Update:  On November 5, 2014, OMA Energy Group filed comments on the rules proposed pursuant to S.B. 310.  OMA Energy Groups’ comments offered the following main criticisms of the proposed rules:  (1) a utility’s energy efficiency/peak-demand reduction (EE/PDR) rider includes costs that are not associated with the cost of utility compliance; (2) historic volatility and inconsistency in utility EE/PDR riders may confuse consumers as to the cost of utility compliance; (3) the cost of EE/PDR compliance is an inadequate and incomplete description of the benefits and costs of energy efficiency and demand response resources; (4) the Commission should not prescriptively allocate EE and PDR requirement compliance costs; and (5) the Commission should create supplemental educational materials on the benefits and costs of the EE and PDR resources, with an Apples-to-Apples comparison with other generation resources.

A number of other interested parties, including the Office of Ohio Consumers’ Counsel (OCC), Industrial Energy Users-Ohio (IEU-Ohio), the Environmental Law and Policy Center (ELPC), Sierra Club, the National Resource Defense Council (NRDC), Ohio Environmental Council (OEC), Direct Energy Services, LLC, Direct Energy Business, LLC, Direct Energy Business Marketing, LLC, the Dayton Power and Light Company, AEP Ohio, and FirstEnergy also filed comments on the proposed rules.  Reply comments are due on November 17, 2014.