Record · Tariffs
AEP Ohio Schedule DCT (Data Center Tariff), P.U.C.O. No. 22 Original Sheet Nos. 223-1 to 223-7 — the terms as filed, and which of them bite at the One Power "Findlay Megawatt Hub"
aep-dct-tariff-posture
meta
- subject AEP Ohio Schedule DCT (Data Center Tariff), P.U.C.O. No. 22 Original Sheet Nos. 223-1 to 223-7 — the terms as filed, and which of them bite at the One Power "Findlay Megawatt Hub"
- kind tariff-posture
- captured_for issue 1464 (epic 1265, readiness(findlay) — grid posture)
- extracted_at 2026-07-31
- method Verbatim read of the tariff sheets in Ohio Power Company's own filed tariff book. Every quoted term below is from the sheets, not from a press summary or a law-firm client alert. Procedural history and the appeal are sourced separately and tagged accordingly.
- sources
- primary
- file data/documents/grid/findlay/July_24_2026_AEP_Ohio_Tariff_Book.pdf
- file data/documents/grid/findlay/20250916-item-04f---aep-large-load-request.pdf
- url https://www.supremecourt.ohio.gov/pdf_viewer/pdf_viewer.aspx?pdf=1000491.pdf&subdirectory=2025-1458%5CDocketItems
- secondary
- url https://content.govdelivery.com/accounts/OHPUC/bulletins/3e8bb79
- url https://www.aepohio.com/company/about/rates/data-center-tariff/
- url https://www.aepohio.com/company/news/view?releaseID=10753
- primary
procedural_history
- tag [reference]
- statement AEP Ohio filed its Application for Approval of New Tariffs on 2024-05-13 in PUCO Case No. 24-508-EL-ATA. The Commission issued its order adopting a settlement on 2025-07-09 (signatories reported as AEP Ohio, PUCO Staff, the Office of the Ohio Consumers' Counsel, the Ohio Energy Group, Walmart and Ohio Partners for Affordable Energy), ordering AEP Ohio to file updated tariffs and to "lift its moratorium on connecting new data centers as soon as possible." The compliance tariff followed on 2025-07-11 and took effect 2025-07-23.
- why_reference_not_verified The Commission's Opinion and Order itself is NOT in the corpus. PUCO's Docketing Information System (dis.puc.state.oh.us) rejects automated retrieval — both the case record and a direct ViewImage document request returned an application-firewall "Request Rejected" page on 2026-07-31 — and PUCO's own news page for this order now 404s, leaving a GovDelivery mirror. So the dates and settlement roster above rest on secondary text. The TARIFF TERMS below do not: those are read off the filed sheets.
- the_tariff_dates_itself
- tag [verified]
- statement The sheets close the loop on their own origin. Sheet 223-2 defines "'Effective Date of Schedule DCT' means the date Schedule DCT became effective following the Commission's order in Case No. 24-508-EL-ATA."
- source tariff book, Original Sheet No. 223-2
- currently_filed_version
- tag [verified]
- statement The sheets captured here are stamped "Filed pursuant to Order dated April 1, 2026 in Case No. 25-392-EL-AIR / Issued: April 8, 2026 / Effective: April 10, 2026" — the schedule as re-issued in AEP Ohio's distribution rate case, not the July 2025 compliance sheet. The tariff book compilation itself is dated 2026-07-24. Any comparison against the 2025 original is [open]; the original compliance sheet is not captured.
- source tariff book, Original Sheet Nos. 223-1..223-7 and Sheet No. 101-1
- on_appeal
- tag [verified]
- statement The order is on appeal to the Supreme Court of Ohio, Case No. 2025-1458, "In the Matter of the Application of Ohio Power Company for New Tariffs Related to Data Centers and Mobile Data Centers," on appeal from Pub. Util. Comm. Case No. 24-508-EL-ATA. Appellant is The Ohio Manufacturers' Association Energy Group (counsel Kimberly W. Bojko, Carpenter Lipps LLP); the PUCO is appellee and the Office of the Ohio Consumers' Counsel filed a merit brief as intervening appellee on 2026-03-24. OMA's propositions of law run to undue discrimination / equal protection, sufficiency of the evidence, and the specificity of the Commission's reasoning under R.C. 4903.09, plus a contention that the case was an application for an increase in rates under R.C. 4909.18.
