
Correggio Consulting delivers specialised advisory support across the European gas and power sectors, helping market participants navigate complex regulatory environments with clarity and confidence.
Our services span the full spectrum of market entry and operational readiness, from strategic market access and executive training to regulatory compliance implementation, legal and contractual support, and the execution of technical assistance projects in emerging markets. With deep sector expertise and a proven track record across wholesale energy markets, we equip clients with the knowledge, frameworks, and guidance required to operate effectively, manage risk, and succeed in an evolving regulatory landscape.
Our Services

Local Entity Incorporation
Establish your operational footprint with a tailored legal presence optimised for participation in European gas and power markets. Correggio Consulting supports clients in structuring and registering local entities that meet national regulatory expectations while remaining operationally efficient and commercially scalable.
Our advisory spans the full lifecycle of establishing a compliant market-facing corporate vehicle, from selecting the optimal jurisdiction and legal form, to aligning governance, tax, and reporting frameworks with national energy-market obligations.
Our Services Include
Jurisdiction & Legal Form Assessment
We provide a comparative analysis of EU and Energy Community jurisdictions to determine the most appropriate legal structure (e.g., branch, subsidiary, SPV) based on your trading strategy, cross-border footprint, regulatory exposure, and tax considerations.
This includes guidance on:
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Market-specific restrictions on foreign entities
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Capitalisation thresholds
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Requirements for local presence, directors, or representatives
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Compatibility with future licensing, BRP/BSP registration, or exchange participation
Entity Set-Up & Registration Management
> 200.000 Euro proof of financial resources for the license + financial guarantees to the TSO and gas exchange BRM - subject to expected trading volumes we coordinate the full incorporation process with local registries, notaries, and legal counsel, ensuring all statutory documentation is drafted, executed, and filed correctly.
This typically includes:
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Articles of association & founding deeds
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Shareholder documentation
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Board resolutions and director appointments
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Secure establishment of registered offices and statutory records
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All filings are aligned with upcoming regulatory requirements to avoid delays at the licensing or balancing accreditation stages.
Governance, Risk & Internal Controls Design
We help implement governance systems that satisfy national regulators, auditors, and counterparties.
This includes:
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Appointment and vetting of directors, authorised signatories, and compliance officers
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Defining internal control systems for risk management, segregation of duties, and documentation retention
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Drafting corporate governance manuals, signing matrices, and compliance frameworks
These controls significantly reduce operational risk and support later applications for licences, market registrations, or balance responsibility status.
Sector-Specific Compliance Integration
Energy trading entities face unique sectoral obligations beyond standard company law. We integrate market-specific requirements into your entity from day one, including:
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Fit-and-proper rules for directors and controllers
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Mandatory local representation or contact points for regulators
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Eligibility conditions for grid access, data exchange, and dispatch communications
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Future-proofing for CBAM, methane-intensity, and sustainability obligations
This avoids restructuring later and accelerates access to physical and financial markets.
Full Project Management & Cross-Border Coordination
We liaise with national registries, local lawyers, tax advisors, banks, notaries, grid operators, and regulatory authorities to ensure a unified and efficient set-up.
Our end-to-end project management includes:
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Milestone planning
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Document collection
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Coordination across time zones and languages
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Timely submission of all filings
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Delivery of a fully incorporated, compliant, and market-ready entity
You receive a turnkey solution that reduces internal administrative burden and accelerates market entry timelines.

Obtaining a Licence
Secure the regulatory authorisations required to participate legally in European gas and power markets.
Correggio Consulting manages the complete licensing process across multiple jurisdictions, ensuring your entity meets all statutory, technical, and organisational criteria for market entry.
Our Services Include
Licence Eligibility Assessment
We analyse your corporate structure, ownership, governance arrangements, and financial standing to determine licensing eligibility in each jurisdiction. This includes assessing fit-and-proper requirements, capital thresholds, VAT status, technical capability, and the applicability of foreign-entity rules.
Preparation of Licensing Documentation
Our team prepares, coordinates, and reviews all materials required for a successful application, including corporate certificates, governance documents, financial statements, technical declarations, risk-management descriptions, and compliance attestations. We ensure every submission reflects local regulatory expectations.
Liaison with National Regulators
We communicate directly with ministries, energy authorities, and regulatory commissions throughout the application process. This includes managing regulator queries, clarifying technical matters, providing supplementary documentation, and ensuring the application proceeds efficiently to approval.
Technical & Operational Prerequisites
Many jurisdictions require certain prerequisites before a licence can be issued. We help establish or validate:
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Market communication capabilities
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Data-exchange and reporting systems
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Settlement, metering, and nomination readiness
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Designation of local representatives or contact points
We ensure the applicant is fully aligned with the operational standards expected by regulators and TSOs.
Compliance Integration
We embed the necessary compliance frameworks including, REMIT, EMIR, MiFID II, and national sectoral obligations, into the application process. This ensures the licensed entity can begin trading without delays or risk of remediation actions once authorisation is granted.
End-to-End Project Management
We oversee the licensing process from initial scoping to final approval, coordinating with internal teams, legal counsel, regulators, and system operators. Clients receive clear timelines, document checklists, status updates, and confirmation of successful licence issuance.

