Motion to Intervene and Initial Comments of Global Capacity Alliance in response to FERC's 06/18/2026 Show Cause Order
Read topic-matched comments in EL26-67
Topics in the text: Reliability and curtailment · Cost allocation
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Opening text
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FERC-001 Version 1.1 0 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Interconnection of Large Loads to the Interstate Transmission System | Docket No.Read this passage
I. INTRODUCTION AND MOTION TO INTERVENE
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Accordingly, the GCA respectfully requests the Commission grant it intervenor party status in these proceedings.Read this passage
II. FRONT-OF-THE-METER NETTING AND THE ATTRIBUTABILITY GAP
printed heading · Topic match: Reliability and curtailment
Because they are treated independently, the resource’s provided mitigation is socialized to the grid, leaving the load still exposed to curtailment even while the paired resource is offsetting its impact, MW for MW.Read this passage Filed comments: Reliability and curtailment
III. THE TECHNICAL AND COMMERCIAL CORE OF FTM-NETTING
printed heading · Topic match: Reliability and curtailment
While rare, controlled shedding during system emergencies is possible due to on-site backup generation, but frequent rapid curtailment events are technically and commercially unviable.Read this passage Filed comments: Reliability and curtailment
IV. TRANSMISSION PLANNING ALIGNMENT AND GRID RELIABILITY
printed heading · Topic match: Reliability and curtailment
Reliability Assurance: The Scarcity Release During system-wide emergency conditions, RTOs may require FTM-Netting participants to execute a Scarcity Release, lowering the telemetry shield so both assets see full market dispatch / curtailment.Read this passage Filed comments: Reliability and curtailment
V. IMPLEMENTATION AND BENEFITS
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The Externalities of FTM-Netting: A System-Level Assessment By aligning the commercial imperatives of developers with macro-grid operational needs, FTM-Netting delivers compounding system benefits: • Grid Visibility & Reliability: Halts the "BTM Exodus" by keeping new generation visible to RTOs. •…Read this passage Filed comments: Cost allocation
VI. CONCLUSION AND REQUEST FOR RELIEF
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CONCLUSION AND REQUEST FOR RELIEF For the foregoing reasons, the GCA respectfully requests that the Commission grant its Motion to Intervene in these consolidated proceedings and accord it full party status with all attendant rights.Read this passage Filed comments: Cost allocation
CERTIFICATE OF SERVICE
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Dated at Austin, Texas this 8th day of July, 2026. ______________________________ Jesse Gossett Jesse Gossett, Interim Executive Director Global Capacity AllianceRead this passage