{"document":{"slug":"filing-20260708-5018","title":"Supplemental Technical Comment of L.M. Marlowe on the integration of large, high-density electric loads and the associated reliability, observability, and cost-allocation methodologies under consideration by the Commission","issued":"2026-07-08","accession":"20260708-5018","docket":"EL26-67-000","group":"PJM, SPP, NYISO, MISO, CAISO, ISO-NE filings","filer":"Individual No Affiliation","kind":"filing","file":"sources/originals/20260708-5018_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260708-5018","sha256":"285f5579e6e030bcf4c281d0903d66d6e18b5915b0a5aac529c9ad235ae0348d","pages":9,"tokens":3536,"emptyPages":[6]},"pages":[{"page":1,"startToken":0,"endToken":349,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nIntegration of Large Loads and Associated Reliability and Cost-\nAllocation Methodologies; \nShow-Cause Proceedings and Related Dockets \n) Docket No. EL26-67-000 \n) Docket No. EL26-68-000 \n) Docket No. EL26-69-000 \n) Docket No. EL26-70-000 \n) Docket No. EL26-71-000 \n) Docket No. EL26-72-000 \n) Docket No. RM26-4-000 \n) Docket No. RP26-358-000 \n \nSUPPLEMENTAL TECHNICAL COMMENT AND RESERVATION OF RIGHTS OF L.M. \nMARLOWE \nDate: July 8, 2026 \nThis submission is made in good faith by a private citizen and independent researcher, supported by extensive \noperational documentation and prior art. It is offered for the public benefit — to improve grid reliability, \ntransparency in large-load cost allocation, and the protection of ratepayers from systemic waste and undue cost-\nshifting. It is based on publicly available records, Commenter’s own timestamped technical documentation and \nprior-art filings, and technical analysis. \nTo the Honorable Secretary, Federal Energy Regulatory Commission, 888 First Street, NE, Washington, \nDC 20426: \nLisa Melton, filing as L.M. Marlowe (“Commenter”), respectfully submits this supplemental technical \ncomment in the above-captioned proceedings concerning the integration of large, high-density electric \nloads and the associated reliability, observability, and cost-allocation methodologies under consideration \nby the Commission. Commenter is a party whose Motion to Intervene in Docket No. EL26-67-000, et al. \nwas accepted for filing (Accession No. 202607025022, July 2, 2026). This comment supplements and \nelaborates upon Commenter’s prior submissions, and is offered for the Commission’s consideration in the \ncaptioned proceedings. Nothing herein is a legal conclusion; the technical characterizations are drawn \nfrom Commenter’s contemporaneous, timestamped record and document sequence, not causation. \nI. Interest of the Commenter \nCommenter is an independent author and developer of a published, timestamped analytical framework \naddressing deterministic reliability invariants, real-time observability of computational load behavior, \ndependency mapping, and the allocation of reliability and capacity burdens created by large \ncomputational loads. Commenter’s published work — including the Architecture of Dependency and \nAutonomy™, the MARLOWE™ Invariant-Based Diagnostic Framework, Intent-Aware Telemetry™, \nContinuous Invariant Validation™, Execution Sovereignty™, and the associated Ghost Load™ \ndependency analysis — bears directly on the reliability and cost-causation questions presented in these \ndockets. Commenter therefore has a direct and substantial interest in their outcome. Commenter states"},{"page":2,"startToken":349,"endToken":794,"text":"that interest plainly: Commenter is the author and rights-holder of this framework and submits it for the \nCommission’s consideration in the belief that it responds to the reliability, observability, and cost-\ncausation questions these proceedings present. Commenter’s object in these proceedings is that the \nreliability of the system be protected and that the costs of large computational load be borne by those who \ncause them rather than by residential and small-commercial ratepayers; Commenter submits this comment \nin good faith and in furtherance of that public interest. Any terms relating to the adoption or use of the \nframework are matters Commenter is prepared to address in the appropriate forum and are not placed at \nissue in this comment. The technical invariants underlying this framework have been published openly \nand in full and made available for examination, comment, and challenge, consistent with the transparency \nthese proceedings seek to advance. \nII. Documented Priority — Diagnostic-to-Action Correlation \nCommenter reported the specific conditions now before the Commission and the reliability community \nbeginning January 17, 2026 — months before the corresponding federal actions. The following \ncorrelations are drawn from Commenter’s timestamped correspondence record (255 items, January 17 – \nJune 29, 2026) and the public federal record. Each states the diagnostic, the date of first report, and the \nlater federal action addressing the same condition. This documents temporal sequence, not causation. \nDiagnostic reported by Commenter \nFirst report \nSubsequent federal action \nInterval \nSub-synchronous resonance / high-frequency “jitter” \nsignature at data-center interconnects (4.83 MW \nharmonic) \n2026-01-17 \nNERC Level 3 Alert (2026-05-04) — documents sub-\nsynchronous oscillation traced to computational \nfacilities in ERCOT and Dominion territories \n107 d \nInverter-Based Resource telemetry / high-speed (PMU) \nmeasurement gap for large loads \n2026-01-17 \nNERC Essential Actions (2026-05-04) — high-speed \nmonitoring at data centers made an Essential Action \n107 d \nGhost Load — unmetered / behind-the-meter large-load \nextraction and metering bypass \n2026-01-17 \nFERC show-cause (2026-06-18) — requires reform of \nco-location and BTM arrangements and accounting \ntransparency \n152 d \nCost-shifting of stranded / infrastructure costs onto \nresidential ratepayers \n2026-01-17 \nFERC (2026-06-18) — preliminarily finds large-load \ntariffs unjust and unreasonable; requires cost-recovery \nagreements \n152 d \nSudden multi-hundred-MW computational load drop as \ngrid-stability / blackout risk \n2026-01-20 \nNERC Level 3 Alert (2026-05-04) — issued in \nresponse to repeated 1,000+ MW load-drop events \n104 d \nPJM / Northern Virginia (Dominion) corridor as point \nof first failure \n2026-01-20 \nDOE 202(c) emergency orders (2026-06-30); NERC \ntraces oscillation to Dominion territory (2026-05-04) \n104 d+ \nNeed for a diagnostic / certification standard and \ngeneration-adequacy accounting for large loads \n2026-01-17 \nFERC resource-adequacy reports (2026-06-18); NERC \n“Computational Load Entity” registration category \n(2026-05-04) \n107 d \nPriority intervals range 104–152 days. Commenter respectfully submits that this documented priority is relevant to \nthe Commission’s evaluation of the methodologies proposed in response to its orders."},{"page":3,"startToken":794,"endToken":1273,"text":"III. Technical Considerations for the Commission \nCommenter respectfully submits the following considerations, each corresponding to matters already \nbefore the Commission and the reliability community. \nA. From periodic review to continuous validation. \nExisting reliability mechanisms are predominantly retrospective — periodic reviews, seasonal \nassessments, and post-event investigations operating on intervals measured in weeks or quarters. Large \ncomputational loads change operating state on sub-second and sub-cycle timescales, driven by automated \norchestration rather than human dispatch. A settlement or reliability process operating on a sixty-to-\nninety-day study cadence cannot resolve behavior that changes faster than the measurement interval; the \nrelevant dynamics have completed before the review begins. Consideration should be given to whether \nreliability verification should migrate from periodic review toward continuously operating validation \nperformed at the interconnection boundary, sampled at sub-cycle resolution, such that latent instability is \ndetected in the telemetry stream before it propagates onto the Bulk Power System. \nB. Observability beyond consumption — high-resolution boundary telemetry. \nConventional load modeling characterizes demand through aggregate consumption measured over \nsettlement intervals. This resolution is insufficient to observe the behavior that large computational loads \nimpose at the point of common coupling: sub-synchronous oscillation, harmonic injection, phase-\ncoherence deviation relative to the nodal reference frame, and rapid load-migration events. These \nsignatures fall below the temporal resolution of SCADA-class metering and are only resolvable through \nPhasor Measurement Unit (PMU) and Dynamic Fault Recorder (DFR) instrumentation sampling at sub-\ncycle rates. The NERC Essential Actions’ requirement for high-speed monitoring and dynamic fault \nrecording at computational facilities identifies the same instrumentation gap. Consideration should be \ngiven to whether interconnection standards should require boundary telemetry of sufficient resolution to \nresolve the physical signature of computational load — the measurable fingerprint of its behavior at the \ngrid interface — rather than telemetry describing only integrated historical consumption. \nC. Embedded reliability boundaries and machine-speed corrective action. \nWhere load behavior changes at sub-cycle speed, corrective mechanisms that depend on human-initiated \ndispatch cannot respond within the window in which an oscillation or load-rejection event propagates. \nConsideration should be given to whether interconnection requirements should include automated, \nboundary-resident reliability functions — continuous invariant monitoring against defined tolerances, \nautomated throttling or curtailment triggered when a measured quantity exceeds its bound, and machine-\nspeed corrective action — such that a deviation is arrested at the interconnection point before it becomes \na system-wide event. This is a shift from retrospective compliance verification to continuous, automated \nenforcement of reliability bounds at the boundary. \nD. Execution sovereignty and software common-mode