The rules contained in Ohio Administrative Code (“O.A.C.”) Chapter 4901:1-39 amplify the energy efficiency standards set forth in Revised Code (“R.C.”) Section 4928.66.  The law requires that utilities meet annual energy efficiency benchmarks through energy efficiency programs or be subject to penalties.  Specifically, utilities must meet a cumulative energy reduction through efficiency programs by the year 2025.  The rules in O.A.C. 4901:1-39 provide details concerning the implementation of the energy efficiency standards, including the banking of surplus energy savings to be applied in future years, encouragement of collaborative engagement, and the inclusion of energy efficiency savings accomplished by mercantile customers within the utility’s energy efficiency portfolio plan.  As part of the JCARR review process, the PUCO has scheduled a workshop for April 23, 2013.  The workshop is intended as an opportunity for PUCO Staff to receive feedback from interested stakeholders before it issues draft rules.  OMAEG counsel is working with John Seryak of Go Sustainable Energy to further determine whether there are provisions in which the OMAEG should provide comments.