EL26-67-000 · 2026-07-09 · Individual No Affiliation

Second Supplemental Technical Comment of L.M. Marlowe on the Frequency-Response Absorption Standard and Coupling-Discrimination Protocol

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
Integration of Large Loads and Associated Reliability and Cost-
Allocation Methodologies; 
Show-Cause Proceedings and Related Dockets 
) Docket No. EL26-67-000 
) Docket No. EL26-68-000 
) Docket No. EL26-69-000 
) Docket No. EL26-70-000 
) Docket No. EL26-71-000 
) Docket No. EL26-72-000 
 
SECOND SUPPLEMENTAL TECHNICAL COMMENT OF L.M. MARLOWE 
(Frequency-Response Absorption Standard and Coupling-Discrimination Protocol) 
Date: July 8, 2026 
This submission is made in good faith by a private citizen and independent researcher, supported by extensive 
operational documentation and prior art. It is offered for the public benefit — to improve grid reliability, 
transparency in large-load cost allocation, and the protection of ratepayers from systemic waste and undue cost-
shifting. It provides additional technical detail responsive to the reliability and observability questions raised in 
these proceedings, and asks that all submissions be evaluated against the full requirements of the Commission’s 
Show Cause Orders. 
Lisa Melton, filing as L.M. Marlowe (“Commenter”), a party whose Motion to Intervene in Docket No. 
EL26-67-000, et al. was accepted for filing (Accession No. 202607025022, July 2, 2026), respectfully 
submits this Second Supplemental Technical Comment. It supplements Commenter’s prior Supplemental 
Technical Comment with additional technical specification responsive to the reliability, observability, and 
cost-causation questions presented, and respectfully addresses the standard by which the Commission 
may wish to evaluate the responses before it. 
I. The Standard of Evaluation Respectfully Urged 
Commenter respectfully urges the Commission, in evaluating the responses to its Show Cause Orders, to 
hold each proposed framework, methodology, and tariff to the full rigor of what those Orders require. The 
Commission’s directives ask not merely whether a proposal addresses large-load integration in some 
respect, but whether it satisfies the just-and-reasonable standard across the complete set of concerns the 
record has raised: 
(1) physical reliability and dynamic stability; (2) observability at the temporal resolution the underlying 
phenomena demand; (3) cost-causation that assigns costs to those who cause them rather than socializing 
them onto ratepayers; and (4) durability under credible worst-case operating conditions, not representative 
ones. 
A submission that resolves the commercial or market-access dimension of large-load integration without 
demonstrably addressing the physical stability and observability questions that gave rise to these 
proceedings has not, in Commenter’s respectful submission, fulfilled the full requirement of the Show 
Cause Orders. Commenter asks that each submission — including Commenter’s own — be measured

against that complete standard, so that the resolution the Commission adopts rests on frameworks that 
fulfill the whole of what reliability and consumer protection require, not a part. 
II. The Binding Contingency Has Shifted 
Reserve adequacy and frequency-response planning have historically been sized against an enumerated 
largest credible contingency — typically the loss of the single largest generating unit — treated as 
physical and independent. Large computational load introduces a contingency of a different character: a 
set of geographically dispersed loads that, through a shared orchestration or control plane, can reduce 
demand in near-simultaneity, behaving as a single correlated block. 
This block is invisible to topology-based N-1 analysis, which scores dispersed loads as independent low-
probability events. Measured at the interconnection boundary, the same loads exhibit correlated ramp 
events at machine speed. Where the coordinated-drop magnitude of the block exceeds the loss-of-largest-
unit value, the largest credible contingency is no longer a generator — it is the load block. A reserve 
adequacy computed against the former, at representative system conditions, is measuring the wrong event 
at the wrong condition. 
III. The Frequency-Response Absorption Standard (Minimum-Inertia Condition) 
A load drop pushes system frequency upward. The immediate rate of change of frequency (RoCoF), 
before primary frequency response (PFR) engages, is governed by the swing equation: 
df/dt  =  − ΔP / (2 H · S_base) 
where ΔP is the net imbalance from the coupled-block drop, H is the system inertia constant, and S_base 
is the system base. Stability requires two conditions simultaneously: the initial RoCoF must remain below 
the protection threshold at which relays trip generation, and the frequency excursion before PFR arrests it 
must remain within the trip band. Both depend on H. 
System inertia is not constant. As synchronous generation retires and is displaced by inverter-based 
resources, H declines, reaching its lowest values under high non-synchronous output and low 
synchronous commitment — conditions that recur on a dispatch-driven schedule. The consequence is a 
compounding exposure: available inertia (H) shrinks while the coordinated-drop magnitude (ΔP) grows, 
both driving RoCoF upward at once. Evaluation at average or representative inertia systematically 
understates the risk, because the binding failure occurs at the minimum, not the mean. 
Commenter therefore respectfully submits that the absorption of any behaviorally-coupled load block 
must be evaluated at a credible minimum-inertia condition — the lowest inertia state expected to recur 
within the planning horizon at a stated low exceedance probability, adjusted for scheduled synchronous 
retirements and forecast resource mix, and crediting only firmly committed grid-forming or synchronous-
condenser contribution. Expressed as a checkable interconnection requirement, a coupled block is 
absorbable only if, at that minimum-inertia condition, its resulting RoCoF remains below the protection 
threshold and deliverable primary frequency response within the arrest window is at least equal to the 
block magnitude. Where neither holds, there exists a coupled-load penetration beyond which further 
interconnection is not physically feasible without defined, committed grid-strengthening measures. This is 
a limit set by physics, not by policy; the standard’s function is to locate it before it is discovered by a 
coordinated-drop event.

