The Alliance submitted comments in response to the Indiana Utility Regulatory Commission Backup, Maintenance, and Supplemental Power Rate Review Draft Report. In our comments, the Alliance expressed concerns with the Draft Report’s conclusion that the electric utilities are already providing cost-based, nondiscriminatory, and non-subsidizing required services. Our comments cite an “Apples-to-Apples” analysis conducted by 5 Lakes Energy that found large differences in the charges between the Indiana utilities and that the charges are among the highest in the region. In light of these findings, we offer the following three recommendations to be included in the Commission’s Final Report: (1) Ask for the topic of standby rates to be included in the forthcoming Legislative Summer Study Committee; (2) Open a docket to review existing tariffs and implement best practices for standby rates; and (3) Require the utilities to provide the Commission with the cost of service level justification for their rates. Adopting these recommendations will help ensure reasonable and transparent standby rates for Indiana customers and cut electricity, heating and cooling costs for Indiana manufacturers, making them more competitive.