- disposition
- tag [open]
- statement No decision was located as of 2026-07-31. The tariff is in force pending appeal. Do not write that the tariff has been upheld or vacated.
- source Merit Brief of Intervening Appellee, Office of the Ohio Consumers' Counsel, Ohio S.Ct. No. 2025-1458, filed 2026-03-24 (read at supremecourt.ohio.gov; caption + tables of contents; not committed to the corpus)
terms
- tag [verified]
- source tariff book, Original Sheet Nos. 223-1 through 223-7
- who_it_applies_to
- data_center_definition "a centralized facility (a) used primarily or exclusively for electronic information services such as the management, storage, processing, and dissemination of electronic data and information through the use of computer systems, servers, networking equipment, and related components that (b) has an aggregate monthly maximum demand of greater than 25,000 kW. Unless otherwise specified, the term 'Data Center' shall include 'Mobile Data Center.'"
- mobile_data_center_definition the same, but "(including mining of cryptocurrency)" and "has load that is portable and/or distributable, including but not limited to structures that are not affixed to the ground or are easily removed from a location."
- availability Service is available to customers operating a Data Center that will use, within the initial contract term, a monthly maximum demand greater than 25,000 kW "at a Single Location or an aggregated Total Customer Contract Capacity in Service Territory of greater than 25,000 kW." Mixed sites are swept in whole unless the customer separately meters at its own cost.
- sheet 223-1, 223-2
- existing_vs_new_load
- existing_load "Data Center load for which a letter of agreement or electric service agreement has already been signed by the Effective Date of Schedule DCT." It "does not include Data Center load for which a customer signs a new electric service agreement to expand its Existing Load by more than 25,000 kW of New Load above the contract capacity under the existing electric service agreement after the Effective Date." Un-separately-metered expansions cost the whole load its Existing Load status.
- new_load "(a) Data Center load for which a letter of agreement or electric service agreement was signed after the Effective Date of Schedule DCT or (b) Existing Load that signs a new ESA to increase its contract capacity by more than 25,000 kW." Expansions of 25,000 kW or less do not convert.
- sheet 223-2
- minimum_billing_demand
- existing_load Not less than 60% of the contract capacity or of the highest previously established monthly billing demand in the past 11 months.
- new_load_during_ramp Not less than 85% of the customer's Load Ramp Contract Capacity, where the Load Ramp Contract Capacity is itself floored at 50% / 65% / 80% / 90% of Contract Capacity in Years 1 / 2 / 3 / 4.
- new_load_after_ramp Not less than the greater of (a) 85% of the highest previously established monthly billing demand in the past 11 months, or (b) the "Minimum Demand" table — 15,000 kW plus 85% of the marginal amount over 25,000 kW for a total contract capacity of 25,001-75,000 kW; 57,500 kW plus 100% of the marginal amount over 75,000 kW above that, capped at 85% of total contract capacity.
- aggregation "All New Loads of affiliated companies and companies with common ownership greater than 25,000 kW will be considered in the aggregate" for the Total Customer Contract Capacity, stacked by energization date. Existing Load is excluded from that aggregate.
- sheet 223-3, 223-4
- reconciliation_note This is where the widely repeated shorthand "data centers must pay for 85% of contracted capacity" comes from, and it is close enough to be usable but not precise enough to quote. The 85% is a floor applied to a RAMPED capacity during the ramp and to a rolling 11-month peak (or the Minimum Demand table) afterwards. The Year-4 ramp floor is 90%, which is higher than 85% — the two numbers are not in conflict because they multiply different things. Cite the sheets, not the shorthand.
- contract_term
- new_load "contracts under the Schedule shall be made for an initial period of not less than the Load Ramp Period plus 8 years. By way of example, the initial period of a Contract for a Data Center with a 4-year Load Ramp Period will be 12 years." After the initial term either party needs three years' written notice to terminate or to change Contract Capacity.
