{"document":{"slug":"filing-20261001-5390-attachment-1","title":"FERC_Public_Comment.pdf","issued":"2026-10-01","accession":"20261001-5390","docket":"EL26-70-000","group":"MISO filings","filer":"Individual No Affiliation","kind":"attachment","file":"sources/originals/20261001-5390_02.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20261001-5390","parent":"filing-20261001-5390","sha256":"9cd1bb986c64852815caecfdc64c3feecde77de3b38151384a50243bc8386e25","pages":5,"tokens":1611,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":393,"text":"FERC Docket No. EL26-70-000\nPage 1\nUNITED STATES OF AMERICA\nBEFORE THE FEDERAL ENERGY REGULATORY COMMISSION\nMidcontinent Independent System Operator, Inc.\nDocket No. EL26-70-000\nPUBLIC COMMENT OF A PULASKI COUNTY, ARKANSAS\nRESIDENT\nI am a resident and electric customer in Pulaski County, Arkansas. I am not an attorney, engineer, utility\nexpert, or energy professional. I am a mother, a ratepayer, and a citizen who began asking questions when\nlarge data-center development became a major issue in my community.\nThe more I have tried to understand how these projects are planned for and served, the more concerned I have\nbecome about whether ordinary customers have enough information to meaningfully participate in decisions\nthat may affect our electric bills and infrastructure for decades.\nI want to be clear that I am not opposed to technology or economic development. I understand that large\nprojects can bring investment and opportunity. I simply believe that development on an extraordinary scale\nshould come with equally strong transparency, accountability, reliable planning, and protections for existing\ncustomers.\nThat is why this FERC proceeding matters to me.\nArkansas enacted the Generating Arkansas Jobs Act in 2025. The Arkansas Public Service Commission\nreported in June 2026 that Entergy Arkansas, LLC is among the utilities approved for a Generating Arkansas\nJobs Act rider, and the Commission's report includes estimated customer and residential bill impacts\nassociated with strategic investments. For an ordinary customer, that makes utility policy decisions very real.\nThey are not merely discussions among utilities, regulators, developers, and lawmakers. They can reach a\nfamily's monthly electric bill.\nI have therefore tried to educate myself about our utility system, our Public Service Commission, transmission\nplanning, generation, rate cases, and the unusually large electricity demands associated with data centers. It has\nnot been easy.\nUtility regulation is already extraordinarily complicated for a person without technical training. In proceedings\nI have tried to follow, I have encountered important information that is redacted or subject to protective\ntreatment. Sometimes information that would help a citizen understand the assumptions, costs, risks, or\nplanning behind a proposal is difficult or impossible for the public to evaluate.\nI understand that legitimate confidential business information sometimes requires protection. I am not asking\nthat every confidential detail be made public. But there is an important difference between protecting\ngenuinely confidential information and leaving the public without enough information to understand what is"},{"page":2,"startToken":393,"endToken":854,"text":"FERC Docket No. EL26-70-000\nPage 2\nbeing planned, why it is needed, what it is expected to cost, and who bears the financial risk.\nThat distinction matters greatly when a new customer may require hundreds of megawatts of electricity.\nThe same concerns are playing out at the local level. For several months, residents of Pulaski County have\nattended Quorum Court meetings asking our elected officials to adopt reasonable safeguards for high-intensity\ndigital infrastructure projects. Citizens have taken time away from work and family, studied documents,\nspoken during public comment, contacted officials, and tried to understand technical issues involving\nelectricity, water, noise, emergency services, infrastructure, and land use.\nIt can be discouraging to watch ordinary residents work this hard simply to understand and have a voice in\ndecisions of this magnitude. At times, it feels as though citizens enter these discussions with far less\ninformation and far fewer resources than utilities and large corporate customers. I do not believe economic\ndevelopment and protecting residents have to be opposing goals. But when the public cannot see enough of the\ninformation underlying major infrastructure decisions, it becomes much harder to have confidence that the\nrisks and costs are being distributed fairly.\nOn September 15, 2026, the Arkansas General Assembly's Joint Committee on Energy held a public meeting\naddressing data-center development. The Arkansas Legislature has made the meeting video and materials\npublicly available. I respectfully encourage the Commission and its staff to review that hearing because it\noffers a useful view of the questions now being raised in Arkansas about the scale of data-center electricity\ndemand, infrastructure, affordability, reliability, and customer protections.\nWhat struck me most was not that everyone agreed. They did not. What struck me was how many fundamental\nquestions are still being asked while planning for very large new loads is already moving forward.\nThat brings me directly to this proceeding.\nI appreciate that the Commission's June 18, 2026 order in Docket No. EL26-70-000 addresses issues including\nrapid growth in large loads, transparency, Network Upgrade costs, load forecasting, cost responsibility, and the\npotential for cost shifting. Those concerns make sense to an ordinary ratepayer because they ultimately\ndetermine who carries the financial consequences of new infrastructure.\nFrom my perspective, the public should be able to understand some basic questions when an exceptionally\nlarge new customer seeks service:\n• How much electricity is the customer requesting?\n• What new transmission facilities or Network Upgrades are needed because of that request?\n• What are those upgrades expected to cost?