{"document":{"slug":"filing-20260708-5103","title":"Motion to Intervene and Initial Comments of Global Capacity Alliance in response to FERC's 06/18/2026 Show Cause Order","issued":"2026-07-08","accession":"20260708-5103","docket":"EL26-67-000","group":"PJM, SPP, NYISO, MISO, CAISO, ISO-NE filings","filer":"Global Capacity Alliance","kind":"comments","file":"sources/originals/20260708-5103_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260708-5103","sha256":"3891f5f85ddf5f9567bcd5d2dfbe139679f9cdf15e6506eaab91197a352a3e37","pages":4,"tokens":1662,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":570,"text":"Ref: FTM-Arch. FERC-001 Version 1.1 \n0 \nUNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION \nInterconnection of Large Loads to the Interstate Transmission System | Docket No. RM26-4-000 \nPJM Interconnection, L.L.C. | Docket No. EL26-67-000  \nSouthwest Power Pool, Inc. | Docket No. EL26-68-000  \nNew York Independent System Operator, Inc. | Docket No. EL26-69-000  \nMidcontinent Independent System Operator, Inc. | Docket No. EL26-70-000  \nCalifornia Independent System Operator Corp. | Docket No. EL26-71-000  \nISO New England Inc. | Docket No. EL26-72-000 \nI. INTRODUCTION AND MOTION TO INTERVENE \nPursuant to Rules 211 and 214 of the Federal Energy Regulatory Commission’s (FERC or Commission) Rules of \nPractice and Procedure (18 C.F.R. §§ 385.211 and 385.214), the Global Capacity Alliance (GCA) hereby submits \nthis Motion to Intervene and Initial Comments in response to the Commission’s June 18, 2026, Section 206 Show \nCause Orders regarding large load integration. \nThe GCA is a newly organized nonprofit association currently undergoing formal incorporation under Section \n501(c)(6) of the Internal Revenue Code.1 As stated in its organizational documents, GCA’s purpose is to promote \nthe common business interests of companies, organizations, and individuals dedicated to resolving the \ninfrastructure bottlenecks between large electrical loads and grid connections, and to serve as a global standard-\nsetting and certification organization with respect to the regulation of capacity attribution and front-of-the-meter \n(FTM) netting. Membership in the GCA is open to all electricity market stakeholders.  \nBecause no other single party in these proceedings offers this specific standard-setting framework to solve the \nlarge load integration challenge, GCA’s unique perspective is not currently represented on the record, and its \nparticipation is in the public interest. Accordingly, the GCA respectfully requests the Commission grant it \nintervenor party status in these proceedings. \nII. FRONT-OF-THE-METER NETTING AND THE ATTRIBUTABILITY GAP \nWhile early-energization on non-firm, transitional service is a developing option (e.g. NITS or CHILLS), purely \ncurtailable connections are commercially challenging for data centers. To mitigate this, developers are exploring \nBehind-The-Meter (BTM) configurations, which inadvertently divorce new generation from grid planning, obscures \nreal-time operations and introduces cost-shifting concerns.  \nFront-of-The-Meter (FTM) Netting can unlock this market, allowing interim flexible load to firm their service \nprivately by bringing-your-own-capacity (BYOC, e.g. gas or BESS) while upgrades are built. Both assets are \nintegrated into grid planning and operating constructs as flexible/non-firm. Co-located but separately metered, \nthese assets net their capacity benefit to each other through a Transitional Deliverability construct until upgrades \nare built, after which, both assets are firm grid participants. \nThe Required “Netting” Evolution:  \nWhen an FTM load and resource are co-located, the grid engine (SCED) does not link them. Because they are \ntreated independently, the resource’s provided mitigation is socialized to the grid, leaving the load still exposed to \ncurtailment even while the paired resource is offsetting its impact, MW for MW.  \nThe Problem in Practice: A 100 MW data center and a 100 MW BESS sit at the same substation on separate \nmeters. During localized congestion, SCED can simultaneously dispatch the BESS to support the grid and curtail \nthe data center — because it has no mechanism to recognize that one was built specifically to offset the other. \nThe developer's investment in mitigation is socialized to the grid.  \nFTM-Netting closes this \"attributability gap\" using existing market tools, allowing a flexible load to mitigate its \ncurtailment risk within normal SCED operations through three connected, core principles:  \n \n1 V-Wire Inc. is acting as the initial corporate promoter of the GCA."