Today, the Alliance filed comments with the Public Utilities Commission of Ohio on draft rules released to implement new energy efficiency legislation to support combined heat and power and waste energy recovery deployment in the state. Our comments recommend three important changes to the proposal: (1) we urge the Commission to establish a universal, performance-based electrical savings accounting method; (2) we believe that there should be greater clarity around the length of the savings credit and the timing of the cash payment; and (3) we are concerned that the maximum incentive available is too low to be effective. Our comments highlight similar incentive programs in other states, noting that the proposed Ohio credit may be as little as one-sixteenth in size. Such a credit will do little to stimulate CHP and WER development in the state. Read the comments here. UPDATE: The Alliance joined the Ohio Coalition for Combined Heat and Power’s Reply brief on March 24, 2014, which can be viewed here.