EL26-67-000 · 2026-07-08 · Global Capacity Alliance

Motion to Intervene and Initial Comments of Global Capacity Alliance in response to FERC's 06/18/2026 Show Cause Order

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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION 
Interconnection of Large Loads to the Interstate Transmission System | Docket No. RM26-4-000 
PJM Interconnection, L.L.C. | Docket No. EL26-67-000  
Southwest Power Pool, Inc. | Docket No. EL26-68-000  
New York Independent System Operator, Inc. | Docket No. EL26-69-000  
Midcontinent Independent System Operator, Inc. | Docket No. EL26-70-000  
California Independent System Operator Corp. | Docket No. EL26-71-000  
ISO New England Inc. | Docket No. EL26-72-000 
I. INTRODUCTION AND MOTION TO INTERVENE 
Pursuant to Rules 211 and 214 of the Federal Energy Regulatory Commission’s (FERC or Commission) Rules of 
Practice and Procedure (18 C.F.R. §§ 385.211 and 385.214), the Global Capacity Alliance (GCA) hereby submits 
this Motion to Intervene and Initial Comments in response to the Commission’s June 18, 2026, Section 206 Show 
Cause Orders regarding large load integration. 
The GCA is a newly organized nonprofit association currently undergoing formal incorporation under Section 
501(c)(6) of the Internal Revenue Code.1 As stated in its organizational documents, GCA’s purpose is to promote 
the common business interests of companies, organizations, and individuals dedicated to resolving the 
infrastructure bottlenecks between large electrical loads and grid connections, and to serve as a global standard-
setting and certification organization with respect to the regulation of capacity attribution and front-of-the-meter 
(FTM) netting. Membership in the GCA is open to all electricity market stakeholders.  
Because no other single party in these proceedings offers this specific standard-setting framework to solve the 
large load integration challenge, GCA’s unique perspective is not currently represented on the record, and its 
participation is in the public interest. Accordingly, the GCA respectfully requests the Commission grant it 
intervenor party status in these proceedings. 
II. FRONT-OF-THE-METER NETTING AND THE ATTRIBUTABILITY GAP 
While early-energization on non-firm, transitional service is a developing option (e.g. NITS or CHILLS), purely 
curtailable connections are commercially challenging for data centers. To mitigate this, developers are exploring 
Behind-The-Meter (BTM) configurations, which inadvertently divorce new generation from grid planning, obscures 
real-time operations and introduces cost-shifting concerns.  
Front-of-The-Meter (FTM) Netting can unlock this market, allowing interim flexible load to firm their service 
privately by bringing-your-own-capacity (BYOC, e.g. gas or BESS) while upgrades are built. Both assets are 
integrated into grid planning and operating constructs as flexible/non-firm. Co-located but separately metered, 
these assets net their capacity benefit to each other through a Transitional Deliverability construct until upgrades 
are built, after which, both assets are firm grid participants. 
The Required “Netting” Evolution:  
When an FTM load and resource are co-located, the grid engine (SCED) does not link them. 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.  
The Problem in Practice: A 100 MW data center and a 100 MW BESS sit at the same substation on separate 
meters. During localized congestion, SCED can simultaneously dispatch the BESS to support the grid and curtail 
the data center — because it has no mechanism to recognize that one was built specifically to offset the other. 
The developer's investment in mitigation is socialized to the grid.  
FTM-Netting closes this "attributability gap" using existing market tools, allowing a flexible load to mitigate its 
curtailment risk within normal SCED operations through three connected, core principles:  
 