- existing_load Existing contracts run on their own terms until terminated under those terms; the Company is not required to supply capacity above Contract Capacity except by mutual agreement.
- exit_fee "If after completion of the fifth year of the Contract after the Load Ramp Period the customer chooses to pay an exit fee equal to minimum charges for 36 months after notice of termination, the customer can thereafter terminate the contract."
- load_additions A new contract is required for any load addition in excess of 100 kW.
- site_control "the customer must designate a specific site at which its Data Center project will be constructed and served by the Company, and the customer must own or have the exclusive right to use the land for this purpose."
- sheet 223-5
- collateral
- new_load Unless the customer holds both an A-/A3 credit rating and liquidity above ten times the requirement, it must post a guarantee, standby letter of credit, or cash equal to 50% of the total minimum charges for the full contract term, reduced by one year's minimum charges for each year energized with on-time payment.
- sheet 223-6
- behind_the_meter_generation
- interconnection_agreement "Consistent with Ohio Administrative Code Chapter 4901:1-22, Schedule DCT Customers shall enter into an interconnection agreement between the Company and the Customer in advance of connecting any source of power other than the delivery point specified in the Contract. Emergency or backup generation that is not designed to operate in parallel with the Company's system is not subject to the additional requirements in this section."
- netting_election A customer electing to use behind-the-meter generation to OFFSET its Contract Capacity must keep equipment in place "to instantaneously curtail load equal to or greater than the behind-the-meter generation output." A customer that does NOT elect to net may have service suspended, with Commission approval, if usage exceeds Contract Capacity by more than 1,000 kW.
- sheet 223-6, 223-7
- mobile_data_center_attestation "Prior to receiving service, Mobile Data Center customers will be required to provide a sworn statement, under penalty of perjury, that neither the customer nor its corporate parent or affiliates are affiliated with or acting on behalf of any foreign adversary as defined in 15 C.F.R. § 7.4," with an immediate disconnection right on a good-faith belief of falsity.
- transmission_voltage_charges Schedule codes 297/797 (transmission service voltage): customer charge $6,800/month plus a supplemental customer charge of $20,000/month, the latter expressly "not a base distribution rate ... and will not apply to Existing Load"; excess reactive demand $0.95/kVAR beyond 50% of metered kW.
- sheet_ref 223-3
findlay_application
- scale_test
- tag [inference]
- statement MARA Holdings' contracted 150 MW at the One Power Findlay Megawatt Hub is 150,000 kW — six times the 25,000 kW threshold — and the 30 MW currently energized already clears it. Whatever else is unresolved, this is not a site that falls below Schedule DCT on size.
- source One Power Co Form S-1 (EDGAR CIK 2039139, filed 2025-01-23) + the tariff's 25,000 kW definition; see data/extracted/findlay/data-centers.md
- crypto_is_named_in_the_tariff
- tag [verified]
- statement The tariff does not leave cryptocurrency mining to interpretation. "Mobile Data Center" is defined to reach electronic information services "(including mining of cryptocurrency)" with portable or distributable load, and "Data Center" is defined to include "Mobile Data Center" unless stated otherwise. MARA Holdings, Inc. is a bitcoin miner. A Findlay compute load of that description, taken as a retail customer of AEP Ohio above 25,000 kW, is squarely inside the definition — and it inherits the sworn foreign-adversary attestation, which is the only place in this tariff where a customer must swear to anything.
- guard MARA Holdings, Inc. (NASDAQ MARA, ex-Marathon Digital) is NOT Marathon Petroleum Corporation (NYSE MPC, the Findlay-headquartered refiner and a Hancock County NPDES permittee). Never merge them. The distinction is live in this very record: One Power's S-1 lists "Marathon Petroleum Company LP, Wyandot County, Ohio, 1.5 MW" as a Wind for Industry customer — a different company, a different county, a different contract.
