states (23) refused to change their rates or allow for any form of competition (Teske, 1991). Today many cities manage their own cable and telecommunication companies under the PUC remit.

In reality the “design at the national level allows for a huge range of choice among the states, and that this potential for choice is being exercised” (O’Toole, 1996: 241). One problem with this approach is that projects can be configured to spend available funds rather than to meet long-term public needs (Miller et al., 2000). It can however utilise the locally-produced decision-making capacity in place in many states and cities, provided by the highly professionalised class of city managers that have evolved from a century of reform in municipal education and civil service. Civil service, once seen as a stepping stone for ambitious politicians, can now be a long-lasting and well-rewarded career in many US cities. While this may have reduced democratic accountability, it has led to decisions being taken based on efficiency, performance standards and professional norms. This has, however, led to “policy making in general [being] a relatively slow moving process, with decisive action difficult to accomplish, and with much of the policy initiative displayed, not by elected officials, but by prominent community groups, business firms, other governments, or the city manager” (Clingermayer and Feiock, 2001: 11). The advantage of this system is that educated and knowledgeable actors can innovate and experiment in their own areas of expertise. Yet the ideal of honesty, impartiality and efficiency within the civil service can favour procedure over substance. Democratic principles of citizen input can be bypassed and actors are often insulated from public opinion. It has also created an “agency-based decentralization of political power, duplication of services, red tape and a concern for self-preservation” (Gluck and Meister, 1979: 116). The National Municipal League promotes good local governance through its Model City Charter, with the council-manager (administrative) form of local government as the ideal. Again, however, local communities are recommended to adopt whichever form of local governance they wish. There is no central diktat as to what should be applied. As Wheeland et al. (2014) outline, the “political situations and motivations idiosyncratic to individual localities have also been identified as playing an important role in institutional selection and change” (Wheeland, Palus and Wood, 2014: 14).

What these factors lead to is a fragmented structure of governance with the locus of power residing at the state level. The federal government is restricted to an incentivizing role in nudging states and cities towards centrally-favourable policy directions. Policy can be slow to react to events, radical changes can be difficult to implement, and states and cities are free to follow a direction of their choosing, albeit by agreeing to abide by the regulatory authority ceded to central government. Cities themselves act in competition with each other to attract citizens and businesses, differentiating themselves from other cities by developing their own strengths, providing the necessary quality of life for residents and offering a mix of infrastructural provision models according to their own socio-political environment. The federal government acts as the neoliberal entrepreneurial state in helping cities identify their appropriate competitive advantage and to correcting market imperfections (Leitner and Sheppard, 2002: 500).

The enabling UK state

In many regards the United Kingdom is the classic variant of liberal market economies. The country is heavily reliant on competitive market relationships underpinned by common law and formal legal contracting; it adapts policies towards the individual citizen rather than a more diffuse conception of society; and it aggressively seeks to export its policies worldwide (Hancké, Rhodes and Thatcher, 2007). However, while the US can be described as an incentivising state, the UK acts an enabling state in that it is the private sector the central government seeks to engage, not its arm of local government. The UK is an exceptionally centralised nation given its size: London, and specifically Westminster, is where power lies within the unitarist UK state. In recent decades government policies have shifted from macroeconomic Keynesian goals to achieve full employment with activist fiscal policies in the post-war period to Thatcher-backed monetarism in the 1980s and 1990s. Today most areas of public policy revolve around the power of the market (Hall, 2001). The UK also has an adversarial nature of politics compared to the consensus-seeking model practices in continental Europe, with decision-making operating “between proposer and opposer, prosecution and defence, government and opposition, without much value being given to the positions between these poles” (Norton, 1993: 361). The Coalition government elected in 2010 – made up of the majority Conservatives and the minority Liberal Democrats – was the first coalition in decades.

A pluralist conception of the state, combined with a neoliberal emphasis on the creation and management of competitive markets, means the state does not have to “do everything or decide everything” (Lorrain, 2005: 244). The UK state is one of limited government with an emphasis on the primacy of the individual, especially in regards to the ability to conduct commerce (Loughlin and Aja, 2006).

