Comment submitted by Arizona Electric Power Cooperative, Inc. (AEPCO)

Summary: Arizona Electric Power Cooperative, Inc. (AEPCO) supports the proposed rule because it provides relief from the burdensome and costly requirements of the 2024 Legacy Rule while moving toward a more flexible, site-specific regulatory scheme. The cooperative argues that the current "one-size-fits-all" framework is ineffective and advocates for the elimination of the CCRMU category, citing a lack of technical and legal justification for its regulation.