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CORRESP
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      Response to April 24, 2007 SEC Comment Letter

                                                          American
      Electric
      Power

                                                                    1
      Riverside Plaza

                                                                    Columbus,
      OH 43215-2373

                                                                       Joseph
      M.
      Buonaiuto

Senior
      Vice
      President

                                                                       &
Chief
      Accounting
      Officer

                                                                       614-716-2821

                                                                       fax:
      614-716-1187

                                                                       jmbuonaiuto@aep.com

        Securities
          and Exchange Commission

        100
          F
          Street NE

        Washington,
          DC 20549

        May
          8,
          2007

        RE:      American
          Electric Power Company, Inc., File No. 1-3525

        AEP
          Generating Company, File No. 0-18135

        AEP
          Texas
          Central Company, File No. 0-346

        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. 0-343

        Southwestern
          Electric Power Company, File No. 1-3146

        Form
          10-K
          for the fiscal year ended December 31, 2006

        Filed
          February 28, 2007

        Responses
          to the comment letter dated April 24, 2007 from the staff (the “Staff”) of the
          Securities and Exchange Commission (the “Commission”) regarding the
          above-captioned Report are provided herewith, including the text of the
          Staff’s
          comments.

        ***

        Form
          10-K for Fiscal Year Ended December 31, 2006

              1.

                Our
                  records show the File Number for AEP Texas Central Company is 1-12973,
                  rather than file number 0-346 that appears on the cover page of
                  your
                  reports. Likewise, our reports show the File Number for Public
                  Service
                  Company of Oklahoma is 1-12945 rather than file number 0-343 that
                  appears
                  on the cover page of your reports. Please make the appropriate
                  revisions.

        Response:

        We
          believe the file numbers of 0-346 for AEP Texas Central Company (“ATC”) and
          0-343 for Public Service Company of Oklahoma (“PSO” and, with ATC, “Filers”) as
          reflected on the Annual Report on Form 10-K (the “Form 10-K”) are accurate. The
          Commission’s EDGAR database indicates that the foregoing file numbers were used
          for these registrants from 1995 through early 1997.

        In
          1997,
          both Filers formed wholly-owned trusts that issued trust-preferred securities
          in
          registered offerings. These securities were initially registered on the
          NYSE.
          Accordingly, at the time of issuance, the Filers each filed a Form 8-A
          with the
          Commission, and new file numbers were issued. In each of these transactions,
          the
          trust was identified as the issuer and ATC and PSO were identified as
          guarantors. These securities are no longer outstanding.

        We
          did
          not believe that the Filers adopted the new SEC File Numbers as a result
          of
          these filings. We believe the original SEC File Number assigned to ATC
          (0-346)
          and PSO (0-343) are the correct file numbers. Tom Berkemeyer in our Legal
          Department spoke with Velma Smith in the SEC’s EDGAR Support Group to discuss
          this issue. Once the SEC EDGAR Support Group advises us of the appropriate
          file
          numbers, PSO and ATC will use those file numbers in future filings.

        Exhibit
          13

        American
          Electric Power Company, Inc. and Subsidiary Companies

        Management’s
          Financial Discussion 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 share 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. Refer to Item 10(e)(1)(i) of Regulation S-K and Question
                  11
                  of our “Frequently Asked Questions Regarding the Use of Non-GAAP
                  Measures,” available on our website at www.sec.gov.

        Response:

        In
          future
          filings, AEP will remove the earnings per share by segment
          information.

        Utility
          Operation, 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 Operations” 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.

        Response:

        AEP’s
          interest in the Plaquemine Facility (“Facility”) was sold in the fourth quarter
          of 2006. The interest in the Facility was recorded on the books of a nonutility
          subsidiary of AEP whose operations were included in “All Other” in the Business
          Segments Footnote. The interest in the Facility was recorded as an owned
          asset
          under a lease financing transaction with Juniper Capital L.P. (reference
          AEP’s
          2003 Form 10-K, page A-109). The Facility was subleased to Dow Chemical
          Company
          (“Dow”) which used a portion of the energy produced by the Facility and sold
          the
          excess energy to AEP Power Marketing, Inc. (“AEPM”) pursuant to a purchase power
          and sale agreement (“PPA”).

        Before
          the Facility commenced operations, AEPM assigned its rights under the PPA
          to
          Ohio Power Company (“OPCo”), one of AEP’s utility subsidiaries. AEPM did not
          have a trading organization in place to support sales of power from the
          Facility, and under the Code of Conduct of the Federal Energy Regulatory
          Commission (“FERC”), AEPM could not use the existing trading organization at
          American Electric Power Service Corporation (“AEPSC”), which acts as agent for
          OPCo for power sales. OPCo’s retail generation rates had become deregulated in
          September 2000 and it had existing authorization from the FERC to sell
          wholesale
          power at market-based rates. The most efficient way to perform under this
          PPA
          was to assign it from AEPM to OPCo, thereby avoiding the necessity to form
          and
          maintain a separate trading organization. However, in order to mitigate
          any risk
          of potential losses related to this contract at a public utility company,
          OPCo
          entered into an indemnification agreement for this contract with the parent
          of
          AEPM (AEP Resources, Inc. or “AEPR”). When market revenues were less than the
          related incurred costs, AEPR paid OPCo an indemnity adjustment. The indemnity
          agreement between AEPR and OPCo effectively held OPCo harmless from market
          exposure related to its PPA with Dow.