The adversarial nature of UK governance extends to relations between central and local government. Local authorities have no general competencies enshrined in law but may perform only what is permitted by Parliament, which defines the ‘powers beyond which’ (ultra vires) they cannot go. (Loughlin, 2006). They have no independent rights and are creations of Parliamentary statutes. There is no binding statement of civil rights nor a codified system of checks and balances to prevent abuse of power. Instead the UK abides by the omnipotence of Parliament. The UK has an unwritten constitution of the ‘utmost flexibility’ that evolves through common case law and statutes can be changed by simple Parliamentarian majorities (Norton, 1993). Central government sees local authorities as nothing more than agencies created to deliver centrally-decided policies: there is no assumption that “local authorities have a right to act in the interests of their inhabitants unless they can quote legal justification or limit their ‘free’ expenditure to a low statutory level” (Norton, 1993: 356). The fact they can be abolished at will by central government makes them vulnerable and reluctant to implement policies which may antagonise national politicians: the Thatcher government’s abolition of the Greater London Council in 1986 is a prime example. It appears local and central civil servants “live in relatively separate worlds” with little understanding and interaction between them (De Jong and Haran, 2002). Unlike the US, cities and local authorities in the UK are weak, financially dependent on central government and often ignored as an effective place of policy implementation.

The recognition that local government should act as an all-purpose service provider reached its peak in the 1930s and has declined ever since. Local councils were relieved of their responsibility for electricity and gas supply in the 1940s and lost control over water supply, conservation and sewage in the 1970s. In the 1980s local government lost control of its housing stock and its flexibility to respond to economic depression. The neoliberal policies of Margaret Thatcher emphasised a minimal state based on grounds of individual personal choice and the maximisation of economic efficiency.

The UK has been criticised for deficiencies in its local government structure. In 1997 the Council of Europe passed a resolution that included UK in a list of countries that had “serious deficiencies in the practice of local democracy” along with Croatia, Bulgaria, Latvia, Moldova and Ukraine, criticising the replacement of local authorities with quasi-autonomous non-governmental organisations (QUANGOs) and centrally imposed limits on local expenditure (Loughlin, 2006). The UK structure also favours efficiency over democracy at the local level and citizens view local government primarily as a provider of services rather than a democratic forum where debate can take place.

In terms of infrastructure the Thatcherite policies of the 1980s and 1990s led to major shifts in how the UK networks were governed, away from the supply-side, Fordist-Keynesian practices of the 1960s and 1970s and towards neoliberal market reforms with an emphasis on competition and consumer choice. The ability of the government to push through its privatisation agenda was arguably due to the “central role of the ideologically determined government, the lack of major institutional barriers and the ability of the government to override societal opposition” (Bartle, 2002: 11). The 1980s and 1990s saw the dismantling of many state-owned infrastructural monopolies and competition introduced into the energy, telecommunications and railway sectors, while monopoly suppliers in water were transferred to the private sector.

Unlike the German principle of territorial infrastructural governance, the splintered nature of the UK landscape leads to an independent government regulator for each sector. Cross-subsidisation is seen as anti-competitive, intervention by elected politicians is viewed as leading to short-term decision-making and ‘fair and effective competition’ is paramount (Thatcher, 2007). The landscape is structured to shift power away from the producer and towards the consumer. Berg and Blake (2013) highlight three fundamental principles of the UK regulatory landscape: the rejection of rate-of-return regulation; the rejection of direct government control; and the rejection of monopoly provision. These principles form the basis of the RPI-X price cap regulation (the average retail price is allowed to increase alongside the retail price index, minus an X-factor to account for technology changes and productivity improvements) which is instrumental in the electricity, gas, telecommunications and water sectors (Berg and Blake, 2013).

North Sea gas reserves provided for a dash-for-gas in the 1990s and today gas meets around 70 per cent of all domestic, commercial and industrial heat demands (Arapostathis et al., 2013). This cheap supply of gas necessitated the integration of large nation-wide gas pipeline networks, while restricting the control local authorities could have over local heat demand. As a result, the amount of district heating networks in the UK is low and mainly found in hospitals, schools and universities. Local authorities lack the organisational capacity to develop district heating schemes and have traditionally not had a prominent role in energy planning (Bolton and Foxon, 2015).

