edc-corresp033016.htm

We note your disclosure that the “[i]nformation regarding [y]our executive officers required by Item 401 of Regulation S-K is presented in Item 1 under the subcaption ‘Executive Officers.’” However, no such disclosure appears to be included in this filing. In future filings, please ensure that the information required by Item 401 of Regulation S-K is properly disclosed in your Annual Report on Form 10-K. Please tell us what this disclosure will look like.

In future filings either on Form 10-K or in our annual proxy statement, we will have a disclosure similar to the following.

The name, age, period of service and title of each of our executive offices as of March 25, 2016, are listed below.

Randall W. White	President and Chairman of the Board Age: 73 President and Chairman of the Board of EDC since 1986 and Treasurer of EDC from February 1984. From 1980 until joining EDC in 1983, Chief Financial Officer of Nicor Drilling Company, Tulsa, Oklahoma, an oil and gas drilling company.
Marilyn Pinney	Controller and Corporate Secretary Age: 52 Controller and Corporate Secretary since 2007
Craig White	Vice President Information Technology Age: 47 Vice President Information Technology since 1994

2.	In future filings, please revise the second signature block to identify your principal executive officer. Refer General Instruction D (2) to Form 10-K.

In future filings of our annual Form 10-K, we will parenthetically denote our Principal Executive Officer to Randall W. White’s title since he also represents the company in this capacity.

3.	In future filings, please provide a table detailing the compensation for your directors. Refer to Item 402(r) of Regulation S-K. Please tell us what this disclosure will look like.

In future filings of our annual proxy statement, we will have a disclosure similar to the following with the appropriate narrative as needed.

Name	Fees earned or paid in cash($)		Stock Awards($)	Option Awards($)	Non-equity incentive plan compensation	Nonqualified deferred compensation earnings	All Other Compensation($)	Total($)
Ronald T. McDaniel		800							800
Kara Gae Neal		800							800
John A. Clerico		400							400
Randall W. White		0							0
Betsy Richert		800							800

In future filings, please disclose the material terms of Ms. Pinney’s employment agreement as your Principal Financial and Accounting Officer. Refer to Item 402(o)(1) of Regulation S-K. If applicable, please also disclose in the Summary Compensation Table, any compensation paid or earned by Ms. Pinney. Refer to Item 402(m)(2) of Regulation S-K. Please tell us what your disclosure will look like.

In future filings either on Form 10-K or in our annual proxy statement we will disclose that no formal employment agreement is in place for Ms. Pinney’s employment. For future Executive Compensation tabular disclosure, we will have a disclosure similar to the following with the appropriate narrative as needed.

Name and Principal Position	Fiscal Year	Salary($)		Bonus($)		Stock Awards($)	Option Awards($)	Non-equity incentive plan compensation	Nonqualified deferred compensation earnings	All Other Compensation($)	Total($)
Randall W. White	2016		155,000		28,000					11,600		194,600
Randall W. White	2015		150,000		28,000					3,300		181,300

Craig White	2016		101,200		10,000					12,900		124,100
Craig White	2015		95,000		10,000					3,700		108,700

Ms. Pinney’s annual compensation for the respective fiscal years ended February 28, 2015 and 2014 did not exceed $100,000 and thus, is not disclosed in the Executive Compensation table as permitted under Item 402 (m)(2)(iii) of Regulation S-K. The Company will include Ms. Pinney’s annual compensation in future filings if she meets or exceeds the $100,000 annual compensation threshold.

5.	Please revise your disclosure in future filings, to provide a more detailed discussion of the performance-based cash bonus component of your compensation plan. Refer to Item 402(m)(1) of Regulation S-K. Please tell us what your future disclosure will look like.

In future filings either on Form 10-K or in our annual proxy statement, we will have a disclosure similar to the following.

The Company has not had a formal policy regarding bonuses, and payment of bonuses has been purely discretionary and is largely based on the recommendations of the Compensation Committee. Cash bonuses are not expected to be a significant portion of the executive compensation package. The annual discretionary bonus is reported in the “Bonus” column of the “Summary Compensation Table” for each Named executive officer.

that it is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.