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      SEC Response Letter Dated 11-6-06

                            November
      6,
      2006

    Mr.
      Jim Allegretto

    Senior
      Assistant
      Chief Accountant

    Division
      of
      Corporation Finance

    Securities
      and
      Exchange Commission

    Mail
      Stop
      3561

    100
      F Street, N.E.

    Washington,
      D.C.
      20549

              Re:

              FirstEnergy
                Corp.

              Form
                10-K for
                Fiscal Year Ended December 31, 2005

              Filed
                March 2,
                2006

              Forms
                10-Q for
                Fiscal Quarters Ended

              March
                31, 2006
                and June 30, 2006

              File
                No.
                333-21011

    Dear
      Mr.
      Allegretto:

    This
      letter is in
      response to your further correspondence dated October 23, 2006 regarding your
      review of the filings by FirstEnergy Corp. on Form 10-K for the fiscal year
      ended December 31, 2005 (Form 10-K), and Forms 10-Q for the periods ended
      March 31, 2006 and June 30, 2006. Your additional comment is indicated
      below in italics, followed by our response.

Form
      10-K for
      Fiscal Year Ended December 31, 2005

    Exhibit
      13

    Management’s
      Discussion and Analysis of Results of Operations and Financial

    Condition,
      page
      4

    Executive
      Summary, page 4

             1.

              We
                have
                reviewed your response to comment 3 in our letter dated September
                8, 2006.
                Please confirm that you will revise your disclosure in future filings
                to
                disclose the information you present in the first sub-response to
                comment
                3. Further, you state that you have never used the non-GAAP measures
                in an
                attempt to smooth earnings, thereby suggesting that Question 8 of
                the
                “Frequently Asked Questions Regarding the Use of Non-GAAP Financial
                Measures” is inapplicable. Similarly, you indicate that all items excluded
                from net income in arriving at “earnings before unusual items” are
                non-recurring. Please note that we view items such as asset impairments
                collectively in relation to each other in determining whether they
                are
                recurring. As such, we consider many of these items, such as asset
                impairments, rate settlements, plant outages, and tax adjustments,
                to be
                recurring in nature. As you have excluded items of a recurring nature
                in
                arriving at both “earnings before unusual items” and “cash earnings,” we
                believe Question 8 is applicable. As such, please show us how your
                revised
                disclosures, which should fully discuss each bullet point of Question
                8,
                will read in future filings. While you indicate management frequently
                references non-GAAP measures in decision-making, ensure you explain
                in
                greater detail how you use the non-GAAP measures to conduct or evaluate
                your business. For example, are such performance measures used in
                budgetary, compensatory or resource allocation decisions? If you
                do not
                use the measures in managing your business, please revise to remove
                such
                measures from your filing. Finally, please tell us in detail how
                you use
                “cash earnings” to measure performance since it appears to be more akin to
                a liquidity measure.

    Mr.
      Jim
      Allegretto

    November
      6,
      2006

    Page
      2 of
      4

              Response:
                We
                hereby
                confirm the representation included in our letter to you dated September
                21, 2006, that we will revise our disclosures in future filings to
                disclose the information we presented in the first sub-response to
                comment
                3 of that letter.

              With
                respect
                to your questions regarding our use of the non-GAAP “cash earnings”
                measure, please be advised that we do not exclude any unusual items
                (as we
                use that term respecting our non-GAAP “earnings before unusual items”
                measure) from the calculation. We include a reconciliation of net
                income
                computed under GAAP to the non-GAAP “cash earnings” measure, showing the
                major non-cash charges or credits to income (e.g., depreciation,
                amortization of regulatory assets, deferral of new regulatory assets).
                The
                intent of that non-GAAP measure is to provide readers of the cash
                flow
                statement with an enhanced understanding of how cash was provided
                from
                operating activities - by segregating earnings that are realized
                in cash
                during a typical business cycle from the effects of working capital
                changes and other impacts to operating cash flows due to the timing
                of
                cash receipts and payments. This comparison tends to separate the
                cash
                impacts of operational performance versus working capital management
                and
                is used by management for cash forecasting, analyzing operational
                performance (i.e., as a budgetary control) and identifying
                trends.

              The
                non-GAAP
                “earnings before unusual items” measure is used by management as a
                budgetary control that in some cases influences resource allocation
                issues. The Board of Directors also uses this non-GAAP measure as
                one
                component in its analysis in awarding performance-based compensation
                to
                executive management and employees.

