Update: OMA, in addition to other interested stakeholders, filed comments in response to the PUCO’s Order regarding the application of the Shroyer test to submeterers in determining if they are operating as public utility companies. In its comments, OMA argued that the PUCO should limit the application of the third prong of the Shroyer test to submeterers serving residential consumers and not unnecessarily interfere with non-residential shared service agreements. OMA also commented that certain comparisons that the test makes are unlawful and have no rational nexus to the determination of whether an entity is a public utility. In addition, in a separate filing, OMA responded to arguments raised by various groups in their respective requests for the PUCO to reconsider its Order.