Until the early 2000s the newly-privatised utilities prioritised reducing costs to the consumer over investment, leading to neglect in maintenance budgets. Regular price controls imposed by the regulator on the private operators have incentivised utilities to reduce their operating costs. However, there have been concerns raised over the quality of service delivered, including rises in outages and interruptions to supply (Bolton and Foxon, 2015). Similar price reduction strategies were introduced onto the railway network when it was privatised from the 1990s until the early 2000s, when a series of accidents revealed the problems in reducing maintenance budgets to keep consumer costs low. Similar concerns were raised in the water industry with criticism over pipe leakages.

In the 2000s a shift in policy aimed to introduce innovation into the networks, partly to account for the lack of historical investment in the ageing infrastructures, but also in a shift towards decarbonisation and the use of ‘smarter’ technologies – the UK has a target for an 80 per cent reduction in greenhouse gas emissions from 1990 levels by 2050. Similar to Germany the UK operates a feed-in tariff scheme (FiT) to boost its share of renewable energy sources – remuneration is paid above the retail or wholesale energy price for those who generate renewable energy sources. However, the UK also introduced a number of market-based decarbonisation projects. The Tradable Green Certificate (TGC) scheme launched in 2002 mandated generators to either earn green certificates by supplying a share of renewable energy to the national electricity market or to buy certificates on the open market from other suppliers. Renewable generators are issued with Renewables Obligation Certificates (ROCs) which can then be traded on the open market. It should be noted that the national nature of the UK energy market can act as a barrier for small-scale local generation schemes driven from community groups or local authorities.

In the UK it is central government that creates policy with an emphasis towards market creation and private provision of services. Local government is weak and often acts merely as an implementation arm of the UK state. The splintered nature of the UK state (Graham and Marvin, 2001), the strong central state and an emphasis on the primacy of markets and consumer choice makes it difficult for any meaningful form of infrastructural integration to occur. A number of small local schemes do exist, yet they struggle to compete with the large national utilities operating in most infrastructural sectors. While there have been moves towards devolution in recent years (Scotland, Wales and Northern Ireland have their own devolved powers) in infrastructural terms many city regions only have power to influence transport spending and economic skills development. The energy, water and telecommunications sectors are still largely the preserve of the large national private providers. These can often be vertically integrated and while several companies do operate within multiple sectors – for example Virgin operating in both the rail and healthcare sectors – this form of horizontal integration is rare. In recent years, there has been a shift towards technological innovation and a decarbonisation of the energy supply; however, the emphasis remains on sectoral efficiency and consumer experience.

The coordinated German State

Germany is the largest economy in Europe, the fourth largest economy by GDP worldwide and offers a working example of a mixed market economy: a strong public sector, powers split between the federal, state and municipal levels and a corporate, co-determinist and collaborative participatory economic model engaging workers and industry. Germany’s collectivist social model has led to the country being described as the ideal co-ordinated market economy (Hall and Soskice, 2001), the definition of a Continental European form of capitalism (Bolognesi, 2014) with a political economy of a contractual, interventionist state evolving from a 19th century culture of local service municipal provision (Lorrain, 2005). Economic life focuses on consensus-seeking and co-determination rather than the competitive and conflictual model practised in the UK and US. Trade unions have strong involvement in industry work councils which operate throughout the country; local authorities are strong and willing to intervene to solve perceived market failures; and local decision-making with strong forms of public participation remains a key feature to citizen democracy. The political economy is distinguished by a particular set of institutions that have created a ‘socially embedded capitalism’ that incorporates the market economy into the reaches of the state with a strong ethos of state-led social reform (Lehmburch, 2005). In describing Germany as a form of ‘cooperative federalism’ Bartle (2002) highlights the importance of “federalism, coalition government, a non-adversarial parliament and the active role of interest groups” (Bartle, 2002: 7). The federal constitution itself mandates to “ensure equal living conditions on the territory of the Republic” which has been interpreted as the foundation for Germany as a unitary federal state (Wollmann et al., 2010a). The strong links between industry, business and public infrastructure are arguably a result of the “social systems of innovation and production based on powerful public intervention by centralised bodies or local authorities” at work in the German state (Bolognesi, 2014).

