Docket No. ER25-192-000

I concur solely because, as today’s order points out in footnote 50,[1] the clear intent of the parties is for Amazon Data Services, Inc., not other consumers, to pay for the costs of the Transmission Customer New or Upgraded Service Construction Service Agreement (CSA).  On that core principle I agree with the Ohio Consumer Counsel.  Moreover, that principle should apply regardless of the rate treatment used to implement this CSA.[2]

For these reasons, I respectfully concur.

 

 

 

[1] See, e.g., Order at P 23 & n.50; see also id. P 4.

[2] In this regard, it merits consideration whether the precedent relied on by AES Ohio to justify its intended rolled-in rate treatment of these network upgrades supports that rate treatment.

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