Comment submitted by American Electric Power Company, Inc. (AEP)

Summary: American Electric Power Company, Inc. (AEP), an investor-owned electric utility, supports the EPA's proposed rule to clarify the "begin actual construction" definition under the New Source Review (NSR) program. AEP argues that the rule provides necessary regulatory clarity and flexibility, and they specifically request further clarifications to ensure that non-emitting infrastructure, such as foundations and underground piping, can be constructed concurrently with the permitting process to accelerate project timelines and reduce costs.