Corporate Structuring
Design a corporate architecture that supports efficient, compliant, and scalable participation in European gas and power markets.
Correggio Consulting advises on how best to structure your organisation to meet regulatory expectations, optimise operational efficiency, and enable long-term expansion across multiple jurisdictions.
Our Services Include
Corporate Model Design
We assess your trading strategy, risk appetite, and geographic footprint to recommend the optimal structure, whether a standalone subsidiary, branch, holding model, or multi-entity configuration. Each solution is tailored to regulatory requirements, governance needs, and commercial objectives.
Governance & Oversight Frameworks
We help define decision-making and control structures that satisfy regulatory standards and support secure trading. This includes designing board arrangements, approval pathways, authority matrices, and risk-management frameworks aligned with energy-sector practices.
Regulatory Positioning & Eligibility
Your corporate structure directly affects your ability to obtain licences, BRP status, and exchange memberships. We align your configuration with eligibility criteria across EU markets, ensuring seamless progression to later regulatory processes such as REMIT, EMIR, MiFID II, and grid-access requirements.
Functional Operating Model
We map the internal organisation needed to support trading activities, including front-office, middle-office, and back-office responsibilities. This includes designing processes for scheduling, nominations, data exchange, settlement, and compliance reporting, as well as developing outsourcing or shared-service strategies where relevant.
Cross-Border Scalability
For clients expanding across multiple jurisdictions, we develop harmonised structural frameworks that minimise duplication and ensure consistency. This supports future entry into additional gas, power, and certificate markets, enabling controlled and well-governed growth.

Exchange Onboarding
Join Europe’s leading power and gas exchanges with a streamlined onboarding process that meets all membership, clearing, technical, and operational requirements.
Correggio Consulting manages the complete onboarding workflow, ensuring your organisation is fully prepared for trading from day one.
Our Services Include
Exchange Eligibility Assessment
We evaluate your suitability for exchange participation across markets such as EPEX SPOT, Nord Pool, ICE, PEGAS, OMIP, and others. This includes assessing the exchange’s membership criteria, corporate requirements, capital position, clearing eligibility, and any foreign-entity considerations.
Membership & Clearing Documentation
We prepare and coordinate all required documentation for exchange and clearing-house admission, including:
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Membership applications
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Know-your-customer (KYC) and due diligence packages
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Financial and governance disclosures
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Clearing agreements and margining arrangements
We ensure each submission is accurate, complete, and aligned with exchange expectations.
Technical Systems & Connectivity
We guide you through meeting the technical prerequisites for exchange access, including:
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API and trading-screen connectivity
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Integration with order management and scheduling systems
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Messaging standards and data exchange protocols
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Trading system testing and approval procedures
Our support ensures your trading desk is fully operational at go-live.
Risk, Compliance & Operational Alignment
Exchanges impose stringent risk and compliance standards. We assist with:
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Setting up trading limits and risk controls
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Trade reporting processes (REMIT, EMIR, MiFID II)
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Operational readiness for nominations, clearing, and settlement
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Internal procedures required for exchange audits or membership reviews
This ensures your organisation meets market–facing expectations from the outset.
Clearing, Margining & Settlement Readiness
We help establish clearing-house relationships and ensure your financial operations are prepared for:
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Initial and variation margin requirements
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Collateral posting and treasury workflows
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Payment cycles and settlement procedures
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Counterparty and clearing risk management
This ensures reliable execution and post-trade performance.
Go-Live Coordination & Member Activation
We coordinate the end-to-end onboarding timeline with the exchange, clearing house, and your internal teams. This includes overseeing technical certification, final approvals, market-access activation, and progression into live trading operations.

