Update: On August 7, 2015, the Office of the Ohio Consumers’ Counsel (OCC) and Industrial Energy Users-Ohio (IEU-Ohio) filed replies to AEP’s memorandum contra OCC’s motion to compel the production of information pertaining to AEP’s revenues collected pursuant to the Retail Stability Rider (RSR) during the term of its second electric security plan. In their replies, OCC and IEU-Ohio argue that the Commission should grant OCC’s motion to compel, as AEP admitted in its memorandum contra that there is a connection between collected RSR revenues, OCC’s discovery request, and the $188.88/MW-day state compensation mechanism rate. In further support of the motion to compel, IEU-Ohio also argued that AEP has acknowledged that a portion of the RSR revenue relates to the capacity deferral. Given these facts, there is no foundation for AEP’s argument that OCC’s discovery request was not reasonably calculated to lead to the discovery of admissible evidence.