Update:  On August 12, 2014, Direct Energy Services, LLC and Direct Energy Business, LLC filed reply comments arguing that the General Assembly eliminated the in-state requirement in its entirety for 2014.  The Ohio Environmental Council and Industrial Energy Users-Ohio (IEU-Ohio) also filed reply comments. The Ohio Environmental Council states that S.B. 310 did not alter the 2014 renewable energy benchmark and that the Commission should not take any action to change its rules as they relate to 2014.  Sierra Club filed reply comments stating that the Commission should not disrupt the in-state requirement for 2014 and if the Commission does anything, it should prorate the requirement to when S.B. 310 is effective.  IEU-Ohio, on the other hand, supports a recommendation that the Commission remove the in-state requirement for 2014.  The Ohio Consumers’ Counsel (OCC) filed reply comments which disputed the position that IEU-Ohio was taking.  The OCC did not take a specific position as to whether the requirement should be eliminated for 2014 or not.  FirstEnergy filed reply comments stating that it believes S.B. 310 eliminated the in-state requirement for 2014.  Finally, the Retail Energy Supply Association filed reply comments also stating that it was its belief that S.B. 310 eliminated the requirement.