EL26-67-000 · 2026-07-08 · Individual No Affiliation

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

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 
) Docket No. RM26-4-000 
) Docket No. RP26-358-000 
 
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 
Date: July 8, 2026 
This motion 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 — and seeks a timely and durable resolution of the matters presented. 
Pursuant to Rules 601 and 603 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §§ 
385.601 and 385.603, Lisa Melton, filing as L.M. Marlowe (“Movant”), whose Motion to Intervene in the 
above-captioned proceedings was accepted for filing (Accession No. 202607025022, July 2, 2026), 
respectfully moves the Commission to establish settlement procedures and convene a settlement 
conference in these proceedings, or, in the alternative, to appoint a settlement judge to facilitate the 
resolution of the reliability and cost-allocation matters presented. In support, Movant states as follows. 
I. Introduction and Relief Requested 
These proceedings concern reliability and cost-allocation problems arising from the interconnection of 
large computational loads — problems that are not prospective or hypothetical, but active and ongoing, as 
the recent federal record establishes. Movant respectfully submits that the public interest is served by 
moving these dockets toward negotiated resolution now, in parallel with the responses the Commission 
has directed, rather than solely through extended, seriatim adjudication. Movant therefore requests that 
the Commission: (1) establish settlement procedures and convene a settlement conference of the 
participants pursuant to Rule 601; or (2) in the alternative, and if the Commission finds settlement-judge 
procedures appropriate, appoint a settlement judge pursuant to Rule 603 to facilitate settlement of the 
matters presented. 
Movant proposes that any such settlement procedures be directed, in the first instance, to the discrete and 
shared technical questions common to these dockets — large-load observability, cost-allocation and cost-
causation, curtailment priority, and boundary-verification methodology — rather than to the entirety of

every issue in all dockets at once. Movant further states its interest plainly: Movant is the author and 
rights-holder of a framework responsive to these questions, and seeks its consideration; the relevant 
technical methodology is set forth in Movant’s contemporaneously filed Supplemental Technical 
Comment and is available to inform any settlement. Any terms relating to the adoption or use of that 
framework are matters for the appropriate forum and are not placed at issue by this motion. 
II. The Commission’s Authority to Convene Settlement at Any Time 
Rule 601 provides that the Commission or other decisional authority “may convene a conference of the 
participants in a proceeding at any time for any purpose related to the conduct or disposition of the 
proceeding, including … the submission and consideration of offers of settlement … or the use of 
alternative means of dispute resolution.” 18 C.F.R. § 385.601. This authority is not limited to proceedings 
already set for hearing. Rule 602 further provides that participants may submit offers of settlement “in 
any proceeding … whether pending or scheduled for hearing, at any time.” 18 C.F.R. § 385.602. Rule 603 
provides that a participant may move for the appointment of a settlement judge, and that where there is no 
presiding officer, such a motion is addressed to the Commission and may be acted upon at any time. 18 
C.F.R. § 385.603. The relief requested is therefore available in the present posture of these proceedings. 
III. Settlement Is Timely, Not Premature 
Any suggestion that a movement toward resolution is premature is not consistent with the documented 
condition of the system at issue. The following federal actions, taken together, demonstrate that the 
reliability problems presented have been the subject of formal federal notice and emergency action for 
months, and remain active: 
Date 
Federal action on the reliability of large-load integration 
2026-05-04 
NERC issued a Level 3 (Essential Actions) Alert addressing large computational loads, high-speed 
monitoring, and sub-synchronous oscillation — the highest tier of NERC alert. 
2026-06-18 
The Commission issued Section 206 show-cause orders to the RTO/ISOs, preliminarily finding large-load 
tariff treatment potentially unjust and unreasonable. 
2026-06-30 
The Department of Energy issued a Section 202(c) emergency order (Order No. 202-26-32) directing 
curtailment of large loads amid record demand, subsequently extended. 
Ongoing 
Repeated emergency conditions and record demand across affected regions during the summer of 2026. 
A proceeding addressing an active and recurring reliability emergency — one already the subject of the 
highest tier of reliability alert and of federal emergency orders — is not one in which movement toward 
resolution can reasonably be characterized as premature. The public interest disfavors delay where the 
underlying conditions are present and ongoing. Settlement procedures may run in parallel with the 
responses the Commission has directed and need not await their conclusion; early structured negotiation 
may narrow issues, surface common ground, and reduce the time to a durable outcome. 
IV. Settlement Serves the Public Interest and Commission Policy 
The Commission has long favored settlement as a means of resolving complex matters efficiently and 
durably, and its rules are structured to encourage resolution at any stage. Settlement in these proceedings 
would allow the participants — the RTO/ISOs, transmission owners, large-load and generation interests, 
State representatives, ratepayer advocates, and intervenors such as Movant — to work toward mutually 
acceptable reliability, observability, and cost-allocation methodologies under the guidance of a neutral, 
rather than through protracted contested proceedings alone. Given the number of dockets, the number of

parties, and the shared underlying technical questions, a structured settlement process is well suited to 
narrowing and resolving the issues presented. 
V. Conclusion 
For the foregoing reasons, Movant respectfully requests that the Commission establish settlement 
procedures and convene a settlement conference pursuant to Rule 601, or, in the alternative, appoint a 
settlement judge pursuant to Rule 603, to facilitate the resolution of these proceedings. Movant brings this 
motion in good faith, seeking a timely and durable resolution that protects the reliability of the system and 
the interests of the ratepaying public, and offers its participation toward that end. 
Respectfully submitted, 
_______________________________ 
Lisa Melton aka L.M. Marlowe 
lm.marlowe@pm.me 
Intervenor / Movant, pro se