risk. \nReliability planning has historically treated geographic and electrical diversity as sufficient protection \nagainst correlated failure. Large computational loads defeat that assumption at the software layer: \nthousands of megawatts distributed across multiple balancing authorities may nevertheless share common \norchestration environments, model-serving stacks, or scheduling dependencies, such that a single \nupstream software event can command a synchronized change in demand across geographically dispersed \nfacilities simultaneously. This is a common-mode failure mode invisible to redundancy analysis that"},{"page":4,"startToken":1273,"endToken":1756,"text":"considers only physical topology. The documented record of sudden, synchronized reductions of large \ncomputational load — including the repeated 1,000-plus-MW load-drop events underlying the NERC \nLevel 3 Alert — is consistent with a shared-dependency mechanism rather than independent local causes. \nConsideration should be given to whether interconnection study must characterize software and \norchestration dependency — execution sovereignty — as a distinct common-mode risk alongside physical \nredundancy, and to whether the concentration of load behind shared control planes should be a studied \nparameter of interconnection. \nE. Dependency mapping and hidden burden. \nTraditional planning methodologies quantify capacity; future methodologies may need to characterize \ndependency — between facilities, orchestration systems, cloud environments, regions, and execution \npathways — including which facilities share identical software assumptions, which execution pathways \nare coupled, and what percentage of computational activity could migrate simultaneously. Commenter’s \nGhost Load™ methodology addresses burdens of this kind that remain hidden from present reliability and \ncost-allocation frameworks. The underlying question is significant whether or not this terminology is \nadopted: whether operators can reliably govern, and correctly allocate the cost of, dependencies that \ncannot yet be observed. \nF. Cost-causation. \nThe reliability burdens created by large computational loads — including the burdens arising from the \nobservability, validation, and dependency considerations above — should be assigned to the loads that \ncause them, on a cost-causation basis, rather than socialized onto residential and small-commercial \nratepayers. The present record — including PJM capacity auction results, Independent Market Monitor \nfindings, the NERC Level 3 Alert, and documented instances of cost-shift in transmission planning — \nsupports the need for cost-allocation methodologies that preserve reliability invariants at the point of \ninterconnection while assigning burden on a cost-causation basis. \nG. Curtailment priority and observability of federally-accelerated computational load. \nIn its Section 202(c) emergency orders during the June–July 2026 heat events (e.g., DOE Order No. 202-\n26-32, June 30, 2026, and its extensions through July 7, 2026), the Department of Energy directed \ncurtailment of data centers and large loads of 50 MW or greater onto backup generation within fifteen \nminutes of an emergency signal, while expressly exempting hospitals, 911 call centers, water treatment \nplants, air traffic control facilities, and defense facilities. Separately, the Department’s Genesis Mission \n(Executive Order, November 24, 2025) is federally accelerating large computational load and expressly \ntargets grid interconnection, planning, and operations, with a stated national-security dimension. \nConsideration should be given to how curtailment priority is to be ordered where federally-directed or \nsecurity-associated computational load may qualify for exemptions available to critical facilities — such \nthat it could sit ahead of, rather than behind, ordinary large loads in a curtailment sequence — and to how \nthe Commission’s cost-causation, transparency, and observability objectives are to be preserved with \nrespect to computational load whose operating characteristics may be shielded from the observability \nthese proceedings seek to establish. Commenter raises these as questions the record should resolve and \ntakes no position on any federal program as such. \nH. Unpriced resource consumption and diffuse externalized costs."},{"page":5,"startToken":1756,"endToken":2215,"text":"Large computational loads impose costs beyond the price of energy — costs that, because they are diffuse \nand fall across many parties, are difficult to trace and are frequently borne by the public rather than by the \ncausing load. Consideration should be given to whether the Commission’s cost-allocation methodologies \naccount for, and assign on a cost-causation basis: (i) water consumed for compute cooling, including non-\nrecycled evaporative consumption and its effect on water availability for other public needs, including \nfirefighting; (ii) fire and air-quality risk associated with backup-generator operation during curtailment \nevents, including operation beyond ordinary emission limits authorized under