SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

      April 24, 2007

Mr. Joseph M. Buonaiuto
Senior Vice President, Controll er and Chief Accounting Officer
American Electric Power Company, Inc.
1 Riverside Plaza, 28th Floor
Columbus, OH 43215

 Re: American Electric Power Co mpany, Inc., File No. 1-3525
  AEP Generating Company, File No. 0-18135
  AEP Texas Central Company, File No. 1-12973
  AEP Texas North Company, File No. 0-340
  Appalachian Power Company, File No. 1-3457
  Columbus Southern Power Company, File No. 1-2680
  Indiana Michigan Power Company, File No. 1-3570
  Kentucky Power Company, File No. 1-6858
  Ohio Power Company, File No. 1-6543
  Public Service Company of Oklahoma, File No. 1-12945
  Southwestern Electric Po wer Company, File No. 1-3146
  Form 10-K for Fiscal Ye ar Ended December 31, 2006
Filed February 28, 2007

Dear Mr. Buonaiuto:

We have reviewed your filings and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ent.  Where indicated, we
think you should revise your disclosures in futu re filings in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may or may not raise
additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We

Mr. Joseph M. Buonaiuto
American Electric Power Company, Inc.
April 24, 2007 Page 2 of 6
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2006
1. Our records show the File Number fo r AEP Texas Central Company is 1-12973,
rather than file number 0-346 that appears on the cover page of your reports.  Likewise, our records show the File Nu mber for Public Service Company of
Oklahoma is 1-12945, rather than file nu mber 0-343 that appears on the cover
page of your reports.  Please make the appropriate revisions.

Exhibit 13

American Electric Power Company, Inc. and Subsidiary Companies

Management’s Financial Discu ssion and Analysis of Results  of Operations, page A-2

Results of Operations, page A-6
2. We note your presentation of  earnings per share by segment, which represent non-
GAAP financial measures.  Please disclose how these measures are used by management and in what way they provide meaningful information to investors.
Additionally, please identify these per shar e measures as non-GAAP measures of
performance and disclose that the non-GAAP  measures should not be considered
as an alternative to earnings  per share determined in accordance with GAAP as an
indicator of operating performance.  Refe r to Item 10(e)(1)(i) of Regulation S-K
and Question 11 of our “Frequently Aske d Questions Regarding the Use of Non-
GAAP Measures,” availa ble on our website at
www.sec.gov .

Utility Operations, page A-7
3. In segment footnote (a) on page A- 111 you disclose that the Plaquemine
Cogeneration Facility is in  the “All Other” segment.  Please explain to us why
expenses at this facility contributed to the increase in other operation and maintenance expenses of the “Utility Op erations” segment as disclosed on page
A-10.  Please also explain to us why the operation of the facility affected revenues, fuel and other consumables used for electric generation and other
operation and maintenance expenses of OPCo with no effect on income as
disclosed on page I-9.

Mr. Joseph M. Buonaiuto
American Electric Power Company, Inc.
April 24, 2007 Page 3 of 6
Consolidated Statements of Income, page A-45
4. Please present the subtotal “Income befo re extraordinary items and cumulative
effects of changes in accounting principl es” as required by Item 5-03(b)(16) of
Regulation S-X.

Note 1.  Organization and Summary of Significant Accounting Policies, page A-51

General
5. Please tell us and disclose how you account  for sales and purchases of power to
and from regional transmission organiza tions.  Specifically address whether you
account for these transactions on a gross or net basis.

Property, Plant and Equipment and Equity Investments, page A-53
6. With respect to your nonregulated  operations, please explain to us why you
charge retirements from plant accoun ts, net of salvage, to accumulated
depreciation rather than r ecording a gain or loss.

Inventory, page A-54
7. If material please disclose the excess of replacement or current cost over stated
LIFO value of PSO and TNC inventories.  See Rule 5-02(6)(c) of Regulation S-X.

Emission Allowances, page A-58
8. We note that you record the net margin on the sales of emission allowances in Utility Operations Revenues “because of its integral nature to the production
process of energy and [your] revenue op timization strategy for [your] utility
operations.”  Please explain to us in greater detail why your accounting treatment
is appropriate.  Specifically address how th e sale of emission allowances relates to
your ongoing major or central operations, as  contemplated in paragraphs 78-79 of
FASB Concepts Statement 6.  Finally, pleas e explain to us in greater detail your
revenue optimization strategy and tell us  why it impacted the classification of
gains or losses on the sale of emission allowances.

Note 4.  Rate Matters, page A-67

SECA Revenue Subject to Refund, page A-81
9. In light of the ALJ decision to disa llow $126 million of your unsettled gross
SECA revenues, please explain to us how  you determined it was appropriate to

Mr. Joseph M. Buonaiuto
American Electric Power Company, Inc.
April 24, 2007 Page 4 of 6
only reserve for $37 million in  net refunds.  Refer to paragraph 11.a of SFAS 71
and paragraph 8 of SFAS 5.

Note 5.  Effects of Regulation, page A-84
10. Please provide us with your probability assessment of the future recovery of the unfunded status of your defined benefit plan s for each regulatory jurisdiction.  In
your response, please tell us how SFAS 87 costs are currently being recovered in
rates and on what basis they are being recovered, explain the regulators’ historical
approach to inclusion of the costs in rate s, provide an analysis of whether there
are significant uncertainties indicated by the regulators regarding the current or future rate recovery approach for SFA S 87 costs and the specific actions by the
regulators with respect to unf unded pension liabilities.

Note 13. Income Taxes, page A-115
11. We note that a significant portion of deferre d tax assets and deferred tax liabilities
were netted in the line item “All Other, Net” in the table on page A-116.  To the
extent material, please separately disclo se each type of de ferred tax asset and
deferred tax liability comprising this line  item.  See paragraph 43 of SFAS 109.

Note 15.  Financing Ac tivities, page A-120

Dividend Restrictions, page A-123
12. In light of the dividend restrictions placed  on the registrant subsidiaries, please
explain to us in detail how you concluded that you are not required to provide
Schedule I.  Refer to Rules 4-08(e) , 5-04 and 12-04 of Regulation S-X.

AEP Generating Company Balance Sheets, page B-6
13. Please explain to us the nature of the accrue d tax benefits line item.  We note that
this line item is presented on several of the registrant subsidiaries’ balance sheets.

Notes to Financial Statements of Registrant Subsidiaries, page L-1

General
14. Please address the above comments on the financial statements and related disclosures of the parent in the financial statements and related disclosures of the
registrant subsidiaries, as applicable.

Mr. Joseph M. Buonaiuto
American Electric Power Company, Inc.
April 24, 2007 Page 5 of 6
Note 15.  Financing Ac tivities, page L-73

Long-term Debt, page L-74
15. Please explain to us why the AEGCo Pollution Controls Bonds were classified as current in 2005 and long-term in 2006.

Exhibits 31 and 32
16. In future filings please provide separate  certifications for each registrant.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.   Please furnish a response le tter that keys your responses
to our comments and provides any requested information.  Detailed response letters
greatly facilitate our review.  Please submit your response letter on EDGAR.  Please understand that we may have additional comments after reviewing your responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

‚ the company 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Mr. Joseph M. Buonaiuto
American Electric Power Company, Inc.
April 24, 2007 Page 6 of 6
You may contact Staff Accountant Sarah Goldberg at (202) 551-3340 if you have
questions regarding comments on the financial statements and related matters.  Please
contact me at (202) 551-3344 with any other questions.

       S i n c e r e l y ,

       William Thompson
       B r a n c h  C h i e f