\n• Who is financially responsible for those costs?\n• What financial commitments must the large customer make before major infrastructure is constructed?\n• What happens if the project is delayed, substantially downsized, or never built?\n• What prevents costs created primarily to serve that customer from later being shifted to existing customers?"},{"page":3,"startToken":854,"endToken":1371,"text":"FERC Docket No. EL26-70-000\nPage 3\n• How can regulators and the public verify those protections while legitimate confidential information\nremains protected?\nI recognize that the answers may involve complicated engineering, market rules, contracts, and jurisdictional\nboundaries. I do not expect FERC to make those subjects simple. I am asking FERC to make the consequences\nunderstandable.\nI respectfully encourage meaningful public disclosure of the amount of new large load seeking transmission\nservice, the Network Upgrades identified to serve those loads, the expected costs associated with those\nupgrades, and the general framework for assigning financial responsibility, while still protecting genuinely\nconfidential information.\nI also encourage strong financial protections when infrastructure is constructed in anticipation of a new large\nload. If a project does not materialize as expected, existing customers should not automatically become the\nfinancial backstop for investments undertaken primarily to serve that project.\nThe Commission's concern about speculative or uncertain large-load requests is particularly important. When a\nsingle proposed customer can represent hundreds of megawatts of demand, inaccurate, duplicated, or\ninsufficiently committed forecasts can have enormous consequences for infrastructure planning. Those risks\ndeserve careful scrutiny before customers are asked to bear long-term costs.\nIf a large-load customer receives specialized treatment because it represents that its demand can be curtailed,\nmanaged, delayed, or otherwise made flexible during periods of system stress, those commitments should be\nclear and enforceable. Planning assumptions should match the obligations that actually exist.\nI also hope the Commission continues to consider the public-participation problem created when information\nis technically available but practically inaccessible. A docket can be public and still be very difficult for an\nordinary person to understand. Redactions, confidential exhibits, specialized terminology, and fragmented\nfilings can make it nearly impossible for a citizen to see the complete picture. Public summaries of the most\nimportant assumptions, costs, risks, and customer protections would make participation far more meaningful\nwithout requiring disclosure of legitimate trade secrets.\nFinally, I hope FERC remembers who ultimately lives downstream from these decisions. Most people will\nnever understand transmission tariffs, cost-allocation formulas, Network Upgrade classifications,\ninterconnection studies, or utility riders. But we understand our electric bills. We understand when basic\nhousehold costs increase. And we understand that infrastructure built today may still be affecting our\ncommunities and our children long after the companies, projects, and public officials involved have changed.\nI have a young daughter. When I started looking into these issues, I was primarily worried about a data center\nproposed near my community. The more I have learned, the more my concern has grown beyond one project. I\nam concerned about what kind of electric system we are building for her generation and who will inherit the\nfinancial consequences of the decisions being made today.\nI do not believe economic development and protecting ordinary families have to be competing goals. Large\ncustomers can succeed. Utilities can build infrastructure that is demonstrably needed. Communities can benefit\nfrom investment. But ordinary customers should be able to see enough of the process to understand what is\nhappening, and they should not be expected to carry financial risks created primarily for very large new"},{"page":4,"startToken":1371,"endToken":1452,"text":"FERC Docket No. EL26-70-000\nPage 4\ncustomers.\nI respectfully ask the Commission to keep transparency, cost responsibility, reliable planning, and protection\nof existing customers at the center of this proceeding.\nThank you for providing the public an opportunity to participate and for considering the perspective of an\nordinary Arkansas customer who is simply trying to understand where these costs and risks ultimately land.\nRespectfully submitted,\nIndividual resident and electric customer\nPulaski County, Arkansas\nIdentifying and contact information provided through FERC eFiling."},{"page":5,"startToken":1452,"endToken":1611,"text":"FERC Docket No. EL26-70-000\nPage 5\nPublicly Available References\nFederal Energy Regulatory Commission, Order Instituting Proceeding Under Section 206 of the Federal Power Act, Docket No.\nEL26-70-000 (issued June 18, 2026).\nhttps://www.ferc.gov/sites/default/files/2026-06/EL26-70-000.pdf\nArkansas General Assembly, Act 373 of 2025, Generating Arkansas Jobs Act of 2025.\nhttps://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2025R%2FPublic%2FACT373.pdf\nArkansas Public Service Commission, Annual Generating Arkansas Jobs Act Report 2026 (June 30, 2026).\nhttps://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F000%2F27977%2FExhibit+\nH.17.c+-+PSC+-+Annual+Generating+Arkansas+Jobs+Act+Report+2026.pdf\nArkansas General Assembly, Joint Committee on Energy, September 15, 2026 meeting record, agenda materials, and video.\nhttps://arkleg.state.ar.us/Committees/MeetingsPast?code=510\nPulaski County Quorum Court, September 22, 2026 meeting video and agenda index, including Item 26-I-56A concerning\nhigh-intensity digital infrastructure.\nhttps://pulaskicountyar.new.swagit.com/videos/401863"}],"sections":[{"p":1,"at":0,"title":"Pages 1 to 4","method":"page range","endPage":5,"endAt":0,"startToken":0,"endToken":1452},{"p":5,"at":0,"title":"Page 5","method":"page range","endPage":5,"endAt":1121,"startToken":1452,"endToken":1611}]}