emergency orders; (iii) \naccelerated wear on transmission, distribution, and related public infrastructure from large-load stress and \nrapid load-switching; (iv) casualty and reliability risk as reflected in rising insurance costs and coverage \ndisputes affecting facilities and surrounding communities; and (v) the administrative and adjudicative \nburden — borne by public agencies, ratepayer advocates, and the courts — of resolving the proliferating \ndisputes among utilities, States, insurers, and customers over who bears these costs. As independent \nanalysis has observed, the confidential nature of many utility–large-load arrangements makes the public’s \nshare of these costs difficult to measure; that opacity itself supports the need for the transparency and \ncost-causation discipline these proceedings contemplate. \nI. Transparency and the orientation of the just and reasonable standard. \nThe Commission’s authority under the Federal Power Act was established to protect consumers and to \nensure that rates are just and reasonable, and cost causation is the foundation of that standard. That \nstandard requires that any determination rest on a rational connection between the facts found and the \nconclusion reached, on the evidence before the Commission. A structural difficulty is presented where the \nsame federal authority both directs the Commission to ensure transparency, cost-causation discipline, and \nratepayer protection with respect to large computational loads, and, through separate mechanisms — \ncontractual confidentiality, emergency-order expedience, and national-security classification associated \nwith federally-directed computational load — withholds from the Commission the information those \nobjectives require. Consideration should therefore be given to a threshold question: whether the \nCommission can discharge its statutory duty, owed to the public the Act was enacted to protect, with \nrespect to costs, risks, and load behavior it is structurally prevented from observing. Where the public \nbears the costs, absorbs the reliability risk, and finances the infrastructure of large computational load, yet \nis denied — through confidentiality, emergency expedience, or classification — the transparency \nnecessary to verify how those costs are caused and allocated, consideration should be given to whether \nthe arrangement serves the public the Commission was created to protect, or inverts that relationship, \nsuch that the public is made to serve the institutions rather than the institutions serving the public. \nCommenter raises this as a consideration for the Commission’s weighing, and asserts no legal conclusion."},{"page":6,"startToken":2215,"endToken":2215,"text":""},{"page":7,"startToken":2215,"endToken":2730,"text":"IV. Toward a Resolution — Verification at the Point of Interconnection \nThe considerations above describe a common difficulty: the Commission is directed to ensure just and \nreasonable rates, reliability, and cost-causation for large computational loads whose behavior and costs it \nmay be structurally prevented from observing. Commenter respectfully submits that a resolution exists \nthat does not require the Commission, the Regional Transmission Organizations, or the operators to \nobtain access to the proprietary or protected interior of any facility. Consideration should be given to \nwhether a standard of the following character — verification performed at the electrical boundary, the \npoint of common coupling, rather than within the facility — would resolve the difficulties identified \nabove. \nSuch a standard would operate as a sequence of verification gates applied at interconnection, each \naddressing a specific consideration raised in this comment: \nGate I — Boundary diagnostic (timing and stability). \nThe first gate establishes the trustworthiness of the telemetry itself and the timing stability of the load at \nthe point of common coupling. Using PMU and Dynamic Fault Recorder data sampled at sub-cycle \nresolution, it measures phase coherence — the rotational alignment of the load’s injected and drawn \npower relative to the nodal reference frame — together with sub-synchronous oscillation and harmonic \nsignature. Two invariants govern this stage: a bounded phase-jitter tolerance, measured against a \nreference clock, which sets the maximum permissible timing deviation of the interconnection; and a \nbounded controller-response interval, which sets the maximum permissible latency of the load’s control \nresponse. Together these determine whether the telemetry stream is coherent enough to be relied upon and \nwhether the load’s timing behavior is within stable bounds. This gate supplies the high-resolution \nobservability the reliability record identifies as absent (Considerations A and B), measured entirely at the \nboundary and without access to internal facility operations. \nGate II — Boundary dependency map. \nThe second gate characterizes the load’s coupling and dependency profile as observed at the boundary: its \nelectrical relationship to proximate generation and to other loads, the