Read from the record · Ohio 24-508-EL-ATA · Georgia 44280

On 9 July 2025 the Public Utilities Commission of Ohio closed a case AEP Ohio had opened on 13 May 2024, with this ordering paragraph.

ORDERED, That the 10/23 Stipulation be approved and adopted, subject to 
modifications consistent with this Order.

That is all of it. Section VII runs from ¶ 170 to ¶ 176, seven paragraphs, six of them beginning ORDERED, and not one says what the modifications are. AEP Ohio must now file a tariff whose text is the stipulation plus something, and the something is somewhere in the ninety-four pages before it.

It is in ¶ 126, on page 75.

the Commission modifies the 10/23 Stipulation’s collateral 
provisions.  We find that, the collateral requirements must either be met by the data center 
customer or the customer’s financial sponsor, so long as the sponsor is a co-signer on the 
contract with AEP Ohio.

Now look for that in the stipulation. Its Exhibit A sets out the Collateral Requirement and gives three ways to satisfy it: a parent or affiliate guarantee, a letter of credit, or cash. Here is the first.

1. A guarantee from the ultimate parent or a corporate affiliate of the customer for the full Collateral Requirement, 
so long as the guarantor has both (a) a credit rating of at least A- from S&P and A3 from Moody’s and (b) 
Liquidity greater than ten times the Collateral Requirement; or

No sponsor. No co-signer. I counted both terms: co-signer appears once in the order and never in the thirty-one pages of the stipulation it modifies. Financial sponsor, the same — once, and never. The two words that will bind a data centre customer and its parent appear once each, in the paragraph above, and nowhere in the document that paragraph amends. The tariff sentence they produce is written down in neither.

This is not a reading problem I invented

The Ohio Blockchain Council filed for rehearing and asked the Commission what it had meant.

requests 
clarification on the meaning of “financial sponsor.”

Fifty-six days after the order, the Commission answered.

we agree with the Company that the term “financial 
sponsor” is a well-known legal term of art that does not require further clarification, we will 
provide additional context for OBC, as requested.

Then it supplied a definition that had appeared in neither document.

As contemplated in the Order, “financial 
sponsor” is meant to include any entity that co-signs a LOA or ESA alongside a data center 
customer and serves to satisfy the data center customer’s creditworthiness criteria and/or 
posts either all, or a portion of, the collateral requirement for the data center customer.

The term needed no clarification, and here is the clarification. The practical point stands either way: anyone drafting the tariff between 9 July and 3 September worked against a term with no definition on the record, and the parties could not agree what it meant.

Georgia 44280 fails the same reconciliation somewhere else

On 28 January 2025 the Georgia Public Service Commission approved Georgia Power's large-load rules with five requirements attached. The fourth was the compliance filing.

The Company shall make a compliance filing of the relevant tariffs for applicable customers to reflect the changes to the rules and regulations.

The company filed on 28 February: ten tariffs, twenty-five sheets, clean and tracked-changes copies in one ZIP on the commission's server. Open the tracked copy. It is the company telling you what it changed.

Extract both and diff them word by word: eighty-seven changed regions. Eighty-two carry nothing but the effective date, the revision number, or one of four section headings the extractor placed differently on the two pages. Here is the effective date, at line 9 of each file.

With Bills Rendered for the Billing Month of April, 2025

With Bills Rendered for the Billing Month of JanuaryApril, 2025

January struck, April inserted, fused because struck and inserted text sit side by side on the page. Ugly, legible, and reported.

The other five regions — every one that carries a word outside those field labels — are these. The word only, struck from one applicability line. One struck sentence about the Flat Price Option, whose last word fuses with the first word of the text that survives it: asAs. And three places where the words Georgia Public Service Commission are struck and PSC put in their place, leaving CommissionPSC. That is the whole of what the redline reports beyond dates, revision numbers and moved headings.

Now the change the filing exists to carry. Lines 24 to 26 of the clean copy:

This  tariff  is  not 
applicable  to  customers  with  an  expected  total  peak  demand  of  100  MW  or  greater  at  one  or  more 
premises located on one tract or contiguous tracts of land.

