Energy Division noticed this disparity and brought it to SDG&E’s attention via a data request dated February 23, 2016. On March 4, 2016, SDG&E replied to Energy Division’s data request by acknowledging that intended to list “SDG&E permissible shared services [presumably under the Affiliate Transaction Rules] COC Rule 13 allows shared services except for employees engaged in … marketing and lobbying Thus, lobbying, as covered by the COC, will not be a … shared service.” he proposed I provides a service that relates to the use of electricity, and therefore, is covered by all Affiliate Transaction Rules, pursuant to ATR II.B. SDG&E argues that its IMD, known as Services Corporation” (SSC), “Sempra despite the suggestion in its very name, not be engaged in the provision of “will any product that uses electricity or provision of services that relate to the use of electricity.” Therefore, SDG&E contends, SSC should not be subject to all of the
Energy Division noticed this disparity and brought it to SDG&E’s attention via a data request dated February 23, 2016. On March 4, 2016, SDG&E replied to Energy Division’s data request by acknowledging that “SDG&E intended to list permissible shared services [presumably under the Affiliate Transaction Rules] … COC Rule 13 allows shared services except for employees engaged in marketing and lobbying … Thus, lobbying, as covered by the COC, will not be a shared service.” he proposed I provides a service that relates to the use of electricity, and therefore, is covered by all Affiliate Transaction Rules, pursuant to ATR II.B. SDG&E argues that its IMD, known as “Sempra Services Corporation” (SSC), despite the suggestion in its very name, “will not be engaged in the provision of any product that uses electricity or provision of services that relate to the use of electricity.” Therefore, SDG&E contends, SSC should not be subject to all of the
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