load-migration fraction — the \nproportion of demand capable of shifting simultaneously — and the degree to which the facility’s \nbehavior is correlated with shared control planes rather than independent local dispatch. This maps the co-\ndependency of electrically proximate load and generation that the reliability record now requires be \nstudied together, and supplies the data needed to assess the software common-mode exposure described in \nConsiderations D and E — derived from observed boundary behavior rather than from disclosure of \ninternal architecture. \nGate III — Boundary settlement (throughput reconciliation and cost-causation). \nThe third gate reconciles declared load against delivered load and provides the measurable basis for cost-\ncausation. Two invariants govern this stage: a throughput differential — the measured difference between \nthe load authorized or represented and the load physically drawn and delivered at the boundary — and an \noperational bound, the tolerance within which that differential is treated as accounted-for. A differential \nexceeding the bound identifies unaccounted or displaced throughput: service received but not reflected in \nthe declared or metered figure. This is the physical basis of the cost-shift and unmetered-extraction \nconcerns before the Commission (Considerations F and H). Because the differential and its bound are"},{"page":8,"startToken":2730,"endToken":3261,"text":"computed from boundary telemetry that the operator already records at settlement points, cost-causation is \nestablished from the measured record rather than from confidential internal accounts. \nGate IV — Boundary certification (integrated operational alignment). \nThe fourth gate is not a single measurement but a certification of the integrated result of Gates I through \nIII. It certifies, against the full set of boundary invariants, whether the load can ramp, curtail, and operate \nflexibly while remaining within the accepted stability envelope — that is, whether its timing (Gate I), its \ndependency profile (Gate II), and its throughput reconciliation (Gate III) together place it inside the \nbounds required for reliable interconnection. Certification attaches to the measured, integrated boundary \nstate of the load, not to representations about internal intent, and is continuous rather than one-time: a \nload that drifts outside the envelope fails certification and is subject to the automated corrective action \ndescribed in Consideration C. This gate provides the operational-alignment and flexible-service \ndetermination the Commission’s reform categories contemplate, expressed as a verifiable state rather than \na representation. \nThe resolution of the transparency difficulty. \nBecause each gate operates at the electrical boundary rather than within the facility, this class of standard \nresolves the difficulty described in Consideration I without disturbing any legitimate interest in \nconfidentiality, emergency response, or classification. The interior of the facility — its proprietary \nmethods and any classified activity — remains undisclosed. What becomes observable and verifiable is \nonly the load’s behavior at the point where it touches the public grid: its timing, its dependency, its cost-\ncausation, and its stability. The Commission thereby obtains the evidentiary basis its just and reasonable \nstandard requires, and the operators obtain observability at the speed of the load, while the facility’s \ninternal integrity is preserved. Consideration should be given to whether a boundary-verification standard \nof this character should be incorporated into the interconnection and cost-allocation methodologies these \nproceedings will produce. Commenter has developed, and holds prior-art and pending intellectual-\nproperty rights in, a specific and complete embodiment of a standard of this character, as set forth in the \nReservation of Rights below, and is prepared to describe that embodiment in full in response to the \nCommission’s inquiries. \nV. Relationship to the Current Record and Pending Deadlines \nThe considerations above correspond to matters already before the Commission and the reliability \ncommunity. The following summarizes the recent federal record and the two imminent deadlines that will \ndevelop it, illustrating that the reliability conditions at issue are active and that the record is presently in \nmotion: \nDate \nMatter \n2026-05-04 \nNERC Level 3 Essential Actions Alert — modeling, instrumentation, and high-speed monitoring of computational loads; \nsub-synchronous oscillation traced to Dominion (Northern Virginia) territory. \n2026-06-18 \nFERC Section 206 show-cause orders to all six RTO/ISOs; large-load tariffs preliminarily found unjust and unreasonable; \nfive reform categories including cost-shifting and transparency. \n2026-06-30 \nDOE Section 202(c) emergency orders (Order No. 202-26-32) directing PJM to curtail large loads onto backup generation; \nNorthern Virginia corridor flagged amid record demand. \n2026-08-03 \nNERC Level 3 Alert response deadline — registered entities must report status on the seven Essential Actions (33 \nquestions). \n2026-08-17 \nFERC show-cause / tariff-reform deadline (60 days from June 18) — each RTO/ISO must show cause or file reforms on \nlarge-load integration."