              In
                future
                filings, we will include disclosure similar to the following for
                the
                non-GAAP “earnings before unusual items” measure:

              The
                non-GAAP
                measure above, earnings before unusual items, is not calculated in
                accordance with GAAP because it excludes the impact of “unusual items”.
                Unusual items reflect the impact on earnings of events that are not
                routine or for which FirstEnergy believes the financial impact will
                disappear or become immaterial within a near-term finite period.
                By
                removing the earnings effect of such issues that have been resolved
                or are
                expected to be resolved over the near-term, management and investors
                can
                better measure FirstEnergy’s business and earnings potential. In
                particular, the non-core asset sales/impairments items refer to a
                finite
                set of energy-related assets that had been previously disclosed as
                held
                for sale, a substantial portion of which have already been sold.
                Similarly, the NRC fine in 2005 and further litigation settlements
                similar
                to the New Source Review settlement in 2005 are not reasonably expected
                to
                occur in the near-term.

      Mr.
        Jim
        Allegretto

      November
        6,
        2006

      Page 3
        of
        4

                  FirstEnergy
                    believes presenting normalized earnings calculated in this manner
                    provides
                    useful information to investors in evaluating the ongoing results
                    of
                    FirstEnergy’s businesses over the longer term and assists investors in
                    comparing FirstEnergy’s operating performance to the operating performance
                    of others in the energy sector. Generally, a non-GAAP financial
                    measure is
                    a numerical measure of a company’s historical or future financial
                    performance, financial position, or cash flows that either excludes
                    or
                    includes amounts, or is subject to adjustment that has the effect
                    of
                    excluding or including amounts, that are not normally excluded
                    or included
                    in the most directly comparable measure calculated and presented
                    in
                    accordance with GAAP. Earnings per share before unusual items
                    on a
                    non-GAAP basis (normalized earnings per share) are not calculated
                    in
                    accordance with GAAP because it excludes the impact of “unusual items.”
                    Unusual items reflect the impact on earnings of material events
                    that are
                    not routine, including those that may be related to discontinued
                    businesses or the cumulative effect of an accounting change.

              The
                non-GAAP
                normalized earnings measure is an important performance metric used
                by
                management to assess the financial results of its business units
                against
                plan for the current year, to establish future performance targets
                and
                identify resources required by business units to reach those targets.
                This
                measure also assists management in setting FirstEnergy’s performance
                expectations with the investment community for future periods, in
                addition
                to assisting investors in comparing FirstEnergy’s operating performance to
                the operating performance of other companies in the energy sector.
                Using
                non-GAAP normalized earnings-based measures limits the ability to
                compare
                FirstEnergy’s economic value added or eroded based on net income computed
                under GAAP and similar comparisons to that of peer companies. Therefore,
                FirstEnergy clearly discloses the differences between the GAAP and
                non-GAAP measures to compensate for that limitation. Non-GAAP measures
                should be considered in addition to, and not as a substitute for,
                their
                most directly comparable financial measures prepared in accordance
                with
                GAAP.

      *
        * * *

      FirstEnergy
        Corp.
        hereby acknowledges that:

            ·

              FirstEnergy
                is
                responsible for the adequacy and accuracy of the disclosures relating
                to
                its annual report on Form 10-K for the year ended December 31, 2005
                and
                its Forms 10-Q for the quarters ended March 31, 2006 and June 30,
                2006;

            ·

              Staff
                comments
                or changes to disclosure in response to staff comments do not foreclose
                the Securities and Exchange Commission from taking any action with
                respect
                to the filing; and

      Mr.
        Jim
        Allegretto

      November
        6,
        2006

      Page 4
        of
        4

            ·

              FirstEnergy
                may not assert staff comments as a defense in any proceeding initiated
                by
                the Securities and Exchange Commission or any person under the federal
                securities laws of the United
                States.

      Please
        feel free to
        call me (330-384-5296) or Jeffrey R. Kalata, Assistant Controller (330-374-6580)
        with any further questions you may have. I appreciate your assistance in
        ensuring our compliance with the Commission’s disclosure
        requirements.

                Sincerely,

                Harvey
                  L.
                  Wagner

                Vice
                  President, Controller and

                Chief
                  Accounting Officer

      HLW:dlc

      Attachment

                cc:

                Sarah
                  Goldberg

                Staff
                  Accountant

                Securities
                  and
                  Exchange Commission

                Anthony
                  J.
                  Alexander

                Richard
                  H.
                  Marsh

                Leila
                  L.
                  Vespoli