EL26-68-000 · 2026-06-29 · Individual No Affiliation

Comments of Lisa Melton concerning the integration of large, high-density electric loads and the associated deterministic stability and cost-allocation methodologies

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Docket No. EL26-68-000
Docket No. EL26-71-000
COMMENT AND NOTICE OF RESERVATION OF RIGHTS OF L.M. MARLOWE
Date: July 7, 2026
To:
Honorable Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
L.M. Marlowe (“Commenter”) respectfully submits this comment in the above-captioned
proceedings concerning the integration of large, high-density electric loads and the associated
deterministic stability and cost-allocation methodologies under consideration by the Commission.
I. Interest of the Commenter
Commenter is an independent author and developer of a published analytical framework addressing
nodal equilibrium, deterministic stability invariants, and the allocation of reliability and capacity
burdens created by large computational loads. Commenter’s published work, including the
MARLOWE™ Invariant-Based Diagnostic Framework and the associated Ghost Load™ extraction
analysis, bears directly on the cost-causation and reliability questions presented in these dockets.
Commenter therefore has a direct and substantial interest in their outcome.
II. Comment on the Subject Matter
These proceedings concern whether existing tariff structures appropriately assign the reliability and
cost burdens associated with large-load interconnection, and whether deterministic stability
requirements should be incorporated into Regional Transmission Organization and Transmission
Owner practice. Commenter respectfully submits that the public record now contains substantial
evidence — including PJM capacity auction results, Independent Market Monitor findings, the
NERC Level 3 Alert concerning large computational loads, and documented ratepayer cost-shift in
transmission planning — that the burdens created by these loads are being socialized onto
residential and small-commercial ratepayers rather than assigned on a cost-causation basis.
Commenter urges the Commission to ensure that any deterministic stability or cost-allocation

methodology adopted or referenced in these dockets assigns burden to the loads that cause it and
preserves reliability invariants at the point of interconnection.
III. Reservation of Rights
Commenter has authored and publicly timestamped a proprietary diagnostic and stability framework
and holds pending United States Patent and Trademark Office applications relating thereto. To the
extent any methodology adopted or referenced in these proceedings incorporates, derives from, or
substantially approximates that framework, Commenter reserves all rights, including the right to
seek appropriate relief in the proper forum. This comment is submitted to place the Commission and
the participants in these dockets on notice of Commenter’s claimed proprietary interest and
reservation of rights, and not to assert any claim for adjudication within these proceedings.
IV. Conclusion
For the foregoing reasons, Commenter respectfully requests that the Commission consider this
comment in the above-captioned proceedings and take note of the reservation of rights stated herein.
Respectfully submitted,
_______________________________
Lisa Melton aka L.M. Marlowe
lm.marlowe@pm.me
Intervenor / Commenter, pro se
Related federal references: GAO No. COMP-26-002174; DOE Administrative Claim No. AR
2026-001.