},{"page":9,"startToken":3261,"endToken":3536,"text":"Commenter notes that the substance of these considerations — including intent-aware observability, \ncontinuous validation, software common-mode exposure, and dependency-based cost allocation — was \nauthored and publicly timestamped prior to the actions now under consideration, and respectfully submits \nthat this priority is relevant to the Commission’s evaluation of methodologies proposed in response to its \norders. \nVI. Reservation of Rights \nCommenter has authored and publicly timestamped a proprietary diagnostic, observability, and stability \nframework and holds pending United States Patent and Trademark Office applications relating thereto \n(USPTO Serial Nos. 99598875, 99600821, 99613073, 99717240, 99729215, and 99745529). To the \nextent any methodology adopted, referenced, or incorporated in these proceedings — or in any Regional \nTransmission Organization, Independent System Operator, or Transmission Owner filing responsive to \nthe Commission’s orders — incorporates, derives from, or substantially approximates that framework or \nits associated marks, Commenter reserves all rights, including the right to seek appropriate relief in the \nproper forum. This comment is submitted to place the Commission and the participants in these dockets \non notice of Commenter’s claimed proprietary interest and reservation of rights, and not to assert any \nclaim for adjudication within these proceedings. \nVII. Conclusion \nFor the foregoing reasons, Commenter respectfully requests that the Commission consider these technical \nconsiderations in the above-captioned proceedings and take note of the reservation of rights stated herein. \nCommenter offers these considerations in good faith and in the shared interest of a reliable Bulk Power \nSystem and of just and reasonable rates for the public the Commission was established to protect. \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 2026-001."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1930,"startToken":0,"endToken":252},{"p":1,"at":1930,"title":"I. Interest of the Commenter","method":"printed heading","endPage":2,"endAt":977,"startToken":252,"endToken":496},{"p":2,"at":977,"title":"II. Documented Priority — Diagnostic-to-Action Correlation","method":"printed heading","endPage":3,"endAt":0,"startToken":496,"endToken":794},{"p":3,"at":0,"title":"III. Technical Considerations for the Commission","method":"printed heading","endPage":3,"endAt":204,"startToken":794,"endToken":818},{"p":3,"at":204,"title":"A. From periodic review to continuous validation.","method":"printed heading","endPage":3,"endAt":1161,"startToken":818,"endToken":940},{"p":3,"at":1161,"title":"B. Observability beyond consumption — high-resolution boundary telemetry.","method":"printed heading","endPage":3,"endAt":2338,"startToken":940,"endToken":1086},{"p":3,"at":2338,"title":"C. Embedded reliability boundaries and machine-speed corrective action.","method":"printed heading","endPage":3,"endAt":3185,"startToken":1086,"endToken":1192},{"p":3,"at":3185,"title":"D. Execution sovereignty and software common-mode risk.","method":"printed heading","endPage":4,"endAt":632,"startToken":1192,"endToken":1354},{"p":4,"at":632,"title":"E. Dependency mapping and hidden burden.","method":"printed heading","endPage":4,"endAt":1414,"startToken":1354,"endToken":1450},{"p":4,"at":1414,"title":"F. Cost-causation.","method":"printed heading","endPage":4,"endAt":2116,"startToken":1450,"endToken":1540},{"p":4,"at":2116,"title":"G. Curtailment priority and observability of federally-accelerated computational load.","method":"printed heading","endPage":4,"endAt":3605,"startToken":1540,"endToken":1748},{"p":4,"at":3605,"title":"H. Unpriced resource consumption and diffuse externalized costs.","method":"printed heading","endPage":5,"endAt":1545,"startToken":1748,"endToken":1962},{"p":5,"at":1545,"title":"I. Transparency and the orientation of the just and reasonable standard.","method":"printed heading","endPage":7,"endAt":0,"startToken":1962,"endToken":2215},{"p":7,"at":0,"title":"IV. Toward a Resolution — Verification at the Point of Interconnection","method":"printed heading","endPage":8,"endAt":374,"startToken":2215,"endToken":2781},{"p":8,"at":374,"title":"III. It certifies, against the full set of boundary invariants, whether the load can ramp, curtail, and operate","method":"printed heading","endPage":8,"endAt":2584,"startToken":2781,"endToken":3088},{"p":8,"at":2584,"title":"V. Relationship to the Current Record and Pending Deadlines","method":"printed heading","endPage":9,"endAt":421,"startToken":3088,"endToken":3313},{"p":9,"at":421,"title":"VI. Reservation of Rights","method":"printed heading","endPage":9,"endAt":1416,"startToken":3313,"endToken":3445},{"p":9,"at":1416,"title":"VII. Conclusion","method":"printed heading","endPage":9,"endAt":2082,"startToken":3445,"endToken":3536}]}