July 24, 2019

Via E-mail
Nicholas K. Akins
Chairman of the Board and Chief Executive Officer
AEP Texas Inc.
1 Riverside Plaza
Columbus, OH 43215-2373


               Re:    AEP Texas Inc.
                      AEP Texas Restoration Funding LLC
                      Registration Statement on Form SF-1
                      Filed June 28, 2019
                      File Nos. 333-232430 and 333-232430-01

Dear Mr. Akins:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form SF-1

General

   1. We note that throughout the registration statement you use the terms
"Issuer" and
      "issuer" of the system restoration bonds, which are not defined. Please
note that the
      issuer of asset-backed securities is the depositor for the particular
issuing entity, and not
      the issuing entity itself. Please replace references to "Issuer" or
"issuer" of the system
      restoration bonds throughout the registration statement with references
to the issuing
      entity, as appropriate. Refer to Securities Act Rule 191.

   2. We note that throughout the registration statement you refer to the
"series supplement" to
      the Indenture. Please confirm your understanding that the issuance of
each new series of
 Nicholas K. Akins
AEP Texas Inc.
July 24, 2019
Page 2

       system restoration bonds will require the filing of a new registration
statement.

    3. We note that throughout the registration statement you state the summary
or statements in
       the prospectus are "subject to" and/or "qualified...by reference to" the
provisions of the
       applicable transaction agreement. As you are responsible for the
accuracy and
       completeness of the information in the registration statement, this type
of disclaimer is
       not appropriate. While disclosure may direct investors to read the
entirety of the
       applicable agreement for a more complete discussion, the description of
the material
       terms of the applicable agreement must be complete. Please revise to
remove language
       that disclaims the completeness of your prospectus disclosure.

Form of Prospectus

The Depositor, Seller, Initial Servicer and Sponsor   Delinquencies, page 60

    4. We note your delinquency information disclosure. Please revise to
describe and clarify
       how you determine when an asset is considered delinquent. Refer to Item
1100(b)(5) of
       Regulation AB.

Risk Retention, page 132

    5. We note your disclosure that this offering of bonds is a public utility
securitization
       exempt from the risk retention requirements. Please revise your
disclosure to refer to the
       relevant section of Regulation RR pursuant to which such exemption can
be found.

Part II   Information Not Required in Prospectus

Item 14. Exhibits, page II-2

    6. Please file your exhibits with your next amendment. Refer to Item
1100(f) of Regulation
       AB and Instruction 1 to Item 601 of Regulation S-K.

       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.

        Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Nicholas K. Akins
AEP Texas Inc.
July 24, 2019
Page 3

        You may contact Lulu Cheng at 202-551-3811 or me at 202-551-3850 if you
have
questions.

                                                        Sincerely,

                                                        /s/ Katherine Hsu

                                                        Katherine Hsu
                                                        Office Chief
                                                        Office of Structured
Finance


 cc:   Giselle M. Barth, Sidley Austin LLP
       Jeannette K. Arazi, Sidley Austin LLP