Update:  On November 17, 2014, OMA Energy Group filed reply comments on the proposed SB 310 rules, arguing the following:  (1) the proposed prescriptive 80% – 20% allocation of the EE/PDR rider is not an accurate accounting of energy efficiency and peak demand reduction compliance costs; (2) adopting the proposed rules without change could be significantly confusing for customers; (3) the Commission should create supplemental educational materials on the benefits and costs of energy efficiency and peak demand response resources, with an apples-to-apples comparison against other electricity resources; and (4) the Commission should review sample bills and sample calculations prior to approving an electric distribution utility’s bill disclosure of energy efficiency and peak demand reduction costs.

A number of other parties, including AEP Ohio, FirstEnergy, Direct Energy Services, LLC, Direct Energy Business, LLC, Direct Energy Business Marketing, LLC, the Office of the Ohio Consumers’ Counsel (OCC), Industrial Energy Users-Ohio (IEU-Ohio), Noble Americas Energy Solutions, the Environmental Law and Policy Center, Sierra Club, the Natural Resources Defense Council, and the Ohio Environmental Council (OEC) also filed reply comments on the proposed rules on November 17, 2014.