Contract Negotiation
Establish reliable and bankable trading relationships through professionally negotiated agreements.
Correggio Consulting supports clients in drafting, negotiating, and implementing Gas and Power Master Agreements, ensuring robust contractual frameworks that meet industry standards and counterparties’ expectations.
Our Services Include
Contractual Needs Assessment
We begin by assessing your trading strategy, counterparties, product scope, and jurisdictional footprint to determine which contractual modules, annexes, and optional provisions are required. This ensures the contract structure fully reflects your commercial and operational needs.
Drafting & Customisation of Master Agreements
We prepare tailored Power and Gas Master Agreements, incorporating the relevant general agreements, appendices, election sheets, credit support documents, and optional clauses. Each contract is adapted to your risk appetite, internal processes, and regulatory environment.
Counterparty Negotiation & Redlining
We lead or support negotiations with trading partners to reach balanced and commercially sound contract terms. This includes redlining, resolving clause-specific disputes, aligning optionality selections, and coordinating legal positions to ensure timely execution without compromising your risk controls.
Credit & Collateral Provisions
Contractual negotiations often hinge on credit risk management. We assist with structuring:
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Credit support annexes
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Margining and collateral terms
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Guarantee mechanics
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Netting and set-off provisions
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Default and early-termination rights
Our focus is on ensuring both creditworthiness and operational efficiency.
Regulatory & Compliance Integration
We ensure your contractual documentation aligns with regulatory regimes such as REMIT, EMIR, MiFID II, and national reporting obligations. This includes embedding required representations, data-sharing provisions, and compliance undertakings to support ongoing regulatory readiness.
Implementation & Contract Lifecycle Management
Once agreements are executed, we support onboarding into your internal systems, creating contract summaries, and integrating operational procedures. We also assist with amendments, supplementary agreements, and updates to reflect evolving commercial activities or regulatory changes.
Agreements Covered
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European Federation of Energy Traders ("EFET") General Agreements for Electricity and Gas
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International Swaps and Derivatives Association ("ISDA") Master Agreements
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Cross Product Master Agreements ("CPMA")
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EFET Master Netting Agreements ("MNA")
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Grid Trade Master Agreements ("GTMA")
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Levy Exemption Certificates Agreements ("LECs")
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Guarantee of Origin Transactions
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Power Purchase Agreement (PPA)

Obtaining BRP Status
Achieve formal recognition as a Balance Responsible Party (BRP) and gain the operational capability to manage imbalances, settlements, and forecasting obligations within European power and gas markets.
Correggio Consulting guides clients through the technical, contractual, and procedural requirements imposed by Transmission System Operators (TSOs) and market operators.
Our Services Include
BRP Eligibility Assessment
We evaluate your entity’s readiness to assume balance responsibility, reviewing corporate structure, financial capacity, operational set-up, and settlement capabilities. This includes assessing whether the applicant meets the TSO’s criteria for creditworthiness, communication readiness, and operational control.
Preparation of BRP Application Materials
We compile and prepare all required filings for BRP accreditation, such as imbalance responsibility agreements, financial guarantees, operational declarations, and communication readiness statements. Documentation is tailored to national TSO requirements and harmonised where cross-border participation is planned.
Technical & Communication Requirements
We support the implementation of the data and communication infrastructure required by TSOs, including:
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Real-time data exchange systems
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Scheduling and nomination capabilities
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Gate closure alignment
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Metering and settlement data processes
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Integration with TSO platforms and market communication tools
Our guidance ensures operational compliance before entering commissioning tests.
Financial Guarantees & Credit Requirements
We advise on the calculation, structuring, and provision of the financial guarantees required to cover imbalance risk. This includes:
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Basic operational guarantees
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Additional monthly or intramonth guarantees
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TSO-specific collateral arrangements
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Coordination with clearing banks or guarantee providers
We ensure guarantees are provided correctly and maintained throughout the BRP lifecycle.
End-to-End Coordination with TSOs
We manage direct engagement with TSOs to oversee the review, testing, approval, and activation process. This includes coordination of technical tests, clarifications, updates, and formal confirmation of BRP status, ensuring a smooth and timely accreditation.

