Update:  Duke filed a memorandum contra the applications for rehearing of OMA and other intervening parties. Specifically, Duke asserts that the Stipulation approved by the PUCO in the shared savings cases is the result of serious bargaining among parties with diverse interests, is in the public interest, and does not violate any regulatory principles or practices. In making its arguments, Duke ignores the PUCO’s prior decision to prohibit the collection of shared savings on banked savings and the cost to customers. Duke also completely disregards PUCO rules and practices.