Germany is a federal state with three interlinked governance levels. At the regional level are 16 states (Länder) each with their own constitution, parliamentary system of governance and administrative departments. At the national level is the Federal Cabinet (with the Chancellor and 14 federal ministries), the directly elected Federal Parliament (Bundestag) and the second parliamentary chamber (Bundesrat) representing the 16 federal states. Each state exercises legislative and political powers over its local authorities, consisting of counties (Kreise) and municipalities (Gemeinden). The majority of legislation (including European legislation) is enforced by the local authorities that exist below the Lander – about 70 to 80 per cent – making Germany’s local government one of the most politically and functionally strongest in Europe (Wollmann et al., 2010b; Monstadt and Scheiner, 2014).

While the federal level of government holds primacy in legislation and policy-making there is a strong system of checks and balances enforced by a vertical division of power and complicated through political and governance networks that operate vertically through the levels of state and horizontally between the various Länder and local authorities. Although the Länder have to enforce the areas of law in which the federal government is responsible they are able to participate directly in shaping that national legislation through the upper chamber of parliament (Wollmann et al., 2010a). Unlike the US, the federal and Länder levels of government work in parallel with a system of interlinked (instead of separate) competencies with a specific division of labour and responsibilities between the two levels of government. Some 60 per cent of federal laws are dependent on the endorsement of the Bundesrat. The ‘organicist’ version of the state in Germany provides a strong theoretical underpinning for local administration – under Article 28 of the constitutional Basic Law German municipalities have full autonomy in regulating local issues such as water and energy provision, housing and transport. They are guaranteed the right to deal with all local matters affecting the municipality and it is not permissible for the state (unlike within the UK) to list the tasks for local government to address. The concept of ‘pragmatic municipalism’ (Lorrain, 2005) has led to the passing of laws and regulations that recognise the importance of local authorities in providing a city’s basic services. While cities are limited by the principle of subsidiarity – they are subordinate to the Land and to the Bund – any intervention from the federal or state level is rare.

It is the interactions between the three levels of government – federal, Länder and local – that characterises German governance. The vertical and horizontal phenomenon of networks pervades the political and administrative system. While critics claim this has led to the formation of a ‘crypto-unitarist’ state in which the Länder have seen their autonomy weakened (Bullman, 2007) this form of statecraft does allow for experimental governance arrangements to be trialled, evaluated and diffused to other authorities. For example, the ability for Länder to tailor federal and European policies to their own locally-specific contexts has allowed for the growth of renewable energy grids, decentralised technologies, widespread recycling schemes and subsidised public transport without the need for federal encouragement, oversight or approval.

The infrastructure of Germany reflects the complications of economic, political and social change during the 20^th Century. Post-war reconstructions maintained the principles of local self-government and public services were provided under municipal ownership. As a result, there was no widespread nationalisation of the electricity system and many services were (and still are) provided by local public utilities under a form of arms-length service provision, often by organisations known as stadtwerke or ‘city works’. Infrastructure has been managed on a territorial basis rather than the more sectoral practices that exist in the UK and US: cities and municipalities manage and govern their own infrastructures and use forms of cross-subsidisation to keep costs low.

The wave of New Public Management strategies introduced across the continent in the 1990s, alongside the network liberalisation and competition policies enacted at the European Union level, has led to the institutional fragmentation of infrastructural governance within Germany and a convergence towards the Anglo-Saxon models of vertically integrated networks alongside horizontal unbundling. The German pragmatic concept of a single municipal organisation managing a region’s entire infrastructure has been called into question and attempts have been made to prevent forms of cross-subsidisation, liberalise infrastructure markets and to open up sectors to European-wide competition. Researchers argue that this neoliberal progression of outsourcing and unbundling “has made it more difficult to link infrastructure provision to broader local strategic goals, and also reduced the scope for governments to capture and reinvest growth revenues” (While and Whitehead, 2013: 2383). However, this argument risks downplaying the complicated governance arrangements at work within Germany. The German pragmatic approach does not lean ideologically towards either pure competitive private markets or to regulated public-sector driven monopolies and unlike the UK and US there is no national desire to transform the state into an ‘enabling’ government. Instead the public sector is viewed as a valid and useful competitor to private enterprise. Efficiency is just one important consideration and many municipalities see other issues such as job and business creation, urban quality of life and integration of space and scale of equal importance.