1 V-Wire Inc. is acting as the initial corporate promoter of the GCA.

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• 
The Telemetry Shield: Each dispatch interval, the Market Participant (MP) dynamically adjusts the load's 
consumption floor via market telemetry to match the paired resource's availability, shielding it from 
curtailment if the paired resource is offered. If the resource exhausts or trips, the shield drops. 
• 
The Post-Operating Day Compliance Ledger: Because the telemetry shield protects the load in real-
time, the regulatory burden shifts to settlement where the MP will be flagged for telemetry deviation. To 
settle, the MP submits a standardized three-stream compliance ledger — telemetry, economic, and 
performance data — subject to independent third-party verification to eliminate conflicts of interest. 
• 
Deterministic Scarcity Yielding: The Telemetry Shield manages localized congestion — it is not a 
reliability exemption. During system-wide emergencies, the Market Participant deterministically drops the 
shield, returning both assets to standard SCED dispatch and curtailment.  
Through this framework, FTM-Netting can provide the administrative insulation an RTO requires, translating 
complex private commercial sequencing into a standardized, fully auditable asset class that aligns with existing 
transmission planning and Open Access Transmission Tariff service rules.  
III. THE TECHNICAL AND COMMERCIAL CORE OF FTM-NETTING 
While FTM-Netting provides operational telemetry, its commercial engine is the private Capacity Attribution 
Contract (CAC), which bridges the gap between initial non-firm energization and completed network upgrades. 
This mitigation is essential because non-firm loads face unpredictable 5-minute curtailments. Most large loads 
cannot drop load on 5-minute notice. 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.  
The CAC pairs the load with a co-located resource to solve this operational mismatch, converting an unbankable 
risk into a deterministic, project-financeable profile in three distinct ways: 
• 
Operational Buffering & SLA Protection (The Load): The resource absorbs real-time (5-minute) 
curtailment obligations, acting as an operational buffer. This increases uptime, and—if an outage outlasts 
the battery's State of Charge (SoC)—provides the load with a predictable "ramp window" to curtail. 
• 
Creditworthy Counter-Parties: Flexible loads need firmness. Flexible generators need offtake. 
• 
Insurability:  Insurers will not underwrite constant 5-minute RTO curtailment risk. The CAC provides a 
multi-hour (e.g., 2-hour) operational buffer for a controlled facility shutdown, converting unpredictable 
grid volatility into a quantifiable risk that can be wrapped. 
Once network upgrades are complete and the load transitions to firm grid service, the CAC sunsets, freeing the 
generator’s capacity to participate fully in the broader wholesale market. 
IV. TRANSMISSION PLANNING ALIGNMENT AND GRID RELIABILITY 
FTM-Netting requires no changes to existing transmission planning processes. Because the load and the paired 
resource are separately metered, they are studied as standard, independent interconnections—fully visible to RTO 
planning models and subject to existing constraint analyses. This is demonstrably better than BTM configurations, 
where resources can disappear from planning models. 
While waiting for network upgrades to be built, both assets operate on a non-firm, flexible construct. Their co-
dependence on these future upgrades is the commercial basis and term length for the CAC. Because this is a 
transitional window, both assets operate in an energy-only phase consistent with their interconnection status, 
asking nothing of capacity markets they cannot yet fully serve. 
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. This is not planned 
capacity, rather, it is a positive externality of FTM-Netting, activated when the grid’s need is highest.

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V. IMPLEMENTATION AND BENEFITS 
FTM-Netting offers a modular framework with universal physics that integrates into current regional market 
designs, mapping to existing market mechanisms in each RTO — through demand response registration 
frameworks, tariff-mandated consumption ceilings, and load telemetry constructs — without operational IT 
updates. Should RTOs wish to pursue FTM-Netting, stakeholder engagement can focus on 3 key areas:  
• 
Scarcity Yield & Coordinated Curtailment: Standardizing the technical parameters and response time 
for a facility to execute a controlled curtailment to onsite backup generation.  
• 
Co-Optimization of Market Products: Determining how and if a resource can participate in ancillary 
service or capacity markets while maintaining shielding obligations.  
• 
Settlement & Compliance: There are two paths for integration, either RTO-driven verification of software 
and ongoing compliance obligations or delegation to an independent Standard-Setting Organization that 
develops and manages the standard.  
By establishing this separation between universal operational physics and regional market design, FTM-Netting 
provides FERC and the RTOs with a pathway for flexible large compute load energization. 
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.  
• 
Ratepayer Benefits: Flexible loads avoid the need to commit expensive generation (e.g., RUCs or MWPs) 
and early energization ahead of upgrades increases utilization, lowering average rates. 
• 
Maximizing utilization of existing infrastructure spreads fixed legacy costs across more MWh, lowering 
volumetric rates for all ratepayers.  
• 
Phantom Load Avoidance: Utilities can safely build long-lead upgrades knowing the triggering load is 
already built and operating, reducing stranded-cost risk and simplifying planning. 
• 
Privately Funded Reliability Infrastructure: To firm their load developers must fund new resources 
without ratepayer subsidy that eventually integrate into the market. FTM-Netting requires the tech sector 
to privately underwrite the dispatchable capacity the grid needs most. 
VI. 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. 
Furthermore, the GCA urges the Commission to direct the RTOs and ISOs, in responding to the June 18, 2026, 
Show Cause Orders, to actively evaluate and incorporate Front-of-the-Meter (FTM) Netting frameworks and 
independent standard-setting coordination pathways into their respective compliance strategies. Doing so 
ensures that the integration of large, flexible loads supports grid visibility, protects regional ratepayers, and 
unlocks privately funded reliability infrastructure.  
To assist the Commission and market stakeholders in this effort, the GCA will submit a technical, operational, and 
settlement architecture for the FTM-Netting and CAC framework in these dockets in the coming days.  
Respectfully submitted, 
 
Jesse Gossett, Interim Executive Director 
Dated July 8, 2026 
www.globalcapacityalliance.org 
Jesse@globalcapacityalliance.org

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CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each person designated on the official 
service list compiled by the Secretary in these proceedings, via the Commission's eFiling system. 
Dated at Austin, Texas this 8th day of July, 2026. 
 
 
______________________________ 
Jesse Gossett 
Jesse Gossett, Interim Executive Director 
Global Capacity Alliance