Case intelligence reportCASE-08-06

AEP Ohio Schedule DCT tariff cluster

AEP Ohio Schedule DCT is effective with appeal pending; cohort C9.

Executive summary

Read the conclusion before the archive.

  1. AEP Ohio Schedule DCT is effective with appeal pending; cohort C9.
  2. The verified path stops at C9; the next transition remains bounded by the public record.
  3. No customer-specific C10 or operating-capacity claim.

01 · Case brief

Why this mechanism belongs in the portfolio.

Effective large-load tariff with litigation and nonpublic customer states. The cluster is retained for its evidentiary function, not as a representative sample or ranking.

01

Observed mechanism

AEP Ohio Schedule DCT is effective with appeal pending; cohort C9.

02

Unverified transition

Named LOA/ESA execution; project approval; energization; rate outcome; final appeal

03

Quantitative basis

Tariff thresholds/terms only; no operating MW

Figures remain attached to their stated unit and state basis.

Decision boundary

The evidence ceiling

Permitted conclusion

Effective C9 tariff pathway with appeal pending.

Prohibited stronger claim

No customer-specific C10 or operating-capacity claim.

Quantitative ceiling
Tariff terms only
Causal ceiling
No rate or project outcome causation

02 · Institutional control

The outcome depends on a distributed permission stack.

No actor, filing or contract is allowed to stand in for the entire conversion chain.

01

Tariff

02

service process

03

collateral/minimum demand

04

judicial review

Controlling actors

Institutions with decision rights

  • PUCO
  • AEP Ohio
  • Ohio Supreme Court
  • customers

Controlling instruments

Documents and mechanisms

  • Schedule DCT, PUCO order, appellate docket

03 · Event sequence

The verified path and the point where proof stops.

The sequence records documentary transitions. It does not imply a standard duration, inevitability or linear progression.

  1. 01

    PUCO approval

  2. 02

    tariff effectiveness

  3. 03

    appeal pending

  4. —
    Blocked or unverified next transition

    Named LOA/ESA execution; project approval; energization; rate outcome; final appeal

04 · Rival tests

Alternative explanations that materially narrow the claim.

A rival “win” does not reverse the record. It defines the strongest inference that survives the contrary evidence.

01

RW-0010 · MATERIAL WIN

Legal/implementation uncertainty

Tested against
Assumption that approved tariff is finally settled and project-complete
Evidence result
Effective tariff remains under appeal and customer states are nonpublic
Ceiling effect
C9 only
Prohibited inference
No named agreement or capacity

Documented adaptation

The mechanism changed; the outcome remains bounded.

ADAPT-0007 · Customer risk security

Schedule DCT service process, term, collateral, minimum demand and assignment controls

Trigger or constraint
Large-load infrastructure and exit risk
Evidence / implementation
Effective tariff · EFFECTIVE / APPEAL PENDING
Observed outcome
Framework in force; customer outcomes unknown
Claim ceiling
C9 mechanism only

05 · Claim register and evidence file

Load-bearing claims and the record that resists them.

8 linked claims, 4 primary source references and explicit contrary or negative evidence are retained under stable IDs.

CLM-0020 · legal status

Ohio, Georgia, and Virginia have public regulatory records creating or approving large-load/data-center-specific rate or contract pathways, but their terms, procedural finality, and risk allocation differ and cannot be collapsed into one regime.

Claim ceiling
Existence and heterogeneity only; no conclusion that any regime fully protects ratepayers.
Evidence
Tier A · HIGH for existence; MEDIUM pending full tariff extraction
Locator
Ohio 24-508-EL-ATA and appeal 2025-1458; Georgia >100 MW summary/dockets; Virginia PUR-2025-00058/GS-5

CLM-0077 · legal status

AEP Ohio Schedule DCT was effective on 2025-07-23 and creates a mandatory application, load-study, LOA and ESA pathway for qualifying data-center service requests.

Claim ceiling
Tariff effectiveness and process only; no project approval, deliverability or energization.
Evidence
Tier A · HIGH
Locator
Lines 832-854
Linked sources
SRC-0099

CLM-0078 · contractual state

Under AEP Ohio Schedule DCT, an LOA can require 100% reimbursement of buildout costs if a customer cancels or delays more than 12 months before target energization, while the ESA term begins on actual energization.

Claim ceiling
Public tariff terms only; actual customer obligations require an executed agreement.
Evidence
Tier A · HIGH
Locator
Lines 851-854
Linked sources
SRC-0099

CLM-0079 · contractual state

AEP Ohio Schedule DCT uses a ramp of no more than four years, an initial term equal to ramp plus eight years, a 50% full-term minimum-charge collateral requirement absent stated credit/liquidity tests, and a minimum-demand formula capped at 85% of contract capacity.

Claim ceiling
Terms allocate risk; they do not prove full cost recovery or actual consumption.
Evidence
Tier A · HIGH
Locator
Lines 866-885
Linked sources
SRC-0099

CLM-0080 · legal status

The AEP Ohio data-center tariff remains subject to an active Ohio Supreme Court appeal at the cutoff; current tariff operation and judicial finality are distinct states.