Today infrastructure management in Germany is a mix of both public and private provision, of competitive markets and regulated monopolies. Many stadtwerke are themselves a mixture of ownership models: some are owned entirely by their respective local authorities; some are operated as publicly-owned arms-length enterprises; others are jointly owned by the public sector and international private firms. Vertical and horizontal ownership networks run throughout German infrastructural life. EnBW, one of the ‘Big Four’ energy firms, is almost wholly owned by municipalities and the state of Baden-Wurttemberg. RWE and E.ON both have subsidiaries holding minority interests in around 100 stadtwerke (Wollmann et al., 2010b) while only 30 per cent of the stadtwerke are wholly owned by their cities – such as in Munich and Leipzig.

Nationally attempts have been made to introduce competition into the electricity and telecommunications markets and both are now dominated by large, almost oligopolistic firms. Until the 1980s the electricity market in Germany was a mixture of private interests and municipal providers. The large private providers generated around 80 per cent of electricity, owned most of the long-distance high-voltage transmission grids, and distributed about 70 per cent to the end consumer (Wollmann et al. 2010b). The municipalities retained ownership of the ‘last-mile’ of the grid – the short-distance distribution networks that connect to the end-consumer.

Liberalisation of energy markets at the European level took place in the late 1990s, introducing the right to switch supplier and encouraging the break-up of the monopolies of the German multi-sector stadtwerke (Hall, Foxon and Bolton 2016). While the aim was to introduce competition into the national energy market the regulations have in fact led to a wave of mergers and buyouts creating a large oligopoly of the ‘Big Four’ – RWE, EnBW, E.ON and Vattenfall – which together have a 67 per cent share of the power market in both Germany and Austria. While the Big Four have shifted towards the vertical integration of generation and transmission within their single-sector competencies they have largely retained their historic territorial biases. E.ON owns and maintains grids in the north, west and in southern Bavaria; RWE has a strong presence in the industrial Rhine-Ruhr region; EnBW controls Baden-Wurttemberg in the south-west and Vattenfall – itself part-owned by the Swedish state – controls the former east GDR.

In telecommunications, the attempt to introduce competition has led to the unbundling of state services. Similar to electricity, while the sector was liberalised in 1998 with the full unbundling of access lines from the state-owned Deutsche Telekom providers still maintain a largely geographic focus – in 2004 there were 80 city-based carriers (Elixmann, Schwab and Stappen, 2003). The liberalization of the telecommunications sector has been incremental. Deutsche Telecom was made into a form of public corporation in 1995, 25 per cent privatized in 1996 and was majority privatized in 2001 (Thatcher, 2007).

Since the turn of the century Germany has been reversing its outsourcing policies with a major expansion in the direct municipal provision of public services. Since 2007, 44 new stadtwerke have been created under a growing culture of re-municipalisation while more than 100 contracts for energy networks have been returned to the public. Today some 850 stadtwerke hold half of the retail energy market. In 2013 they had combined sales of 110 billion euros and their market share for Germany retail energy was 46 per cent in electricity, 59 per cent in gas and 65 per cent in heat distribution (Schlandt, 2015). In comparison RWE, the biggest energy retailer in Germany, had a market share of just 10 per cent in gas and 16 per cent in electricity. The stadtwerke are popular and are trusted by German consumers. Most are still small enough to act quickly to tailor national legislation to their own local and regional histories.

According to Wollmann et al. (2010b) the deregulation changes have forced stadtwerke to adapt and integrate some of their services to compete with the national players. While liberalisation may have led to an unbundling at a national level, for the municipalities attempts have been made to ‘double-down’ on their own offerings to compete with the national players. Not only have many areas created new transmission grid operation companies to “economize, pool capacities and join forces” (Wollmann et al., 2010b: 178) but they have also established shared services (billing, call centres, book-keeping), built their own power plants to compete in energy production, and taken advantage of existing horizontal networks to create joint offices with other municipalities to buy energy collectively on the European Energy Exchange (EEX).

