August 3, 2012

Update:  This week, several parties submitted comments regarding AEP-Ohio’s corporate separation plan, including: (1) OMAEG; (2) FirstEnergy Solutions (“FES”) (3) Constellation NewEnergy, Inc. and Exelon Generation Company, LLC; (4) OCC; and, (5) PUCO Staff.  Essentially, most parties’ comments addressed the fact that AEP-Ohio failed to provide enough information and evidence to support the reasonableness of its application; therefore, requesting that the PUCO direct AEP-Ohio to file the net book and market value of the generating assets and set the matter for hearing.

However, FES also urged the PUCO to adopt a corporate separation plan that: (1) treats all Renewable Energy Purchase Agreements similarly; (2) does not approve in this proceeding, the post-separation wholesale contract between AEP-Ohio and AEP Generation; (3) prohibits subsidies between AEP-Ohio and AEP Generation; and, (4) prohibits AEP-Ohio from seeking any revenue due to the termination of the pool modification rider (“PMR”).  Reply comments are due on August 3, 2012.  However, as discussed at this week’s monthly meeting, since AEP-Ohio did not file initial comments and we agree with the other comments, we will not file reply comments.  We will provide an update on AEP-Ohio’s reply comments and any PUCO action that follows.