Analysis of Platform and Balancing Agreements
Ensure full understanding of your obligations when participating in European gas and power markets.
Correggio Consulting provides in-depth review and interpretation of platform rules, grid codes, and balancing agreements, enabling traders to operate confidently within complex operational and contractual frameworks.
Our Services Include
Review of Trading Platform Rules
We analyse the rulebooks and participation agreements of power and gas trading platforms, including day-ahead, intraday, cross-border allocation, and balancing markets. Our reviews identify key operational obligations, settlement mechanics, data-exchange requirements, and compliance risks relevant to your trading strategy.
Examination of Grid Codes & Balancing Frameworks
Balancing responsibilities differ significantly across jurisdictions. We interpret national grid codes, TSO balancing methodologies, imbalance price calculations, and settlement arrangements. Our guidance ensures your organisation understands its responsibilities as a market participant or BRP.
Contractual Risk & Liability Assessment
We identify areas of contractual exposure in platform agreements and balancing frameworks, including imbalance liabilities, penalties, curtailment procedures, force majeure provisions, financial securities, and default scenarios. Clients receive clear explanations of how these risks affect trading operations.
Operational Process Mapping
We translate contractual obligations into operational workflows. This includes mapping nomination processes, scheduling responsibilities, gate-closure timelines, communication flows, metering data requirements, and settlement cycles. The outcome is a clear operational handbook tailored to the client’s internal teams.
Cross-Border Participation Requirements
Participation in coupled markets and regional balancing platforms often requires additional commitments. We review CCR-specific requirements, interconnection rules, cross-border capacity products, and TSO-to-TSO arrangements to ensure your trading model is fully compatible with regional frameworks.
Recommendations for Compliance & Process Optimisation
Following each contract analysis, we provide actionable recommendations to strengthen compliance, reduce operational risk, and improve internal alignment. This may include amendments to internal procedures, updates to BRP processes, enhancements to forecasting capabilities, or suggestions for contract modifications with TSOs or platforms.

Compliance Review
Maintain full conformity with European regulatory, contractual, and operational obligations through structured annual compliance reviews.
Correggio Consulting conducts comprehensive audits to ensure your organisation remains aligned with evolving legislation, market rules, and internal governance standards.
Our Services Include
Regulatory Compliance Review
We assess adherence to all relevant regulatory frameworks, including REMIT, EMIR, MiFID II/ MiFIR; MAD/MAR; the Dodd-Frank Act, CBAM, REMIT II, national licensing obligations, grid code requirements, and sustainability-related reporting. Our auditors identify gaps, emerging obligations, and areas requiring corrective action to maintain a strong regulatory posture.
Operational Process Assesment
We review the operational procedures associated with scheduling, nominations, balancing, settlement, data exchange, and trade reporting. This ensures day-to-day execution aligns with contractual obligations, market rules, and TSO requirements. Findings include recommendations for strengthening reliability and reducing operational risk.
Governance & Internal Control
Strong governance is essential for energy-market compliance. We examine decision-making frameworks, internal controls, segregation of duties, risk-management processes, and compliance monitoring systems. Our evaluation highlights weaknesses and provides structured guidance to reinforce organisational oversight.
Data Quality & Reporting Validation
Regulatory and market reporting requires precise and reliable data. We review data flows, system interfaces, reporting logic, and record-keeping practices to ensure accuracy and auditability. This helps prevent reporting errors, remedial actions, or compliance breaches.
Final Report & Remediation Plan
At the conclusion of the project, we deliver a formal report summarising findings, ranking risks, and outlining a clear remediation plan with timelines, priorities, and responsible functions. Follow-up support is available to assist with implementation and prepare the organisation for future reviews.