- who_is_the_retail_customer
- tag [open]
- statement The tariff applies to "the customer," and at this hub it is not established who that is. One Power owns the site and built its own transmission-voltage digital substation; MARA leases capacity behind it under a 15-year take-or-pay lease whose "lease payment is due regardless of whether or not the customer elects to purchase power" (S-1). So the party holding an electric service agreement with AEP Ohio may be One Power rather than MARA, and One Power describes the hub as a multi-tenant "electrified industrial park" for uses spanning fixed and mobile data centers, digital currency mining, electric fleet charging, cathode/anode manufacturing, hydrogen production, indoor farming and additive manufacturing — which is not obviously "used primarily or exclusively for electronic information services." Whether Schedule DCT reaches the hub, reaches its compute tenant, or reaches neither is a question for the ESA, and no ESA, LOA or PUCO filing naming this site was located. Lead HUB-ESA-CUSTOMER.
- the_grandfather_question
- tag [inference]
- statement Two dates set up the question. MARA's 150 MW take-or-pay was announced 2024-11-11 and the hub was energized in 2023 — both before Schedule DCT's Effective Date of 2025-07-23. If an LOA or ESA covering that load was signed before that date, it is "Existing Load," billed at a 60% minimum demand rather than 85%, exempt from the $20,000 supplemental transmission customer charge, and left on its own contract terms. The +300 MW is what breaks it: the tariff makes "Existing Load that signs a new ESA to increase its contract capacity by more than 25,000 kW" into New Load by definition, and +300 MW is twelve times that trigger. On the tariff's own terms an expansion of that size cannot be taken as Existing Load — it is either separately metered New Load, or it converts the whole site. That conclusion follows from the sheets; whether the premise holds (an executed pre-2025-07-23 instrument) is [open] and turns on the ESA nobody has produced.
- source tariff sheets 223-2, 223-3; MARA Holdings release 2024-11-11; One Power Co Form S-1 2025-01-23
- behind_the_meter_bearing
- tag [inference]
- statement The netting provision is the one that reads as if it were written with a site like this one in mind. The hub sits behind One Power's own digital substation, One Power's Hancock County behind-the-meter wind fleet is operating, its Whirlpool Net Zero project in the county is in construction, and AEP has a publicised collaboration to place Bloom fuel cells at data-center customers. Under sheets 223-6/223-7 none of that is free: any non-parallel emergency/backup generation is carved out, but anything designed to operate in parallel needs an interconnection agreement with the Company under O.A.C. 4901:1-22, and electing to net BTM output against Contract Capacity obliges the customer to maintain instantaneous load-curtailment equipment. What the Findlay hub has actually elected is not on any captured record. See behind-the-meter-generation.yaml.
- ratepayer_backdrop
- tag [verified]
- statement AEP's own numbers give the scale the tariff is sorting. Its 2025-09-16 PJM LAS presentation puts the Ohio interconnection queue at 38 GW, DCT study requests at 13.0 GW, and the tariff-adjusted figure at 11.1 GW, with AEP Ohio cumulative summer-peak additions of 2,273 MW by 2026, 7,615 MW by 2030 and 22,272 MW "Ultimate." Its 2026-02-13 release reports 5,642 MW of contracts signed under the DCT as of 2026-02-12 against 12,219 MW signed before it, 17,861 MW total through 2035, from 13,022.7 MW that "asked and paid for a study" and an original ~30,000 MW of requests — against a customer peak demand of roughly 8,000-10,500 MW today.
- findlay_share_of_it
- tag [open]
- statement None of those figures is broken out by county, substation or customer, and neither document mentions Findlay, Hancock County, One Power or MARA. Findlay's share of the 38 GW queue, the 13.0 GW of study requests, or the 5,642 MW of signed DCT contracts is unknown and must not be estimated.
- source data/documents/grid/findlay/20250916-item-04f---aep-large-load-request.pdf (slides 3-5, 7); AEP Ohio release 2026-02-13 (aepohio.com releaseID 10753)
Where it connects
grid/findlay/aep-dct-tariff-posture.yaml · — · grid