Update:  Staff filed comments in this proceeding on February 4, 2014.  Staff stated that it supports DP&L’s cost allocation manual (CAM) as long as it was the CAM that was previously approved by the Commission.  Staff, however, opposes DP&L’s request for the Commission to find that the AES US Services Cost Alignment and Allocation Manual is consistent with the Commission’s corporate separation rules.   Staff requests that DP&L file the AES US Services Cost Alignment and Allocation Manual to allow the Commission to determine if it is consistent with the Commission’s rules.

The Ohio Consumers’ Counsel (OCC) and Direct Energy Services, LLC and Direct Energy Business, LLC also filed comments.  The OCC suggested that the Commission carefully scrutinize DP&L’s CAM and AES US Services Cost Alignment and Allocation Manual to ensure DP&L customers will not be harmed by improper allocation to affiliates.  The OCC also recommends that DP&L be required to account for its generation and transmission and distribution separately, pending sale or transfer of generation assets.

Direct Energy states that no shared employee should be allowed to participate in the drafting or filing of the ESP application to prevent DP&L affiliates from obtaining and unfair advantage.

The Industrial Energy Users – Ohio (IEU-Ohio) filed objections stating that the application is incomplete because it does not specify the costing methodology for the services AES will provide. IEU-Ohio also says that the Commission should not act on the corporate separation application without addressing the unlawful Service Stability Rider that remains subject to grant of rehearing in the recent ESP case.  Finally, IEU-Ohio suggests that the Commission refrain from ruling on the transfer of generation assets portion of the plan until DP&L supplements its application in the generation asset transfer case (Case No. 13-2420-EL-UNC).