Expert Training
Empower senior leadership with the knowledge, tools, and strategic insight required to operate effectively in Europe’s rapidly evolving gas and power markets. Correggio Consulting delivers high-level training programmes designed for executives, board members, senior management teams, and key decision-makers engaged in energy trading, regulatory affairs, and strategic market development.
Our trainings combine deep regulatory expertise with practical industry experience, ensuring participants gain a clear understanding of complex market structures, compliance obligations, and commercial opportunities.
Our Services Include
Tailored Executive Education
We design bespoke training modules shaped around the client’s activities, business model, market exposure, and internal knowledge base. Whether onboarding new senior hires or upskilling established leadership, our sessions provide targeted guidance aligned with corporate objectives.
Expert-Led Workshops
All programmes are delivered by experienced practitioners with backgrounds in energy regulation, trading, compliance, policy, and corporate governance. This ensures every course blends rigorous theoretical insight with practical, market-tested knowledge.
Strategic and Regulatory Orientation
Our instruction helps leaders understand the regulatory frameworks, trading systems, and market reforms shaping the European energy sector. We emphasise how regulatory expectations, contractual structures, and operational obligations impact corporate strategy, risk management, and growth.
Practical Application & Case-Study Based Learning
Training modules incorporate market case studies, regulatory scenarios, and hands-on exercises. Participants gain clarity on how strategic decisions interact with market rules, how risk exposures are managed in practice, and how execution processes link to compliance obligations.
Sector-Specific Compliance Integration
Energy trading entities face unique sectoral obligations beyond standard company law. We integrate market-specific requirements into your entity from day one, including:
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Fit-and-proper rules for directors and controllers
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Mandatory local representation or contact points for regulators
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Eligibility conditions for grid access, data exchange, and dispatch communications
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Future-proofing for CBAM, methane-intensity, and sustainability obligations
This avoids restructuring later and accelerates access to physical and financial markets.

Example Training Topics
Introduction to Energy Trading
Market fundamentals, product structures, trading venues, market coupling, and the commercial logic behind power and gas trading
Principles of Risk Management in Commodities Trading
Market risk, credit risk, operational risk, limit frameworks, VaR concepts, and how risk governance is embedded in daily operations
Contractual Negotiation for OTC Energy Transactions
Overview of EFET agreements, credit support annexes, collateral terms, and negotiation strategies for counterparties and new markets
Back- and Middle-Office Structuring in an Energy Context
Processes for settlement, scheduling, nominations, reporting, collateral management, and operational compliance.

Training Delivery Formats
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In-Person Workshops for boards and leadership teams
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Virtual Executive Sessions tailored to specific regulatory developments
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Full-Day or Multi-Day Intensives for comprehensive onboarding
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Modular Programmes delivered across several weeks
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One-to-One Executive Briefings for senior decision-makers
Training Outcomes
Upon completion of the training, senior teams gain:
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Clear understanding of market design, regulation, and trading processes
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Enhanced capability to assess risks and strategic opportunities
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Improved decision-making around governance, compliance, and commercial expansion
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A unified language across leadership teams for discussing market issues
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Strengthened institutional knowledge and internal alignment

Correggio Consulting Technical Assistance Projects
Correggio Consulting provides high-level regulatory and strategic technical assistance to governments, regulators, exchanges, and state-owned energy companies as they design, liberalise, and modernise their gas and power markets.
Our experts advise on market design and target models, unbundling and wholesale market development, risk management frameworks, corporate reform of state entities, and the creation of competitive trading environments and regional hubs.
Drawing on assignments funded by institutions such as the European Commission, USAID, and national ministries in jurisdictions including Azerbaijan, Moldova, Ukraine, and Türkiye, we combine deep EU market experience with practical, hands-on support tailored to local regulatory, institutional, and political realities.
Republic of Azerbaijan
The project, funded by the Ministry of Energy of Azerbaijan, focuses on developing market regulations aligned with the target model to foster a competitive environment among electricity producers and suppliers. We collaborate closely with Azerbaijani stakeholders on the electricity market unbundling initiative, with particular emphasis on understanding the functioning of the electricity market. Our contributions include sharing insights on various critical topics such as wholesale market efficiencies, deregulation, and the implementation of market reforms in both EU and non-EU contexts. Additionally, we examine the roles of power market operators, power exchanges, and transmission system operators in driving market dynamics. (2024)
Ukraine
We provided assistance in advising the National Securities and Stock Market Commission (NSSMC) and relevant government bodies in Ukraine to align legislation for modernizing financial and commodity products trading. Our consulting involved assessing the legal framework, particularly in explaining spot and forward trading activities, title transfer, settlement functionalities, and conducting gap analysis for market development. (EU Funded Project, 2018 - 2019)

