American Electric Power

1 Riverside Plaza

Columbus, OH 43215-2373

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-1004

Re: File No. 1-3570

Indiana Michigan Power Company

Annual Report on Form 10-K

Dear Sirs:

On behalf of Indiana Michigan Power Company (the "Company"), we are filing herewith, under the Securities Exchange Act of 1934, the Annual Report on Form 10-K of the Company for the fiscal year ended December 31, 2006.

The financial statements in the 2006 Annual Report, incorporated herein by reference, do not reflect any change in any accounting principles or practices, or in the method of applying such principles or practices, from the financial statements included in the Company's 2005 Annual Report, except as indicated below:

A.   SFAS 158 “Employers’ Accounting for Defined Benefit Pension and Other Postretirement Plans” (SFAS 158)

We implemented SFAS 158 effective December 31, 2006. SFAS 158 requires employers to fully recognize the obligations associated with defined benefit pension plans and other postretirement employee benefit plans, which include retiree healthcare, in their balance sheets. We reported the effect of implementation of SFAS 158 as an adjustment to Accumulated Other Comprehensive Income offset by adjustments to SFAS 71 regulatory asset and deferred income tax asset.

For more detailed information regarding the above-mentioned accounting changes, please refer to Notes 2 and 9 in the Notes to Financial Statements of Registrant Subsidiaries within the 2006 Annual Report included in Item 8, “Financial Statements and Supplementary Data,” of the Form 10-K.

Very truly yours,

/s/Thomas G. Berkemeyer

Assistant Secretary

(614) 716-1648