{"document":{"slug":"filing-20260708-5207","title":"Motion of L.M. Marlowe for the Establishment of Settlement Procedures and Convening of a Settlement Conference, or, in the Alternative, for the Appointment of a Settlement Judge","issued":"2026-07-08","accession":"20260708-5207","docket":"EL26-67-000","group":"PJM, SPP, NYISO, MISO, CAISO, ISO-NE filings","filer":"Individual No Affiliation","kind":"motion","file":"sources/originals/20260708-5207_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260708-5207","sha256":"590f7636faf25554a4cdfc3a18e673f13e52b227497083d37bb1b2de3465b1b5","pages":3,"tokens":1083,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":395,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nIntegration of Large Loads and Associated Reliability and Cost-\nAllocation Methodologies; \nShow-Cause Proceedings and Related Dockets \n) Docket No. EL26-67-000 \n) Docket No. EL26-68-000 \n) Docket No. EL26-69-000 \n) Docket No. EL26-70-000 \n) Docket No. EL26-71-000 \n) Docket No. EL26-72-000 \n) Docket No. RM26-4-000 \n) Docket No. RP26-358-000 \n \nMOTION OF L.M. MARLOWE FOR THE ESTABLISHMENT OF SETTLEMENT \nPROCEDURES AND CONVENING OF A SETTLEMENT CONFERENCE, OR, IN THE \nALTERNATIVE, FOR THE APPOINTMENT OF A SETTLEMENT JUDGE \nDate: July 8, 2026 \nThis motion is made in good faith by a private citizen and independent researcher, supported by extensive \noperational documentation and prior art. It is offered for the public benefit — to improve grid reliability, \ntransparency in large-load cost allocation, and the protection of ratepayers from systemic waste and undue cost-\nshifting — and seeks a timely and durable resolution of the matters presented. \nPursuant to Rules 601 and 603 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §§ \n385.601 and 385.603, Lisa Melton, filing as L.M. Marlowe (“Movant”), whose Motion to Intervene in the \nabove-captioned proceedings was accepted for filing (Accession No. 202607025022, July 2, 2026), \nrespectfully moves the Commission to establish settlement procedures and convene a settlement \nconference in these proceedings, or, in the alternative, to appoint a settlement judge to facilitate the \nresolution of the reliability and cost-allocation matters presented. In support, Movant states as follows. \nI. Introduction and Relief Requested \nThese proceedings concern reliability and cost-allocation problems arising from the interconnection of \nlarge computational loads — problems that are not prospective or hypothetical, but active and ongoing, as \nthe recent federal record establishes. Movant respectfully submits that the public interest is served by \nmoving these dockets toward negotiated resolution now, in parallel with the responses the Commission \nhas directed, rather than solely through extended, seriatim adjudication. Movant therefore requests that \nthe Commission: (1) establish settlement procedures and convene a settlement conference of the \nparticipants pursuant to Rule 601; or (2) in the alternative, and if the Commission finds settlement-judge \nprocedures appropriate, appoint a settlement judge pursuant to Rule 603 to facilitate settlement of the \nmatters presented. \nMovant proposes that any such settlement procedures be directed, in the first instance, to the discrete and \nshared technical questions common to these dockets — large-load observability, cost-allocation and cost-\ncausation, curtailment priority, and boundary-verification methodology — rather than to the entirety of"},{"page":2,"startToken":395,"endToken":969,"text":"every issue in all dockets at once. Movant further states its interest plainly: Movant is the author and \nrights-holder of a framework responsive to these questions, and seeks its consideration; the relevant \ntechnical methodology is set forth in Movant’s contemporaneously filed Supplemental Technical \nComment and is available to inform any settlement. Any terms relating to the adoption or use of that \nframework are matters for the appropriate forum and are not placed at issue by this motion. \nII. The Commission’s Authority to Convene Settlement at Any Time \nRule 601 provides that the Commission or other decisional authority “may convene a conference of the \nparticipants in a proceeding at any time for any purpose related to the conduct or disposition of the \nproceeding, including … the submission and consideration of offers of settlement … or the use of \nalternative means of dispute resolution.” 