December 7, 2018 Nicholas Akins Chief Executive Officer AEP Texas Inc. 1 Riverside Plaza Columbus, OH 43215-2373 Re: AEP Texas Inc. Registration Statement on Form S-4 Filed December 3, 2018 File No. 333-228657 Dear Mr. Akins: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Scott Anderegg, Attorney, at 202-551-3342 with any questions. Sincerely, Division of Corporation Finance Office of Consumer Products