Lines 25 to 27 of the tracked copy are those characters exactly. Not similar — identical, double spaces and all. The threshold 100 MW appears eleven times in each file, on ten of the twenty-five sheets, and not one of the eighty-seven changed regions touches the string 100 or the string MW.

The order that approved these sheets defines the new regime in exactly those words — as defined in the revisions to the Rules and Regulations (100 MW or greater at one or more premises located on one tract or contiguous tracts of land), at line 102 of ga-44280-order-rules-regs-tariff-compliance.txt. That is the sentence the redline does not report.

Count word by word and the asymmetry is total. Thirty-seven word-tokens sit in the clean copy and not in the tracked one, and every one is the half of a fusion that survives: April, inside JanuaryApril,; First inside the fused revision field, which the extractor breaks across a line as OriginalFi and rst; PSC inside CommissionPSC. Nothing stands alone. A strike leaves a fusion you can see. An insertion with nothing struck beside it leaves nothing at all.

So the tracked copy reports the month the tariff takes effect and reports nothing about the threshold. All twenty-five sheets moved from revision Original to First, and the redline names the date on every one of them and the threshold on none. I cannot prove from these two files which words this filing added — that is the point. Neither can you, and neither can the redline the company filed to tell you.

The Georgia order does not agree with itself

The 17 April order adopts Staff's recommendations wholesale — WHEREFORE IT IS ORDERED, that Staff’s recommendations … are hereby adopted — and then restates them as ordering clauses. The restatement is not the same text.

… will apply this framework.

… will apply the framework in the same manner as provided and demonstrated to Staff.

Both sentences sit in one order: the first in the findings of fact, the second among the ordering clauses that say they adopt the findings. The second adds a compliance standard the first lacks. Which binds the contract language? Somebody must choose, and the order does not help.

• OH 24-508Two rival stipulations landed in the same case thirteen days apart. They share 1,953 words — 22 per cent of the one that was adopted.
• GA 44280The sheets took effect with April 2025 bills. The order approving them is dated 17 April.
• GA 44280Two further revisions of one tariff, TOU-SC-15, landed on 19 March and 4 April — after the compliance filing, before the order.

What you can do on Monday, with nothing you have to buy

How the numbers were made

Word lists come from Python's str.split(), which cuts on any run of whitespace and throws the whitespace away. Not collapsing it — discarding it. Regions come from difflib.SequenceMatcher. This is the Georgia count, whole:

import difflib
D = "data/real/"
clean   = open(D+"ga-44280-rules-regs-tariff-compliance-clean.txt").read().split()
tracked = open(D+"ga-44280-rules-regs-tariff-compliance-tracked.txt").read().split()

m = difflib.SequenceMatcher(None, clean, tracked, autojunk=False)
regions = [op for op in m.get_opcodes() if op[0] != "equal"]

FIELDS = {"April,", "JanuaryApril,", "2025", "Original", "First",
          "OriginalFi", "rst", "EFFECTIVE", "DATE",
          "AVAILABILITY:", "ON-PEAK:", "TERM", "OF", "CONTRACT:"}
other = [r for r in regions
         if not set(clean[r[1]:r[2]]) | set(tracked[r[3]:r[4]]) <= FIELDS]

print(len(regions), len(regions) - len(other), len(other))   # 87 82 5
print(sum("100" in w or "MW" in w
          for r in regions for w in clean[r[1]:r[2]] + tracked[r[3]:r[4]]))   # 0

The rest, in the same style. Ohio paragraphs come from re.split(r"\{¶\s*\d+\}", order)[1:] — the braced marks, not bare pilcrows, because a bare count returns 198: the order cites its own paragraphs. That gives 176, of which 17 match modif case-insensitively. co-signer and financial sponsor, both case-insensitive, return 1 in the order and 0 in the 23 October stipulation. The two stipulations share 1,953 words — the matching blocks of the same SequenceMatcher over their word lists — against 8,796 words in the adopted one, so 22.2 per cent. Leave autojunk at its default there and you get 1,891 and 21.5 per cent, so the flag is not decoration. Georgia sheet count is occurrences of EFFECTIVE DATE: 25 in each copy. The threshold count is " ".join(text.split()).count("100 MW"): 11 in each copy.

Each file carries a provenance record with its source URL and a SHA-256 that recomputes. Open them and repeat it; if a number here is wrong I would rather hear it.