Claim ceiling
Effective tariff status may coexist with pending appellate review.
Evidence
Tier A · HIGH
Locator
PUCO order; Supreme Court Case 2025-1458; OCC filing index

CLM-0097 · interpretation

Across the six inspected tariff regimes, thresholds, terms, minimum-billing formulas, deposits/collateral, exit obligations and resource rules vary materially; there is no single U.S. large-load tariff template in the inspected public record.

Claim ceiling
Bounded to inspected regimes and cutoff; not an exhaustive census.
Evidence
Tier A · HIGH
Locator
Pass 04 tariff ledger
Show 2 additional linked claim IDs

CLM-0107CLM-0203

Contrary evidence and competing mechanisms

CTR-0004 · Private-risk allocation

Tariffs, collateral, minimum bills, contract terms, and exit provisions may shift material risk to large-load customers.

Evidence result:Ohio, Georgia, and Virginia records establish differentiated large-load rate/contract pathways, while consumer/intervenor records contest adequacy and legal status varies.

Ceiling effect:No claim that risk is fully shifted or ratepayers fully protected.

CTR-0025 · Private-risk allocation

Ohio appeal contests sufficiency/finality of approved tariff protections.

Evidence result:OCC current filing registry and Supreme Court appeal record remain active.

Ceiling effect:Prevents claim of uncontested finality or proven full protection.

CTR-0026 · Private-risk allocation

Georgia Commission retained jurisdiction and may revise its framework.

Evidence result:Order expressly retains review and modification authority.

Ceiling effect:Prevents immutable/complete-framework claim.

CTR-0027 · Private-risk allocation

Virginia requires future alternative generation/transmission allocation proposals.

Evidence result:SCC fact sheet states future proposals remain required.

Ceiling effect:Prevents claim GS-5 closes all cost-allocation questions.

CTR-0028 · Private-risk allocation

I&M terms resulted from compromise among materially different proposed thresholds and obligations.

Evidence result:Settlement testimony documents utility, consumer and data-center positions.

Ceiling effect:No single design proven optimal.

CTR-0029 · Policy/data uncertainty

Tariff structures are heterogeneous across states and utilities.

Evidence result:Pass 04 six-regime comparison shows different thresholds, terms, deposits and resource rules.

Ceiling effect:No national-template claim.

Public-record gaps

NEG-0005

Question checked:Are all customer-specific obligations in large-load contracts public?

No; redactions and framework-only public records remain.

Implication:Framework-level claim ceiling; REDACTION GAP.

NEG-0027

Question checked:Is there one uniform U.S. large-load tariff design?

NO. Thresholds, terms, collateral and cost-allocation mechanisms differ materially.

Implication:Use bounded portfolio comparisons only.

NEG-0028

Question checked:Does an effective/approved tariff prove all stranded costs are recovered?

NO comparable ex post dataset was located.

Implication:Outcome/causal ceiling remains low.

Show the complete linked control-ID index
Contrary evidence
CTR-0004CTR-0025CTR-0026CTR-0027CTR-0028CTR-0029CTR-0066
Negative findings
NEG-0005NEG-0027NEG-0028
Reopen controls
OIR-0007OIR-0024OIR-0029

06 · Record maintenance

What would justify reopening this report.

Updates require a documented evidence delta. Passage of time, repetition of an announcement or a portfolio-level disclosure is not enough.

What could change this record

  • OIR-0007 · Ohio appeal resolves, or Ohio/Georgia/Virginia tariffs/contracts are modified, stayed, superseded, or implemented through new sheets/orders.

    Required update: Retrieve final holdings/effective sheets; record customer obligations, conditions, supersession, and legal finality.

  • OIR-0024 · Ohio Supreme Court issues a decision, stay, remand or other material action in Case 2025-1458, or PUCO/AEP supersedes Schedule DCT.

    Required update: Inspect controlling judgment/order and effective tariff; record supersession and customer-obligation changes.

  • OIR-0029 · Comparable ex post cost, default, stranded-cost or rate-impact data become public for an inspected tariff.

    Required update: Add outcome dataset with denominator, counterfactual/rivals and causal ceiling.

Record navigation

These records share claims or sources with this report. The linkage supports navigation, not a causal inference.

  • PS-0008Regulatory Or Tariff Framework

    AEP Ohio data-center customer cohort

    Geography
    Ohio
    State handling
    Framework status with scoped C9/C10 only; participant states unknown
    3 shared sources

Sources — bibliography and exact locators

  1. SRC-0041 — Data Centers — Ohio PUCO Resource Page

    Public Utilities Commission of Ohio · 2025-07-09 · Tier A-minus

    Locator: Case links and tariff resources

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  2. SRC-0042 — PUCO Orders AEP Ohio to Create Data Center-Specific Tariff

    Public Utilities Commission of Ohio · 2025-07-09 · Tier A-minus

    Locator: Case 24-508-EL-ATA; official summary

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  3. SRC-0044 — Merit Brief, Supreme Court of Ohio Case 2025-1458

    Supreme Court of Ohio / appellant · 2026-02-02 · Tier A

    Locator: Case 2025-1458; appellant merit brief; docket status

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  4. SRC-0099 — Data Center Tariff

    AEP Ohio · 2026-06-18 current page · Tier A

    Locator: Lines 832-888: effective date, study/service process, LOA/ESA, ramp, term, collateral, minimum demand, assignment

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE