{"document":{"slug":"filing-20260720-5218","title":"Eolian, L.P. submits Limited Request for Clarification or, In the Alternative, Rehearing of the 06/18/2026 Order Instituting Proceedings Under Section 206 of the Federal Power Act","issued":"2026-07-20","accession":"20260720-5218","docket":"EL26-67-001","group":"PJM, NYISO, MISO, CAISO, ISO-NE filings","filer":"Eolian, L.P.","kind":"request","file":"sources/originals/20260720-5218_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260720-5218","sha256":"7d234b5709c8f1ba8328d85eaa1a3cfa9f44c8dfe5cccd6e194d961edbfd8e45","pages":28,"tokens":8310,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":244,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nPJM Interconnection, L.L.C., et al. \nDocket No. EL26-67-000 \nNew York Independent System Operator, Inc., et al. \nDocket No. EL26-69-000 \nMidcontinent Independent System Operator, Inc., et \nal. \nDocket No. EL26-70-000 \nCalifornia Independent System Operator \nCorporation, et al. \nDocket No. EL26-71-000 \nISO New England Inc., et al. \nDocket No. EL26-72-000 \n \n \n \nLIMITED REQUEST FOR CLARIFICATION OR, IN THE ALTERNATIVE, \nREHEARING BY EOLIAN, L.P. OF THE COMMISSION’S ORDERS \nINSTITUTING PROCEEDINGS UNDER SECTION 206 OF THE FEDERAL \nPOWER ACT \n \nPursuant to section 313(a) of the Federal Power Act (“FPA”), 16 U.S.C. § 825l (2024), \nand Rule 713 of the Rules of Practice and Procedure of the Federal Energy Regulatory \nCommission (“Commission” or “FERC”), 1 Eolian, L.P. (“Eolian”), requests clarification or,  in \nthe alterative, rehearing of the Commission’s June 18 Orders in the above-captioned proceedings \n(“Large Load Show Cause Orders” or “Orders”).  \nThe Large Load Show Cause Orders take critical steps to facilitate more timely \ninterconnection for large load customers while ensuring the affordability and reliability of the \nelectric system for existing customers. Eolian strongly supports the steps taken in these orders, \nwhich demonstrate exactly the bold leadership this moment demands. We request rehearing of \none aspect of the Orders that would severely limit the scope of any subsequent replacement rates \nand prevent the Orders from achieving the robust benefits to just and reasonable rates and \n \n1 18 C.F.R. § 385.713."},{"page":2,"startToken":244,"endToken":533,"text":"2 \nreliability that they aim to achieve. Specifically, while the Orders preliminarily find it unjust and \nunreasonable for RTO/ISO tariffs to fail to recognize the ability of large loads to limit their \nwithdrawals from the transmission system under certain conditions and propose that transmission \nservices that reflect their use of the transmission system be available on both an interim and \npermanent basis,2 the Orders appear to practically limit the availability of the new transmission \nservices by failing to provide for matching availability of permanent large load-limited generator \ninterconnection services.  \nBecause the Commission appears to categorically limit the availability of permanent \ngenerator interconnection services to co-located generation,3 while requiring any load-limited \ngeneration interconnection service for electrically proximate generation serving large loads to be \ntemporary, electrically proximate generators that are equally capable of serving large loads and \nenabling them to limit their withdrawals from the transmission system face a significant barrier \nto development. 4 In short, large loads’ ability to make use of the new transmission services will \nbe severely limited if new front-of-the-meter generation projects that would be willing and able \nto serve a large load on a long-term basis are unable to support use of the new permanent \ncontract demand transmission service and interim network integration transmission service \n(“Interim NITS”). Limited uptake of the new transmission services will, in turn, greatly limit the \nability of the Commission’s Orders to ensure just and reasonable and not unduly discriminatory \nrates.   \n \n2 See, e.g., Midcontinent Independent System Operator, Inc., 195 FERC ¶ 61,212, at PP 99-105 \n(2026) (“MISO Order to Show Cause”). \n3 Throughout this filing, we use the term “generation” to include both generation and energy \nstorage resources. \n4 MISO Order to Show Cause, at P 115."},{"page":3,"startToken":533,"endToken":837,"text":"3 \nFirst, we request that the Commission clarify, or grant rehearing if necessary, to provide \nthat electrically proximate generation may access permanent load-limited generator \ninterconnection service where it is equally capable of enabling the large load to limit its \nwithdrawals from the transmission system on a long-term basis without creating system \nreliability risks. Failure to do so will greatly limit the potential solutions that RTO/ISOs may \npropose in response to the Orders, and therefore greatly limit the real-world impact and benefits \nof the Orders. At minimum, we request that the Commission make clear that RTO/ISOs are not \nlimited in their ability to provide permanent load-limited generator interconnection service where \nthe generator is capable of enabling the large load to limit its withdrawals from the transmission \nsystem on a long-term basis without reliability concerns, and that the Commission strongly \nencourage RTO/ISOs to make such service broadly available.  \nSecond, and relatedly, we seek rehearing or clarification of the Orders because they \nappear to leave too much flexibility to RTO/ISOs to provide only very limited reforms to their \ngenerator interconnection study processes and services. While we do not believe the Commission \nintended to afford so much flexibility to RTO/ISOs that they could adopt minimal reforms that \ndo not achieve the objective of ensuring just and reasonable and not unduly discriminatory rates, \nthe Orders include some language that could be interpreted as such. The Commission must \nclarify this discussion, so that it does not inadvertently create a loophole that would undermine \nthe critical benefits of its Orders to reliability, affordability, limiting cost shifts, and speed to \npower.   \nI. \nCONCISE STATEMENT OF ISSUES AND SPECIFICATION OF ERRORS \n(1) The Commission’s Orders arbitrarily and capriciously limit RTO/ISOs’ ability to put \nin place a replacement rate that will ensure just and reasonable and not unduly"},{"page":4,"startToken":837,"endToken":1129,"text":"4 \ndiscriminatory rates by not requiring and/or by limiting their ability to adopt a \npermanent load-limited generator interconnection service for front-of-the-meter \nresources that are capable of enabling large loads to limit their withdrawals from the \ntransmission system under certain conditions on a long-term basis without resulting in \nreliability concerns. See 16 U.S.C. § 824d(a)-(b); Consol. Edison Co. of New York v. \nFERC, 45 F.4th 265, 282 (2022); Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State \nFarm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983). \n(2) The Commission’s Orders arbitrarily and capriciously provide that minimal reforms \nto RTO/ISO generator interconnection processes may suffice despite a broader \npreliminary finding of unjust and unreasonable rates. Without commensurate reforms \nto the generator interconnection process to enable generating resources to timely \nserve large loads, the Commission’s Orders cannot achieve its stated aims and ensure \njust and reasonable and not unduly discriminatory rates. See Motor Vehicle Mfrs., 463 \nU.S. at 43. \nII. \nARGUMENT \nA. \nThe Commission’s Orders Seek to Address Urgent Problems Due to Large \nLoad Growth, but Cannot Achieve Sufficient Scale Impact Without a Key \nModification.    \nEolian fully supports the Commission’s preliminary findings that a series of actions is \nnecessary to ensure just and reasonable and not unduly discriminatory rates in RTO/ISOs in light \nof the significant acceleration of large loads seeking to interconnect, which poses the potential \nfor impacts to reliability and affordability, cost shifts among transmission customers, and delays \nin interconnection and service of large loads. Eolian seeks rehearing or clarification of the \nCommission’s Orders solely to address one unreasonable limitation on the scope of actions that \nRTO/ISOs would be required to take under the Orders, because that limitation would create a"},{"page":5,"startToken":1129,"endToken":1519,"text":"5 \nsignificant barrier to large loads’ ability to use the new transmission services directed under the \nOrders, and therefore would significantly impair the ability of the Orders to ensure just and \nreasonable and not unduly discriminatory rates. To be able to use the new transmission services \non a widespread basis rather than in limited circumstances, large loads must be able to \ncommercially transact with new generation resources to serve them, so that they can limit their \nwithdrawals from the transmission system. Large loads will not be able to transact with new \nfront-of-the-meter resources if resource developers face significant commercial barriers to \ninterconnection, including the cost and timing uncertainty of the traditional generator \ninterconnection queue procedures. Because the Commission’s Orders limit the availability of a \npermanent large load-limited generator interconnection to only a small subset of front-of-the-\nmeter configurations that would be capable of serving large loads on a long-term basis, the \nOrders unduly constrain the ability of these generators to serve large loads.    \n1. \nThe Commission has preliminarily determined that new transmission \nservices must be made available for large loads that limit their withdrawals \nfrom the transmission system.  \nThe Commission’s Orders seek to address a series of critical challenges that arise due to \nthe rapid growth of large loads seeking to interconnect and be served through the transmission \nsystem.5 Absent action to address these challenges, the Commission has determined that the \n \n5 See, e.g., MISO Order to Show Cause, at P 1 (“[L]arge loads are not efficiently and \nappropriately integrated onto the transmission system; have identified a number of unique \nchallenges that large load integration poses for the reliable operation of that system; and have \ndebated how best to ensure that the rates, terms, and conditions of transmission service remain \njust and reasonable as more and more large loads are onboarded onto that system . . . The records \nin these proceedings likewise present serious concerns about the lack of clarity and consistency \nin Regional Transmission Organization or Independent System Operator (RTO/ISO) tariffs—\nincluding with respect to the rates, terms, and conditions of service that apply to flexible large \nloads, co-location arrangements, load with behind the meter generation, and generating facilities \nwith electrically proximate large load or co-located load”); id. at P 12 (“many commenters in the \nANOPR proceeding filed persuasive comments documenting, generally, the need for clear and"},{"page":6,"startToken":1519,"endToken":1848,"text":"6 \nstatus quo may not ensure just and reasonable and not unduly discriminatory rates. One of the \ndeficiencies the Commission seeks to address through its Orders is to ensure RTO/ISO tariffs \n“include transmission services that reflect Eligible Customers taking transmission service on \nbehalf of Eligible Load that are willing and able to limit their use of the transmission system \nunder certain conditions.”6 The Commission considers availability of such new transmission \nservices necessary because “certain large loads are able to limit their withdrawals from the \ntransmission system under certain conditions. Namely, commenters observe that flexible large \nloads can quickly and verifiably adjust their consumption in response to system conditions or \nprice signals.”7 The Commission further explained that, “Eligible Customers taking transmission \nservice on behalf of Eligible Load should be allowed to choose a transmission service that aligns \nwith their use of the transmission system and therefore aligns the charges for service with the \nbenefits received.”8 Enabling access to the new transmission services for loads that are willing \nand able to limit their use of the transmission system “can avoid inefficient and costly \ntransmission system build-out” and “could help timely interconnect flexible large loads.”9 \nIt is evident that the Commission believes that making these new transmission services \navailable to large loads is necessary because it expects a significant number of large loads \ninterconnecting to and seeking services from the transmission system would make use of the new \ntransmission services if they are available, thereby avoiding unneeded transmission infrastructure \n \nconsistent tariff provisions to ensure regulatory and process certainty, fairness and consistency, \nand efficiency as large and co-located loads are added to the transmission system in increasing \nnumbers.  There is also broad support for rules that help to ensure that other transmission \ncustomers are not unfairly burdened with additional costs or reliability impacts as large and co-\nlocated loads interconnect to the transmission system.”) \n6 Id. P 102. \n7 Id. P 103. \n8 Id. P 104 \n9 Id."},{"page":7,"startToken":1848,"endToken":2158,"text":"7 \nbuild-out, providing reliability benefits by limiting strain on the transmission system, reducing \nthe cost impacts to bulk power sales by encouraging loads to commercially transact with new \ngeneration resources to be able to access the new transmission services, and enhancing speed-to-\npower. We agree with these conclusions, which are well-supported by the record.   \n2. \nThe Commission’s Orders will not achieve widespread benefits if few \nlarge loads are able to avail themselves of the new transmission services. \nThe uptake of the new transmission services will be limited, however, if large loads \ncannot identify sufficient new generation resources to support their ability to limit their \nwithdrawals from the transmission system during certain conditions. Large loads vary in their \nability to curtail their operations depending on their business model. Large loads that cannot \ncommit to curtail their operations may, nonetheless, be able to commit to limit their use of the \ntransmission system by transacting with generation resources that will continue to serve their \nload at times when withdrawals from the broader network must be limited. The more diverse the \nconfigurations of resources that are eligible to serve a large load and enable it to limit its \nwithdrawals from the transmission system—i.e., the ability to rely on behind-the-meter \ngeneration, front-of-the-meter generation that is co-located, or front-of-the-meter generation that \nis electrically proximate—the more likely it is that a large load will be able to identify an \narrangement that works for its business model. If few new generating resources are able to \ntransact to serve large loads because resource developers face insurmountable or significant \ncommercial barriers to offering such services, large loads will not be able to procure such \nservices at reasonable cost and there will be much more limited uptake of the new transmission \nservices. This, in turn, will mean that making the new transmission services available has little \nreal-world impact."},{"page":8,"startToken":2158,"endToken":2472,"text":"8 \nIn summary, for the Commission’s Orders to ensure just and reasonable and not unduly \ndiscriminatory rates, not only must large loads have the theoretical capability to use the new \ntransmission services, but generating resources must also be available on a timely basis to serve \nthese new large loads and enable the large loads to reduce their use of the bulk power system.     \n3. \nSignificant limitations on the front-of-the-meter resource \nconfigurations that may use permanent large load-limited generator \ninterconnection service create a barrier to commercial development and \nconstrain the resources available to serve large loads.  \n \nWhile the Orders recognize the need for reforms to RTO/ISO generator interconnection \nprocesses that would afford some resources the opportunity to more timely serve large loads, the \nOrders contain a key limitation on the scope of the generator interconnection service and study \nprocess that RTO/ISOs must provide. Because the Orders appear to unreasonably limit \npermanent load-limited generator interconnection service to only co-located resources, many \nnew generating resources that are capable and willing to commit to reliably serving a large load \non a long-term basis will be unable to do so.   \nThe Orders preliminarily find that RTO/ISOs’ generator interconnection processes require \nreforms to “reflect an interconnection customer’s commitment in an interconnection agreement \nto limit the generating facility’s output to minimize the impact on the transmission system while \nserving an electrically proximate large load or large co-located load.”10 The Commission \nrecognizes that “[w]here a generating facility’s output is matched to the demand of the \nelectrically proximate large load or large co-located load or if the generating facility’s output is \nlimited to ensure no new injection, the impacts to the transmission system of interconnecting the \ngenerating facility to serve that electrically proximate large load or large co-located load may be \nlimited, thereby potentially reducing the need for Network Upgrades, which can accelerate the \n \n10 Id. P 113."},{"page":9,"startToken":2472,"endToken":2766,"text":"9 \ngenerator interconnection process.”11 The Commission further notes that where a generating \nfacility and load are located closely on the transmission system and the generating facility’s \noutput matches the load’s demand,  “the transmission provider would need to study only the local \nimpacts because the impact on the transmission system of the combination of the generating \nfacility and the load, with the exception of the transmission facilities between the two, will be \neffectively the same as if they were located at the same substation.”12 \nYet even as the Commission recognizes the value of an interconnection service and study \nprocess tailored to more limited service to a specific load, the Commission imposes practical \nlimits on the availability of such a load-limited interconnection study process and service. The \nOrders specify that while “it may be reasonable for the generator interconnection service to be \npermanent” “[t]o the extent that the interconnection customer’s generating facility is serving a \nlarge co-located load,” where “the interconnection customer’s generating facility is serving an \nelectrically proximate large load, we believe that the generator interconnection service should be \nof an interim nature until the interconnection customer obtains Energy Resource Interconnection \nService (ERIS) or Network Resource Interconnection Service (NRIS).”13 This potential \nrestriction, unless clarified, threatens to greatly limit the use of load-limited generator \ninterconnection service.  \nAs a practical matter, to be able to provide limited service to a large load and enable that \nlarge load to avoid or reduce its reliance on the transmission system, a generating resource must \nhave (i) access to an interconnection process that enables it to interconnect and commence \noperation in time to serve the large load and (ii) reasonable cost certainty to understand if the \n \n11 Id.  \n12 Id. at n. 48. \n13 Id. P 115."