WILLIAM C. PORTH ATTORNEY AT LAW ROBINSON &McELWE p 0. BOX 1791 CHARLESTON, WV 25326 DIRECT DIAL (304) 347-8340 E-MAIL wc@raiiiia\~ coin May 8,2014 - *. -.I. BY HAND DELIVERY Ms. Ingrid Ferrell Executive Secretary West Virginia Public Service Commission 201 Brooks Street Charleston, vu"v' 2.5301 Re: Appalachian Power Company and Wheeling Power Company Case No. 14-0546-E-PC Dear Ms. Ferrell: I enclose herewith the Commission's copy of the responses of Appalachian Power Company and Wheeling Power Company to the Consumer Advocate Division's Fourteenth Request for Information in the above-referenced-proceeding. I William C. Porth (W.Va. State Bar #2943) Appalachian Power Company and Wheeling Power Company WCP:ss Enclosures cc: Service List (w enc.) {R0903332.1} Charleston, WV I Clarksburg, WV I Wheeling, WV 1 Alliance, OH AFLA International Member wiw.ramlaw.com
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY WEST VIRGINIA CASE NO. 14-0546-E-BC FOURTEENTH REQUEST FOR INFORMATION - CAD Request A-73 Refer to the attached SEC filing Form 8-K of Duke Energy dated February 17, 2014 and the accompanying news article from the Dayton Daily news dated Feb. 18,2014. These attachments indicate that Duke Energy plans to sell 13 power plants with approximately 6,600 MWs total capacity at approximately $1-2 billion below current book value. Have the Companies: a) evaluated whether WPCo can meet its load requirements with any of this available capacity at a lower cost to ratepayers than in its current proposal? (i) If not, why not? Please provide the results of such evaluation and please produce each and every document related to such evaluation; (ii) If so, please provide the results of such evaluation and please produce each and every document related to such evaluation. b) made inquiries about whether Duke Energy will consider selling any of the plants individually? (i) If so, please list each and every communication with Duke Energy or its representatives, specifying date, time, place, and each and every person that was a part of the communication, and please produce each and every document related to such evaluation, whether electronic or hard copy. (ii) If not, why not? Please identify each and every person that was in any way involved in the determination not to investigate whether Duke Energy would consider selling any of the plants individually and produce and please produce each and every document related to such investigation. Response A-73 a) - b) The Companies have not made inquiries of Duke Energy. In March, 2014, Duke Energy s financial advisor indicated to AEP that Duke was not inclined to sell individual assets from its Midwest portfolio of power plants. The Companies have not performed any evaluation of any individual Duke asset.
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY WEST VIRGINIA CASE NO. 14-0546-E-PC FOURTEENTH REQUEST FOR INFORMATION - CAD Reauest A-74 Refer to the attached SEC filing Form 8-K of Duke Energy dated February 17, 2014 and the accompanying new article from the Dayton Daily news dated Feb. 18, 2014. Please identify which of the plants Duke Energy is selling are co-owned by AEP or any AEP affiliate or subsidiary. Specify the plant name, nameplate generation capacity, and each plant co-owner and its percentage ownership. Response A-74 AEP Generation Resources Inc. co-owns the following units with Duke Energy Ohio and Dayton Power & Light.
PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 14-0546-E-PC APPALACHIAN POWER COMPANY and WHEELING POWER COMPANY both dba AMERICAN ELECTRIC POWER, Petition for acquisition of Mitchell plant by Wheeling Power Company. CERTIFICATE OF SERVICE I, William C. Porth, counsel for Appalachian Power Company and Wheeling Power Company, do hereby certify that true copies of the foregoing discovery responses were served by hand delivery or first-class U.S. Mail on this 8th day of May, 2014, addressed to the following: Wendy Braswell, Esquire Public Service Commission 201 Brooks Street Charleston, West Virginia 25301 Staff of West Virginia Public Service Commission Tom White, Esquire Consumer Advocate Division 7fh Floor, Union Building 723 Kanawha Blvd., East Consumer Advocate Division Damon E. Xenopoulos, Esquire Brickfield, Burchette, Ritts & Stone, PC 1025 Thomas Jefferson St., NW 8* Floor - West Tower Washington, DC 20007 Steel of West Virginia, Inc. William V. DePaulo, Esquire 179 Summers St., Suite 232 Derrick P. Williamson, Esquire Spilman Thomas & Battle, PLLC 1100 Bent Creek Blvd., Suite 101 Mechanicsburg, PA 17050 West Virginia Energy Users Group Susan J. Riggs, Esquire Keith Fisher, Esquire Spilman Thomas & Battle, PLLC 300 Kanawha Blvd., East West Virginia Energy Users Group Charles K. Gould, Esquire Thomas E. Scarr, Esquire Jenkins Fenstermaker, PLLC 325 Sth Street, Znd Floor Huntington, WV 2570 1 Steel of West Virginia, Inc Emmett Pepper, Esquire 1500 Dixie Street Charleston, WV 253 11 {R0903333.1}
Zachary M. Fabish, Esquire 50 F Street, NW, 8* Floor Washington, DC 2000 1 Mike Becher, Esquire Appalachian Mountain Advocates P.O. Box 507 Lewisburg, WV 24901 Vincent Trivelli, Esquire 178 Chancery Row Morgantown, WV 26505 WV State Building & Construction Trades Council, AFL-CIO Stephen J. Baron J. Kennedy & Associates, Inc. 570 Colonial Park Drive, Suite 305 Roswell, GA 30075 Consultant for WVEUG Kevin Ellis, Esquire PO Box 323 1 Charleston, WV 25332 WVONGA %&- William C. Porth (WV State Bar ID No. 2943) (R0903333.1)