},{"page":2,"startToken":570,"endToken":1141,"text":"Ref: FTM-Arch. FERC-001 Version 1.1 \n1 \n• \nThe Telemetry Shield: Each dispatch interval, the Market Participant (MP) dynamically adjusts the load's \nconsumption floor via market telemetry to match the paired resource's availability, shielding it from \ncurtailment if the paired resource is offered. If the resource exhausts or trips, the shield drops. \n• \nThe Post-Operating Day Compliance Ledger: Because the telemetry shield protects the load in real-\ntime, the regulatory burden shifts to settlement where the MP will be flagged for telemetry deviation. To \nsettle, the MP submits a standardized three-stream compliance ledger — telemetry, economic, and \nperformance data — subject to independent third-party verification to eliminate conflicts of interest. \n• \nDeterministic Scarcity Yielding: The Telemetry Shield manages localized congestion — it is not a \nreliability exemption. During system-wide emergencies, the Market Participant deterministically drops the \nshield, returning both assets to standard SCED dispatch and curtailment.  \nThrough this framework, FTM-Netting can provide the administrative insulation an RTO requires, translating \ncomplex private commercial sequencing into a standardized, fully auditable asset class that aligns with existing \ntransmission planning and Open Access Transmission Tariff service rules.  \nIII. THE TECHNICAL AND COMMERCIAL CORE OF FTM-NETTING \nWhile FTM-Netting provides operational telemetry, its commercial engine is the private Capacity Attribution \nContract (CAC), which bridges the gap between initial non-firm energization and completed network upgrades. \nThis mitigation is essential because non-firm loads face unpredictable 5-minute curtailments. Most large loads \ncannot drop load on 5-minute notice. While rare, controlled shedding during system emergencies is possible due \nto on-site backup generation, but frequent rapid curtailment events are technically and commercially unviable.  \nThe CAC pairs the load with a co-located resource to solve this operational mismatch, converting an unbankable \nrisk into a deterministic, project-financeable profile in three distinct ways: \n• \nOperational Buffering & SLA Protection (The Load): The resource absorbs real-time (5-minute) \ncurtailment obligations, acting as an operational buffer. This increases uptime, and—if an outage outlasts \nthe battery's State of Charge (SoC)—provides the load with a predictable \"ramp window\" to curtail. \n• \nCreditworthy Counter-Parties: Flexible loads need firmness. Flexible generators need offtake. \n• \nInsurability:  Insurers will not underwrite constant 5-minute RTO curtailment risk. The CAC provides a \nmulti-hour (e.g., 2-hour) operational buffer for a controlled facility shutdown, converting unpredictable \ngrid volatility into a quantifiable risk that can be wrapped. \nOnce network upgrades are complete and the load transitions to firm grid service, the CAC sunsets, freeing the \ngenerator’s capacity to participate fully in the broader wholesale market. \nIV. TRANSMISSION PLANNING ALIGNMENT AND GRID RELIABILITY \nFTM-Netting requires no changes to existing transmission planning processes. Because the load and the paired \nresource are separately metered, they are studied as standard, independent interconnections—fully visible to RTO \nplanning models and subject to existing constraint analyses. This is demonstrably better than BTM configurations, \nwhere resources can disappear from planning models. \nWhile waiting for network upgrades to be built, both assets operate on a non-firm, flexible construct. Their co-\ndependence on these future upgrades is the commercial basis and term length for the CAC. Because this is a \ntransitional window, both assets operate in an energy-only phase consistent with their interconnection status, \nasking nothing of capacity markets they cannot yet fully serve. \nReliability Assurance: The Scarcity Release \nDuring system-wide emergency conditions, RTOs may require FTM-Netting participants to execute a Scarcity \nRelease, lowering the telemetry shield so both assets see full market dispatch / curtailment. This is not planned \ncapacity, rather, it is a positive externality of FTM-Netting, activated when the grid’s need is highest."},{"page":3,"startToken":1141,"endToken":1599,"text":"Ref: FTM-Arch. FERC-001 Version 1.1 \n2 \nV. IMPLEMENTATION AND BENEFITS \nFTM-Netting offers a modular framework with universal physics that integrates into current regional market \ndesigns, mapping to existing market mechanisms in each RTO — through demand response registration \nframeworks, tariff-mandated consumption ceilings, and load telemetry constructs — without operational IT \nupdates. Should RTOs wish to pursue FTM-Netting, stakeholder engagement can focus on 3 key areas:  \n• \nScarcity Yield & Coordinated Curtailment: Standardizing the technical parameters and response time \nfor a facility to execute a controlled curtailment to onsite backup generation.  \n• \nCo-Optimization of Market Products: Determining how and if a resource can participate in ancillary \nservice or capacity markets while maintaining shielding obligations.  \n• \nSettlement & Compliance: There are two paths for integration, either RTO-driven verification of software \nand ongoing compliance obligations or delegation to an independent Standard-Setting Organization that \ndevelops and manages the standard.  \nBy establishing this separation between universal operational physics and regional market design, FTM-Netting \nprovides FERC and the RTOs with a pathway for flexible large compute load energization. \nThe Externalities of FTM-Netting: A System-Level Assessment \nBy aligning the commercial imperatives of developers with macro-grid operational needs, FTM-Netting delivers \ncompounding system benefits: \n• \nGrid Visibility & Reliability: Halts the \"BTM Exodus\" by keeping new generation visible to RTOs.  \n• \nRatepayer Benefits: Flexible loads avoid the need to commit expensive generation (e.g., RUCs or MWPs) \nand early energization ahead of upgrades increases utilization, lowering average rates. \n• \nMaximizing utilization of existing infrastructure spreads fixed legacy costs across more MWh, lowering \nvolumetric rates for all ratepayers.  \n• \nPhantom Load Avoidance: Utilities can safely build long-lead upgrades knowing the triggering load is \nalready built and operating, reducing stranded-cost risk and simplifying planning. \n• \nPrivately Funded Reliability Infrastructure: To firm their load developers must fund new resources \nwithout ratepayer subsidy that eventually integrate into the market. FTM-Netting requires the tech sector \nto privately underwrite the dispatchable capacity the grid needs most. \nVI. CONCLUSION AND REQUEST FOR RELIEF \nFor the foregoing reasons, the GCA respectfully requests that the Commission grant its Motion to Intervene in \nthese consolidated proceedings and accord it full party status with all attendant rights. \nFurthermore, the GCA urges the Commission to direct the RTOs and ISOs, in responding to the June 18, 2026, \nShow Cause Orders, to actively evaluate and incorporate Front-of-the-Meter (FTM) Netting frameworks and \nindependent standard-setting coordination pathways into their respective compliance strategies. Doing so \nensures that the integration of large, flexible loads supports grid visibility, protects regional ratepayers, and \nunlocks privately funded reliability infrastructure.  \nTo assist the Commission and market stakeholders in this effort, the GCA will submit a technical, operational, and \nsettlement architecture for the FTM-Netting and CAC framework in these dockets in the coming days.  \nRespectfully submitted, \n \nJesse Gossett, Interim Executive Director \nDated July 8, 2026 \nwww.globalcapacityalliance.org \nJesse@globalcapacityalliance.org"},{"page":4,"startToken":1599,"endToken":1662,"text":"Ref: FTM-Arch. FERC-001 Version 1.1 \n1 \nCERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon each person designated on the official \nservice list compiled by the Secretary in these proceedings, via the Commission's eFiling system. \nDated at Austin, Texas this 8th day of July, 2026. \n \n \n______________________________ \nJesse Gossett \nJesse Gossett, Interim Executive Director \nGlobal Capacity Alliance"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":580,"startToken":0,"endToken":76},{"p":1,"at":580,"title":"I. INTRODUCTION AND MOTION TO INTERVENE","method":"printed heading","endPage":1,"endAt":2022,"startToken":76,"endToken":285},{"p":1,"at":2022,"title":"II. FRONT-OF-THE-METER NETTING AND THE ATTRIBUTABILITY GAP","method":"printed heading","endPage":2,"endAt":1342,"startToken":285,"endToken":747},{"p":2,"at":1342,"title":"III. THE TECHNICAL AND COMMERCIAL CORE OF FTM-NETTING","method":"printed heading","endPage":2,"endAt":3012,"startToken":747,"endToken":970},{"p":2,"at":3012,"title":"IV. TRANSMISSION PLANNING ALIGNMENT AND GRID RELIABILITY","method":"printed heading","endPage":3,"endAt":40,"startToken":970,"endToken":1148},{"p":3,"at":40,"title":"V. IMPLEMENTATION AND BENEFITS","method":"printed heading","endPage":3,"endAt":2408,"startToken":1148,"endToken":1450},{"p":3,"at":2408,"title":"VI. CONCLUSION AND REQUEST FOR RELIEF","method":"printed heading","endPage":4,"endAt":40,"startToken":1450,"endToken":1606},{"p":4,"at":40,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":4,"endAt":446,"startToken":1606,"endToken":1662}]}