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AEP Ohio filed an application that asks the Commission to revisit a “proposed solution to address volatile pricing impacts for SSO customers when data centers return to the SSO from community aggregation.”

This proposal had been proposed previously but was withdrawn in the utility’s most recent ESP V settlement. In that proceeding AEP Ohio proposed that large load data center customers must provide advance notice if they wish to participate in the SSO and to conduct a separate auction to help prevent pricing impacts of such large load shifts for SSO customers. As part of the rate case settlement adopted by the Commission, the AEP Ohio agreed to withdraw its SSO proposal.

In its most recent application AEP Ohio states that it would like to “engage stakeholders prior to finalizing its proposed tariff through an entry that establishes the following procedural steps: (a) intervention deadline, (b) a series of three technical workshops or stakeholder meetings to discuss the proposal and alternative solutions, perhaps starting with a discussion of implementing the interim relief (see below), (c) a period of engagement in settlement discussions with SSO customers, and (e) additional steps deemed appropriate by the Commission. If the Commission does not wish to use this cooperative process or if the process is utilized but does not lead to a settlement, the Company can proceed to amend its Application and add a proposed tariff.”

In its application AEP Ohio also includes the following principles that it states should guide the outcome:

1) Data center customers should pay for the generation costs they are causing during any period they rely on the SSO.

2) Non-data center SSO customers should not pay for the generation costs driven by data center customers.

3) CRES Providers should be the LSE that is assigned RBA costs for any period of time they are supplying competitive generation service to the underlying data center load; to the extent AEP Ohio is required to provide SSO generation supply to data centers and is considered the LSE during that period, the additional steps below should be followed.

4) Ideally, the multi-year RBA price would follow the data center MWs being served – from CRES provider to CRES provider or to the SSO (i.e., data centers that do not provide their own generation and, instead, elect to rely on RBA generation resources should pay the resulting RBA price assigned to the LSE for the full term of the generation commitment, regardless of whether they shop and with whom they shop including any period of relying on the SSO).

5) If for some reason the RBA price does not follow the data center customer MWs when they return to the SSO, a separate procurement or auction product should be procured for data center load being served by the SSO (i.e., so that the data centers can pay the full price of their procurement without impacting the regular SSO price).

6) Data center customers should provide 180 days advance notice to AEP Ohio prior to returning to the SSO, in order to implement solutions being provided in a timely manner.

7) If the data center does not provide sufficient advance notice before returning to the SSO, spot market purchases will be made during any period that a separate SSO auction/product can be conducted to serve data center load.

AEP Ohio also recommends that the Commission should adopt interim relief until the new tariff solution can be adopted.

Specifically, AEP Ohio requests that items 5) through 7) above be implemented on an interim basis. If the Commission adopts the interim relief requested to require data center customers that wish to return to the SSO to provide 180 days advance notice in order to be served by a separate auction/product (or simply be served by spot market procurement if in adequate notice was provided), the Company will submit a detailed compliance plan to modify AEP Ohio’s CBP and associated auction procures accordingly.

The utility thereby requests that the Commission issues orders adopting the interim relief described above and establishing the procedural schedule as detailed above.