{"document":{"slug":"filing-20260629-5029","title":"Comments of Lisa Melton concerning the integration of large, high-density electric loads and the associated deterministic stability and cost-allocation methodologies","issued":"2026-06-29","accession":"20260629-5029","docket":"EL26-68-000","group":"SPP, CAISO filings","filer":"Individual No Affiliation","kind":"comments","file":"sources/originals/20260629-5029_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260629-5029","sha256":"34eaa0ac7837b5a717c2ba1f6229afd54463bdcfe62354720db3e2acff57a8c1","pages":2,"tokens":442,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":263,"text":"UNITED STATES OF AMERICA\nBEFORE THE\nFEDERAL ENERGY REGULATORY COMMISSION\nDocket No. EL26-68-000\nDocket No. EL26-71-000\nCOMMENT AND NOTICE OF RESERVATION OF RIGHTS OF L.M. MARLOWE\nDate: July 7, 2026\nTo:\nHonorable Secretary\nFederal Energy Regulatory Commission\n888 First Street, NE\nWashington, DC 20426\nL.M. Marlowe (“Commenter”) respectfully submits this comment in the above-captioned\nproceedings concerning the integration of large, high-density electric loads and the associated\ndeterministic stability and cost-allocation methodologies under consideration by the Commission.\nI. Interest of the Commenter\nCommenter is an independent author and developer of a published analytical framework addressing\nnodal equilibrium, deterministic stability invariants, and the allocation of reliability and capacity\nburdens created by large computational loads. Commenter’s published work, including the\nMARLOWE™ Invariant-Based Diagnostic Framework and the associated Ghost Load™ extraction\nanalysis, bears directly on the cost-causation and reliability questions presented in these dockets.\nCommenter therefore has a direct and substantial interest in their outcome.\nII. Comment on the Subject Matter\nThese proceedings concern whether existing tariff structures appropriately assign the reliability and\ncost burdens associated with large-load interconnection, and whether deterministic stability\nrequirements should be incorporated into Regional Transmission Organization and Transmission\nOwner practice. Commenter respectfully submits that the public record now contains substantial\nevidence — including PJM capacity auction results, Independent Market Monitor findings, the\nNERC Level 3 Alert concerning large computational loads, and documented ratepayer cost-shift in\ntransmission planning — that the burdens created by these loads are being socialized onto\nresidential and small-commercial ratepayers rather than assigned on a cost-causation basis.\nCommenter urges the Commission to ensure that any deterministic stability or cost-allocation"},{"page":2,"startToken":263,"endToken":442,"text":"methodology adopted or referenced in these dockets assigns burden to the loads that cause it and\npreserves reliability invariants at the point of interconnection.\nIII. Reservation of Rights\nCommenter has authored and publicly timestamped a proprietary diagnostic and stability framework\nand holds pending United States Patent and Trademark Office applications relating thereto. To the\nextent any methodology adopted or referenced in these proceedings incorporates, derives from, or\nsubstantially approximates that framework, Commenter reserves all rights, including the right to\nseek appropriate relief in the proper forum. This comment is submitted to place the Commission and\nthe participants in these dockets on notice of Commenter’s claimed proprietary interest and\nreservation of rights, and not to assert any claim for adjudication within these proceedings.\nIV. Conclusion\nFor the foregoing reasons, Commenter respectfully requests that the Commission consider this\ncomment in the above-captioned proceedings and take note of the reservation of rights stated herein.\nRespectfully submitted,\n_______________________________\nLisa Melton aka L.M. Marlowe\nlm.marlowe@pm.me\nIntervenor / Commenter, pro se\nRelated federal references: GAO No. COMP-26-002174; DOE Administrative Claim No. AR\n2026-001."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":578,"startToken":0,"endToken":78},{"p":1,"at":578,"title":"I. Interest of the Commenter","method":"printed heading","endPage":1,"endAt":1158,"startToken":78,"endToken":153},{"p":1,"at":1158,"title":"II. Comment on the Subject Matter","method":"printed heading","endPage":2,"endAt":163,"startToken":153,"endToken":287},{"p":2,"at":163,"title":"III. Reservation of Rights","method":"printed heading","endPage":2,"endAt":864,"startToken":287,"endToken":385},{"p":2,"at":864,"title":"IV. Conclusion","method":"printed heading","endPage":2,"endAt":1299,"startToken":385,"endToken":442}]}