IV. The Coupling-Discrimination Protocol 
A rigorous standard must distinguish the true common-mode risk from legitimate distributed flexibility, 
because both produce correlated load movement. Two loads may move together because a shared control 
plane commanded them (orchestration-coupling — the contingency), or because each independently 
responded to the same public signal, such as price or system frequency (environmental correlation — the 
demand-response behavior the system relies upon). A metric based on aggregate correlation alone cannot 
separate them and would erroneously penalize legitimate response. 
The protocol discriminates on signatures observable at the boundary, without knowledge of internal 
cause: the dispersion of ramp-event onset times (a shared command arrives within a narrow machine-
speed window; independent responses disperse over each participant’s own reaction time); the 
congruence of ramp waveform shape (a command replicates one instruction; independent responses vary 
in shape); and, decisively, the correlation that survives conditioning on common environmental signals. 
Only co-movement that remains after removing the price-, frequency-, dispatch-, and weather-explained 
components counts toward the coupling coefficient: 
ρ_coupling  =  corr( residualᵢ , residualⱼ )  after conditioning on common environmental signals 
A set of loads all responding to a price signal shows high raw correlation but near-zero residual 
correlation — correctly cleared as environmental. A set sharing a scheduler shows correlation that 
survives conditioning — correctly identified as orchestrated. Only genuinely orchestration-coupled load 
enters the block magnitude tested under Section III. This resolves each participant into a measured 
position — coupled and subject to the absorption test, environmentally correlated and cleared, or 
independent — so that no party is swept into a contingency obligation by mere correlation, and none 
escapes one by disputing intent. The classification is reproducible from boundary data. 
V. Remediation Is Intrinsic to the Measurement, Not Appended to It 
This section states an engineering property of the architecture, not a policy position. In the settlement 
measure, the quantity that identifies unaccounted-for load and the quantity that reassigns its cost are the 
same quantity. The measure computes the difference between declared and delivered load; that difference 
is, simultaneously and by the same arithmetic, the measured extraction and the cost-causation basis that 
reassigns it to the load that caused it. There is no intermediate discretionary step — no point at which an 
operator elects whether to reallocate — because the reallocation is not a subsequent decision applied to 
the measurement; it is the measurement, read as a ledger entry. Detecting the extraction and correcting it 
are one operation. Value recovered is thereby directed, by the arithmetic itself, to those who bore its cost, 
to the grid infrastructure its presence stressed, and to the structural correction of the conditions that 
permitted the misallocation, so that it does not recur. 
Because the two are one operation, accountability is not a discretionary layer that any institution is asked 
to honor by declaration; it is a property of the invariants, such that the measurement and the reassignment 
cannot be performed independently of one another. This removes the discretion through which 
unaccounted-for costs are ordinarily socialized: a system that performs the measurement has, in the same 
step, performed the reallocation. Stated in the Commission’s terms, the protection of the ratepaying public 
here is not an aim asserted alongside the technical work — it is a defined output of the equations, present 
or absent as a measurable quantity rather than as a declared posture. The specific mechanism for

administering the resulting allocation is a matter Commenter is prepared to address in the appropriate 
forum and is not placed at issue here. 
VI. Relationship to the Record and Reservation 
This Comment supplements and does not supersede Commenter’s prior filings. The complete 
specifications of the frequency-response absorption standard and the coupling-discrimination protocol are 
held by Commenter and are described here at the functional level; Commenter is prepared to describe 
them in full in response to the Commission’s inquiries. Commenter reserves all rights previously stated, 
including under 18 U.S.C. § 1833(b) and the referenced USPTO filings, and asserts no legal conclusion 
herein. 
VII. Conclusion 
Commenter respectfully requests that the Commission consider these technical considerations, and that it 
hold each framework, methodology, and tariff before it — including Commenter’s own — to the full 
rigor of what the Show Cause Orders require. Commenter offers these considerations in good faith and in 
the shared interest of a reliable Bulk Power System and of just and reasonable rates for the public the 
Commission was established to protect. 
Respectfully submitted, 
_______________________________ 
Lisa Melton aka L.M. Marlowe 
lm.marlowe@pm.me 
Intervenor, pro se