European Commission
We provided consulting services to develop and implement a Gas Trading Platform (GTP) for the Turkish Ministry of Energy and Natural Resources, with BOTAŞ as the main beneficiary. Our recommendations covered organisational management, financial management, natural gas supply security, and the establishment of a Turkish natural gas hub, with a focus on capacity building activities. (EU Funded Project, 2015 - 2017)
USAID C4G, Republic of Moldova
We assist the Moldova State Company Energocom to develop towards wholesale energy market participant in the EU, providing high level strategy advice on corporate reform and basic risk management policies to migrate from a state organization to a commercial enterprise. We give support in energy procurement activities for the Republic of Moldova and assistance to the top Energoatom management and government departments. (USAID funded project 2022 - 2025)

European Commission
As a key expert in a comprehensive project, contributed to establishing a gas balancing and wholesale gas market platform, serving as a blueprint for future gas offerings at EPIAS (Turkish Energy Exchange), we provided detailed explanations on the functionalities of physical and financial platforms. Additionally, we conducted training sessions for Turkish gas traders, covering financial regulation application, commodity derivative market operations, and principles of effective risk management in commodity and capital markets. Acting as the main point of contact, we addressed inquiries from the Turkish Ministry of Energy and BOTAŞ regarding Turkey's deregulation of the national gas market. (EU Funded Project, 2013 - 2016)
European Commission
As a consultant supporting the Cyprus Transmission System Operator (TSO) in the consultation process for the Trading and Settlement Rules, we ensured efficient presentation and explanation of the new market rules to relevant stakeholders. Our responsibilities included consulting with all market stakeholders on the specifics of the new Electricity Market Trading and Settlement Rules (TSR) and coordinating their feedback and inputs. This was done with the aim of producing the final draft of the market rules to be adopted by the Ministry of Energy and the Energy Regulatory Authority of Cyprus.
(EU Funded Project, 2016)


Security of Infrastructure
Support clients in assessing, strengthening and operationalising energy resilience across gas, power, LNG, fuels and emerging clean energy systems. Our work combines operational policy, regulatory, commercial and contractual expertise to help clients understand their exposure, prioritise practical measures, and design governance and response frameworks that can operate under stress.
Energy security has returned to the centre of strategic decision-making for governments, utilities, infrastructure operators and energy market participants. War, geopolitical disruption, cyber and physical threats, supply chain pressure, and exposure to critical import routes now require companies and public institutions to look beyond standard business continuity planning.
Our Services Include
• Critical infrastructure exposure assessments for gas, power, LNG, storage, fuel and industrial energy assets
• Energy security and supply risk analysis, including import dependency, route exposure, market disruption and contractual risk
• Desktop stress testing and scenario exercises for severe disruption, conflict-related risk and emergency response planning
• Resilience investment roadmaps, including prioritisation of high-impact assets, redundancy, decentralisation and rapid repair capability
• Crisis governance and decision-making frameworks for governments, utilities, TSOs, DSOs, traders and energy companies
• Regulatory and commercial resilience advice, including emergency procurement, price regulation, tariff recovery, rapid-response funds and market flexibility mechanisms
• Contractual and counterparty risk review, including supplier and customer flexibility, force majeure, hardship and security of supply provisions
• Practical capacity building for management teams, regulators and operational staff on energy security, crisis response and resilience planning
• Access to relevant experts, technologies and implementation experience from Ukraine and other high-risk energy markets
Ukraine-tested resilience experience
The practice draws on direct advisory experience in Ukraine’s energy sector during one of the most severe wartime stress tests faced by a modern energy system. This includes work connected to gas security, market reform, storage, system modelling, emergency procurement, resilience planning, and support to operators affected by war-related disruption.
Correggio Consulting’s expert team continues to work in Ukraine and is able to quickly connect clients seeking to understand how energy systems perform under extreme stress, what measures can be implemented quickly, which products, services and resilience suppliers can support them and how companies and public institutions can improve resilience without creating unnecessary complexity or cost.
Practice lead
Our Energy Resilience and Security Services are led by Justin Goonesinghe, Senior Advisor, Energy Resilience and Markets. Justin has nearly two decades of experience across gas and LNG markets, energy security, regulation, and critical infrastructure resilience. He has advised governments, donors, utilities and energy companies across Europe, Ukraine, Central Asia, South Asia, Africa and the Middle East, with a particular focus on how energy systems can remain secure, investable and operational during periods of market, geopolitical and physical disruption. Justin has played a central role in Ukraine’s wartime resilience since 2020 and continues to support the country as a supervisory board member in the national gas utility company.

