Supplemental Technical Comment of L.M. Marlowe on the integration of large, high-density electric loads and the associated reliability, observability, and cost-allocation methodologies under consideration by the Commission
Read topic-matched comments in EL26-67
Topics in the text: Cost allocation · Reliability and curtailment
Responses and related views
No section-specific public response is linked for this document.
Source sections
Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword. Pages with no text layer: 6.
Opening text
opening text · Topic match: Cost allocation
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.Read this passage Filed comments: Cost allocation
I. Interest of the Commenter
printed heading · Topic match: Cost allocation
Commenter’s object in these proceedings is that the reliability of the system be protected and that the costs of large computational load be borne by those who cause them rather than by residential and small-commercial ratepayers; Commenter submits this comment in good faith and in furtherance of…Read this passage Filed comments: Cost allocation
II. Documented Priority — Diagnostic-to-Action Correlation
printed heading · Topic match: Cost allocation
Documented Priority — Diagnostic-to-Action Correlation Commenter reported the specific conditions now before the Commission and the reliability community beginning January 17, 2026 — months before the corresponding federal actions.Read this passage Filed comments: Cost allocation
III. Technical Considerations for the Commission
printed heading
Technical Considerations for the Commission Commenter respectfully submits the following considerations, each corresponding to matters already before the Commission and the reliability community.Read this passage
A. From periodic review to continuous validation.
printed heading
Existing reliability mechanisms are predominantly retrospective — periodic reviews, seasonal assessments, and post-event investigations operating on intervals measured in weeks or quarters.Read this passage
B. Observability beyond consumption — high-resolution boundary telemetry.
printed heading
Observability beyond consumption — high-resolution boundary telemetry.Read this passage
C. Embedded reliability boundaries and machine-speed corrective action.
printed heading · Topic match: Reliability and curtailment
Consideration should be given to whether interconnection requirements should include automated, boundary-resident reliability functions — continuous invariant monitoring against defined tolerances, automated throttling or curtailment triggered when a measured quantity exceeds its bound, and…Read this passage Filed comments: Reliability and curtailment
D. Execution sovereignty and software common-mode risk.
printed heading
Consideration should be given to whether interconnection study must characterize software and orchestration dependency — execution sovereignty — as a distinct common-mode risk alongside physical redundancy, and to whether the concentration of load behind shared control planes should be a studied…Read this passage
E. Dependency mapping and hidden burden.
printed heading
Traditional planning methodologies quantify capacity; future methodologies may need to characterize dependency — between facilities, orchestration systems, cloud environments, regions, and execution pathways — including which facilities share identical software assumptions, which execution pathways…Read this passage
F. Cost-causation.
printed heading · Topic match: Cost allocation
The reliability burdens created by large computational loads — including the burdens arising from the observability, validation, and dependency considerations above — should be assigned to the loads that cause them, on a cost-causation basis, rather than socialized onto residential and…Read this passage Filed comments: Cost allocation
G. Curtailment priority and observability of federally-accelerated computational load.
printed heading · Topic match: Reliability and curtailment
Consideration should be given to how curtailment priority is to be ordered where federally-directed or security-associated computational load may qualify for exemptions available to critical facilities — such that it could sit ahead of, rather than behind, ordinary large loads in a curtailment…Read this passage Filed comments: Reliability and curtailment
H. Unpriced resource consumption and diffuse externalized costs.
printed heading · Topic match: Cost allocation
Unpriced resource consumption and diffuse externalized costs.Read this passage Filed comments: Cost allocation
I. Transparency and the orientation of the just and reasonable standard.
printed heading · Topic match: Cost allocation
The Commission’s authority under the Federal Power Act was established to protect consumers and to ensure that rates are just and reasonable, and cost causation is the foundation of that standard.Read this passage Filed comments: Cost allocation
IV. Toward a Resolution — Verification at the Point of Interconnection
printed heading
Toward a Resolution — Verification at the Point of Interconnection The considerations above describe a common difficulty: the Commission is directed to ensure just and reasonable rates, reliability, and cost-causation for large computational loads whose behavior and costs it may be structurally…Read this passage
III. It certifies, against the full set of boundary invariants, whether the load can ramp, curtail, and operate
printed heading
It certifies, against the full set of boundary invariants, whether the load can ramp, curtail, and operate flexibly while remaining within the accepted stability envelope — that is, whether its timing (Gate I), its dependency profile (Gate II), and its throughput reconciliation (Gate III) together…Read this passage
V. Relationship to the Current Record and Pending Deadlines
printed heading · Topic match: Cost allocation
Commenter notes that the substance of these considerations — including intent-aware observability, continuous validation, software common-mode exposure, and dependency-based cost allocation — was authored and publicly timestamped prior to the actions now under consideration, and respectfully…Read this passage Filed comments: Cost allocation
VI. Reservation of Rights
printed heading
Reservation of Rights Commenter has authored and publicly timestamped a proprietary diagnostic, observability, and stability framework and holds pending United States Patent and Trademark Office applications relating thereto (USPTO Serial Nos. 99598875, 99600821, 99613073, 99717240, 99729215, and…Read this passage
VII. Conclusion
printed heading
Conclusion For the foregoing reasons, Commenter respectfully requests that the Commission consider these technical considerations in the above-captioned proceedings and take note of the reservation of rights stated herein.Read this passage