January 19, 2016

RE: LSA Document #16-49, Indiana Utility Regulatory Commission, Rulemaking No. 15-06

On behalf of the Indiana Utility Regulatory Commission (IURC), I am submitting this written notice in compliance with IC 4-22-2-19, which requires an agency to begin the rulemaking process not later than 60 days after the effective date of the statute that authorized the rule, unless a notice is filed with the Publisher that includes the reasons for the noncompliance.

The General Assembly enacted P.L.246-2015, SEC. 1, effective May 6, 2015, requiring the IURC to execute a rulemaking concerning public utilities' integrated resource plans and requiring certain electricity suppliers to submit an energy efficiency plan at least once every three years. The rulemaking requirements are now codified at IC 8-1-8.5-3(e) and IC 8-1-8.5-10(q), respectively.

The IURC was unable to begin the formal rulemaking process within 60 days of the statute authorizing the rule because of the extensive pre-rulemaking period required to draft an accurate and all-encompassing rule. The IURC held pre-rulemaking workshops with the public on July 30, 2015, and November 5, 2015. The IURC additionally received substantial written comments from numerous stakeholders, which it used to produce two "strawman" draft rules for additional public comment. Please be assured that the IURC is proceeding, and will continue to proceed, in such a manner as to comply with P.L.246-2015 and IC 4-22-2 in order to best serve the State of Indiana and its citizens.

Beth Krogel Roads

General Counsel

Indiana Utility Regulatory Commission