Update: On January 22, 2015, Eramet Marietta (Eramet) filed an application to amend its reasonable arrangement with AEP Ohio, in which it requested authority from the Commission to, among other things, extend the term of its reasonable arrangement by one year, to change the pricing terms of its reasonable arrangement.

On February 6, 2015, Ohio Energy Group (OEG) filed comments and objections indicating that Eramet’s application to amend its reasonable arrangement improperly failed to quantify how much additional delta revenue other AEP Ohio customers would pay both annually and over the term of the reasonable arrangement to fund Eramet’s requested rate discount. OEG also contended that Eramet’s failure to include hard caps (annual and over the term of the arrangement) on the potential delta revenues to be recovered from AEP Ohio customers was unreasonable, as was Eramet’s failure to quantify the amount of cost-shifting between customer classes, etc., that would result from approving Eramet’s request to be exempt from all applicable AEP Ohio distribution riders. OEG also contended that Eramet’s application failed to answer several other important questions arising in the context of the application, including whether Eramet would operate at a loss or shut down its operations but for the Commission’s approval of the proposed amendments; whether any Eramet jobs would be lost or gained depending upon the Commission’s ruling; whether there are any quantifiable benefits to other AEP Ohio customers that would result from the amended application; and whether AEP Ohio supports the application to amend the reasonable arrangement.

On February 13, 2015, the Office of the Ohio Consumers’ Counsel (OCC) also filed comments on Eramet’s application to amend the reasonable arrangement between AEP Ohio and Eramet, reiterating the comments made by OEG and stating the following additional concerns: (1) that it may be unlawful and unreasonable for Eramet to ask AEP Ohio customers to subsidize the generation provided by certified retail electric suppliers to Eramet; (2) that Eramet unreasonably failed to include in its application a commitment to maintain the facility’s Ohio operation and retain full-time Ohio jobs; and (3) that the Commission should direct AEP Ohio, rather than its customers, to fund at least a portion of any discount it approves for Eramet.