The governance structure of Germany operates as a tripartite locus of power between the federal, state and city governments. Germany’s form of pragmatic municipalism sees the state as a valid competitor to private utility suppliers. Infrastructures owned by city authorities are viable, cross-subsidisation is possible (subject to European liberalisation laws) and offers valid competition to national and international service providers. Many stadtwerke organisations are popular with citizens and, alongside infrastructural provision, can be used for economic development purposes. Integration within Germany is possible and likely in a number of urban regions. However, policy change in Germany can be slow and piecemeal and new technological innovations may be difficult to introduce into the publicly-managed utilities. The concept of co-determination, the desire to allow forms of direct democracy (many cities allow for referenda to be held on infrastructural decisions) and the aim of inclusive government can act as a barrier to drastic shifts in infrastructural management techniques.

Conclusion

The growing discourse surrounding the concept of infrastructure integration necessitates an examination of its meanings in theory and in practice. If integration is occurring, then there are likely to be variations in the scale and extent of its application. There are three points to make in relation to the countries examined in this paper.

First, the speed of any potential moves towards infrastructure integration will vary within the three countries. The UK has a history of quick and radical shifts in policy that can be enacted often against the will of the local arm of state. If the national government chooses to move towards a reintegration of its currently splintered infrastructural sectors, then this policy may be carried out more swiftly than elsewhere. In the US and in Germany, the slow pace of change within governance networks created by the fragmented federal structures could filter through to attempts to introduce innovations within infrastructures when they arise or are needed. The opposition to Reaganite reforms in telecommunications within many US states is a good example. However, these potential problems may be offset by the power locus set within the state-level governance structure. A highly educated, professionalised, career-driven civic structure could offer experts influence over future utilities without the threat of external political influence. The decentralised decision-making structure allows for innovative cities to act quickly within their own locales without seeking prior approval from the federal centre. In the US especially the desire to integrate on a geographic level (through telecommunications, road and rail networks) has been a common discourse since the country’s creation. However, the patchwork quilt of policy amongst states and the relatively weak federal centre in both the US and Germany makes it difficult for any meaningful integration to occur on a national scale. When infrastructure integration does occur, it may often be local, small-scale and sector-specific.

Second, there is significant variation in the likelihood of infrastructure integration occurring. Within the UK the emphasis on consumer experience over resource reduction, on competitive markets over state guarantees, and a focus on sectoral efficiency over holistic territorial planning makes it unlikely that any radical changes towards infrastructure integration will occur. The UK has an added complication in being splintered at the national regulatory level: the government regulator Ofcom regulates the telecommunications industry, Ofgem regulates energy, Ofwat regulates water etc. Without significant changes within central government and without infrastructure integration being pursued as a specific and clearly defined government policy it is difficult to see how significant forms of integration can occur. The German and US conceptions of the state – German co-determination and US weak federalism – allow for infrastructures to be managed more at the urban scale than in the unitarist UK, allowing locally tailored and context specific networks to be developed at the expense of national goals of universalism. Cities can, and do, pick from a rich tapestry of governance models to tailor their own needs, from public or private regulated monopoly provision to free competitive markets. In Germany, this emphasis on the local has allowed for a re-municipalisation of a variety of urban infrastructural services, offering a vehicle through which integration can be pursued as a specific policy goal at the local level.

Third, there is variety in the forms of infrastructure integration likely to be enacted within the three countries. The US and the UK are more likely to undergo vertical sectoral forms of infrastructure integration (coming with a history of sectoral infrastructural management policies) as opposed to the multi-sector provision as practised in Germany. Despite the PUC model in the US providing a possible organisational vehicle for multi-utility governance, many infrastructures in the country remain splintered and sector-specific: water, energy and telecommunications utilities are separately owned and managed under strict regulatory controls. A similar situation exists in the UK. In contrast, Germany offers an example of how sectoral integration between sectors may be possible. The stadtwerke organisations are similar to the US PUCs; however, they have the ability to offer direct provision of services and act alongside city authorities in terms of economic development and social service provision. The stadtwerke model offers a perfect example of how organisational forms of integration could occur.

One aim of this paper has been to open up the debate surrounding infrastructure integration, to categorise its varying definitions within the literature and to examine the potential for it to occur in three countries. It may be useful for further research to examine the exact forms of infrastructure integration that are occurring, if indeed, they are occurring at all, and to link those forms to wider debates of regulatory and institutional management.