18 C.F.R. § 385.601. This authority is not limited to proceedings \nalready set for hearing. Rule 602 further provides that participants may submit offers of settlement “in \nany proceeding … whether pending or scheduled for hearing, at any time.” 18 C.F.R. § 385.602. Rule 603 \nprovides that a participant may move for the appointment of a settlement judge, and that where there is no \npresiding officer, such a motion is addressed to the Commission and may be acted upon at any time. 18 \nC.F.R. § 385.603. The relief requested is therefore available in the present posture of these proceedings. \nIII. Settlement Is Timely, Not Premature \nAny suggestion that a movement toward resolution is premature is not consistent with the documented \ncondition of the system at issue. The following federal actions, taken together, demonstrate that the \nreliability problems presented have been the subject of formal federal notice and emergency action for \nmonths, and remain active: \nDate \nFederal action on the reliability of large-load integration \n2026-05-04 \nNERC issued a Level 3 (Essential Actions) Alert addressing large computational loads, high-speed \nmonitoring, and sub-synchronous oscillation — the highest tier of NERC alert. \n2026-06-18 \nThe Commission issued Section 206 show-cause orders to the RTO/ISOs, preliminarily finding large-load \ntariff treatment potentially unjust and unreasonable. \n2026-06-30 \nThe Department of Energy issued a Section 202(c) emergency order (Order No. 202-26-32) directing \ncurtailment of large loads amid record demand, subsequently extended. \nOngoing \nRepeated emergency conditions and record demand across affected regions during the summer of 2026. \nA proceeding addressing an active and recurring reliability emergency — one already the subject of the \nhighest tier of reliability alert and of federal emergency orders — is not one in which movement toward \nresolution can reasonably be characterized as premature. The public interest disfavors delay where the \nunderlying conditions are present and ongoing. Settlement procedures may run in parallel with the \nresponses the Commission has directed and need not await their conclusion; early structured negotiation \nmay narrow issues, surface common ground, and reduce the time to a durable outcome. \nIV. Settlement Serves the Public Interest and Commission Policy \nThe Commission has long favored settlement as a means of resolving complex matters efficiently and \ndurably, and its rules are structured to encourage resolution at any stage. Settlement in these proceedings \nwould allow the participants — the RTO/ISOs, transmission owners, large-load and generation interests, \nState representatives, ratepayer advocates, and intervenors such as Movant — to work toward mutually \nacceptable reliability, observability, and cost-allocation methodologies under the guidance of a neutral, \nrather than through protracted contested proceedings alone. Given the number of dockets, the number of"},{"page":3,"startToken":969,"endToken":1083,"text":"parties, and the shared underlying technical questions, a structured settlement process is well suited to \nnarrowing and resolving the issues presented. \nV. Conclusion \nFor the foregoing reasons, Movant respectfully requests that the Commission establish settlement \nprocedures and convene a settlement conference pursuant to Rule 601, or, in the alternative, appoint a \nsettlement judge pursuant to Rule 603, to facilitate the resolution of these proceedings. Movant brings this \nmotion in good faith, seeking a timely and durable resolution that protects the reliability of the system and \nthe interests of the ratepaying public, and offers its participation toward that end. \nRespectfully submitted, \n_______________________________ \nLisa Melton aka L.M. Marlowe \nlm.marlowe@pm.me \nIntervenor / Movant, pro se"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1640,"startToken":0,"endToken":234},{"p":1,"at":1640,"title":"I. Introduction and Relief Requested","method":"printed heading","endPage":2,"endAt":499,"startToken":234,"endToken":472},{"p":2,"at":499,"title":"II. The Commission’s Authority to Convene Settlement at Any Time","method":"printed heading","endPage":2,"endAt":1506,"startToken":472,"endToken":639},{"p":2,"at":1506,"title":"III. Settlement Is Timely, Not Premature","method":"printed heading","endPage":2,"endAt":3202,"startToken":639,"endToken":876},{"p":2,"at":3202,"title":"IV. Settlement Serves the Public Interest and Commission Policy","method":"printed heading","endPage":3,"endAt":154,"startToken":876,"endToken":990},{"p":3,"at":154,"title":"V. Conclusion","method":"printed heading","endPage":3,"endAt":812,"startToken":990,"endToken":1083}]}