        The
          PPA
          required OPCo to purchase up to approximately 800 MW of such excess energy
          from
          Dow for a 20-year term. The Facility was a major source of steam supply
          for Dow
          which operated the Facility at certain minimum levels. OPCo was obligated
          to
          purchase the energy generated at those minimum operating levels. The PPA
          required OPCo to reimburse Dow for the operation and maintenance costs
          of the
          Facility, including fuel. The indemnity adjustment was required within
          each
          respective quarter and year for the Facility’s operations from March 2004
          through December 2006.

        Although
          both OPCo and AEP’s “Utility Operations” segment had no net income impact from
          the transactions related to the Facility, it did have fluctuations in related
          expenses and revenues. The indemnification payment to OPCo from AEPR effectively
          transferred any risk of loss associated with the Facility to AEPR, which
          is
          reflected in the “All Other” Business Segments footnote consistent with the
          actual economics of the respective Facility transactions.

        Consolidated
          Statements of Income, page A-45

              4.

                Please
                  present the subtotal “Income before extraordinary items and cumulative
                  effects of changes in accounting principles” as required by Item
                  5-03(b)(16) of Regulation S-X.

        Response:

        In
          future
          filings, AEP and its registrant subsidiaries will include the subtotal
“Income
          before extraordinary items and cumulative effects of changes in accounting
          principles”, when applicable.

        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 organizations. Specifically address
                  whether
                  you account for these transactions on a gross or net
                  basis.

        Response:

        Most
          of
          the power produced at the generation plants of our East operating companies
          (Appalachian Power Company, Columbus Southern Power Company, Indiana Michigan
          Power Company, Kentucky Power Company and Ohio Power Company, collectively,
          the
“AEP East Companies”) is sold to PJM, the regional transmission organization
          (“RTO”) operating in our service territory, and we purchase power back from the
          same RTO to supply power to our load. These power sales and purchases are
          reported on a net basis in Operating Revenues in the respective registrants’
financial statements. Other RTOs in which the Company operates do not function
          in the same manner as PJM. They function as balancing organizations and
          not as
          an exchange.

        For
          the
          remaining power transactions with RTOs, we account for the following types
          of
          energy marketing and risk management activities as follows:

              ·

                On
                  page A-56 of the 2006 Form 10-K, in the third sentence of the second
                  paragraph under Energy
                  Marketing and Risk Management Activities
                  states: "We include the unrealized and realized gains and losses
                  on
                  wholesale marketing and risk management transactions that are accounted
                  for using MTM in Revenues on our Consolidated Statements of Income
                  on a
                  net basis".

              ·

                Certain
                  physical energy purchases from RTOs that are identified as non-trading
                  (accrual accounting treatment) are accounted for on a gross basis
                  in
                  Purchased Energy for Resale in the AEP Consolidated Statements
                  of Income,
                  and Purchased Electricity for Resale in the subsidiaries' Statements
                  of
                  Income.

        In
          future
          filings, AEP and its registrant subsidiaries will expand our disclosure
          related
          to sales and purchases to and from RTOs.

        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
                  accounts, net of salvage, to accumulated depreciation rather than
                  recording a gain or loss.

        Response:

        The
          AEP
          Utility Operations segment’s generation fleet provides power to its cost based
          regulated utilities and is managed as an integrated pool. In Ohio and Virginia
          (until recently), generating plants are considered nonregulated. However,
          operationally they were retained in AEP’s power pool and used to supply power to
          the east utility operating companies. In addition, several of the generating
          plants are jointly owned and are considered both “regulated” and “nonregulated”
(see discussion below). Because the operational nature of the nonregulated
          plants did not change, AEP did not change its depreciation policies related
          to
          the plants that are considered “nonregulated”. Accordingly, these generation
          assets continued to be included in the assets of the Utility Operations
          segment.

        At
          certain generating plants, the individual generating units are owned by
          utilities whose generation rates are both regulated and nonregulated. For
          example, Amos generating Unit 3 is owned 2/3 by Ohio Power (nonregulated)
          and
          1/3 by Appalachian Power (regulated in West Virginia and nonregulated in
          Virginia). At Sporn Generating Plant, generating Units 1 and 3 are owned
          by
          Appalachian Power (regulated in West Virginia and nonregulated in Virginia)
          and
          generating Units 2, 4 and 5 are owned by Ohio Power Company (nonregulated).

        Retirements
          from the plant accounts, net of salvage, are charged to accumulated depreciation
          for nonregulated operations because AEP has continued accounting for its
          nonregulated operations using the group composite method of depreciation.
          AEP
          believes the gr