},{"page":10,"startToken":2766,"endToken":3064,"text":"10 \nproject is commercially viable. In Eolian’s commercial experience, co-location is a much more \nchallenging resource configuration to achieve, because limits on space at the load site may \nprevent such a configuration; and because it is more commercially complex to coordinate the \ndevelopment timelines of both the load and the new generating facility at the same site. In \ncontrast, the ability for a resource to locate in an electrically proximate or electrically equivalent \nsite, rather than only on the same site as the load, increases the likelihood that a commercially \nviable arrangement can be found to serve a specific large load. \nBut, based on Eolian’s experience as a developer of generating facilities that seek to serve \nlarge loads, few developers will be able to develop resources that are electrically proximate if the \nonly available load-limited interconnection service is temporary and requires the resource to \nmake its way through the standard generator interconnection process to obtain permanent \ninterconnection service. The standard generator interconnection process remains plagued by long \ndelays and the potential for high-cost, project-killing network upgrades. A developer that is \nprovided access to only a temporary interconnection service must make the decision to invest in \nthe full cost of developing its generating facility years before it will learn the total all-in cost of \nthe project, because it will face a decision whether to proceed to commercial operation under a \ntemporary load-limited generator interconnection service long before it will be studied and learn \nits actual network upgrade costs to obtain permanent NRIS or ERIS interconnection service. Cost \nuncertainty that can range in the tens to hundreds of millions of dollars for additional network \nupgrades, or even more in particularly constrained parts of the transmission system, typically \nresults in a potential project being unfinanceable and non-viable. It is therefore Eolian’s"},{"page":11,"startToken":3064,"endToken":3374,"text":"11 \nexpectation based on its commercial experience that few developers will be able to make use of a \nsolely temporary load-limited interconnection service.14  \nThis challenge of cost uncertainty for temporary interconnection service means that, even \nfor Interim NITS customers, generation developers can much more readily provide \ncorresponding load-limited service if that service is permanent. A permanent interconnection \npathway provides the resource with the financial certainty necessary to support development, \neven if in the future that resource likely will elect to proceed through the standard queue \n(pending study results that show a commercially workable level of network upgrade costs). \nWhile a load-limited interconnection would restrict the generation to serving the load, which \nwould itself graduate to full network service, the generation resource could continue to provide \nits service to the load. Permanent service could, for instance, facilitate a long-term power \npurchase agreement between the load and generator, whereas temporary service would likely \nrender such an arrangement non-viable (because the generator’s ability to serve the load over the \nlong-run would remain highly uncertain given the potential for project-killing cost assessments \nassociated with obtaining permanent service).  \nAnd for transmission customers taking contract demand service, temporary load-limited \ngeneration interconnection is an even worse match. Where a transmission customer plans to \nreduce its long-term reliance on the transmission system by leveraging the capability of a \ngeneration resource, the obligation to transition to NRIS or ERIS will result in unnecessary \n \n14 In Eolian’s experience, this challenge of uncertain costs for permanent service will prevent the \ndevelopment of new resources even in SPP, where the region is providing for up-front \ninterconnection charges, because the size of those up-front charges is not known at the time a \nresource may pursue Load Limited Resource Interconnection Service through the region’s High \nImpact Load Generation Assessment process. But in regions without such up-front charges, this \nchallenge is even more magnified."},{"page":12,"startToken":3374,"endToken":3648,"text":"12 \ntransmission upgrades, introducing excessive and uncertain costs and therefore stymying the \ncommercial arrangements necessary to facilitate the pairing.   \nBetween the practical barriers to co-location arrangements, and the commercial barriers \nto electrically proximate front-of-the-meter arrangements, the Commission’s Orders are unlikely \nto unlock the rapid development of sufficient resources to match the rapid pace of large load \nadditions.        \nB. \nAbsent modification or clarification, the Commission’s Orders unreasonably \nlimit RTO/ISOs’ ability to use a significant tool in the toolkit to address the impacts \nof large loads. \nThe Commission’s justification for limiting permanent load-limited generator \ninterconnection service to co-located resources appears to be that, for such configurations, “there \nwill be no injections onto the transmission system and therefore” permanent load-limited \ninterconnection service “does not present operational or planning risks for reliability.”15 But as \nexplained in the affidavit of Andrew Levitt, imposing a “co-location requirement for permanent \nLLGIS would disqualify many configurations that present the same simplified reliability picture \nas co-located arrangements.”16 Such broad disqualification is not necessary because many \nresources that are not “co-located” as that term is defined in the Commission’s orders, \nnevertheless could connect on a permanent load-limited basis while imposing essentially the \nsame lack of reliability impacts to the broader system. RTOs have identified locations that are \n“electrically equivalent”, which means load and generation could be at locations that, while not \nthe same, are electrically equivalent in terms of their impacts on the grid.  This would allow for a \nbroader set of load-generation agreements than “co-location” as currently defined by the \nCommission.  SPP, for example, defines electrical equivalence as “[a] relationship between \n \n15 Id. P 115. \n16 Levitt Affidavit at 6."},{"page":13,"startToken":3648,"endToken":3946,"text":"13 \nPoints of Interconnection (POI) that are (1) at the same substation and nominal voltage level, (2) \non the same branch or on a collection of in series two-terminal branches and associated buses \nand facilities, or (3) on the same radial branch and associated facilities.”17 \nThis broader category of generation-load pairings nevertheless imposes the same lack of \nsystem impact risks as co-located resources because “[e]lectrically equivalent interconnection \npoints are defined to be functionally identical for reliability purposes.”18 Numerous RTOs have \nimplemented services and study processes based on this general concept because, as MISO \nstates, electrical equivalence criteria “‘limit potential impacts to flow in the transmission \nsystem’, ‘will not cause new constraints in the contingency analysis’, will ‘minimize impacts to \nflow and therefore other projects in the interconnection queue’, all ‘without subjecting other \nprojects to an unreasonable risk of causing network upgrades’.”19  \nAs Levitt explains, regions also implement this same sort of analysis when conducting \ngenerator replacement analysis: “In generator replacement, the test asks whether moving the \npoint of injection from Point A to Point B materially changes transmission impacts. For \npermanent LLGIS, it asks the same question about locating new generation at Point A (behind \nthe load’s point of interconnection) or at Point B. In each case, the central planning question is \nwhether the alternate generation connection point produces material grid impacts: new \nconstraints, materially different power flows, or harm to queued projects.”20 While it is true that \n“[w]ith permanent LLGIS, electricity may flow across a short segment of public transmission \nbetween the generator and load, . . . that fact alone does not establish the kinds of regional \n \n17 Id. at 7 (citing  SPP, Generator Interconnection (DSIS) Manual, Version 4.4 (March 31, 2026) \nat 7). \n18 Id.  \n19 Id.  \n20 Id. at 8."},{"page":14,"startToken":3946,"endToken":4217,"text":"14 \nimpacts addressed by the full interconnection queue. Rather,” the relevant consideration “is \nwhether the arrangement creates material grid impacts. MISO’s and SPP’s generator replacement \ntests for electrical equivalence reflect that impact-based approach, and it can be applied with \nequal effectiveness to similarly-situated load-limited generators connecting close to their paired \nloads.”21 \nA resource that is in an “electrically equivalent” location as load but not co-located with \nit is similarly situated in its ability to limit the load’s withdrawal from the transmission system, \nbecause a transmission customer may rely on the resources in an “electrically equivalent” \nlocation, offsetting load when the broader system is constrained without creating adverse \nreliability impacts for other customers. In fact, “electrically equivalent generation/load pairings \nmay improve reliability outcomes compared to the behind-the-meter frameworks that the \nCommission has already required to be permanent, as a result of the improved metering, \ntelemetry, scheduling, and control required of the various front-of-the-meter components of the \npaired LLGIS facilities.”22  \nC. \nThe Orders fail to require broad enough reforms to the generator \ninterconnection study process and services to ensure the Orders achieve their \ncritical objectives. \nFinally, the Commission’s Orders contain contradictory discussion of RTO/ISOs’ \nobligation to implement reforms to the generator interconnection processes that could lead to \nconfusion and may limit the Commission’s ability to require reforms that are sufficient to ensure \njust and reasonable and not unduly discriminatory rates. On the one hand, the Orders \npreliminarily find most RTO/ISOs’ tariffs unjust and unreasonable because they do not contain \nprovisions to allow “an interconnection to seek the generator interconnection service(s) that \n \n21 Id. \n22 Id. at 8-9."},{"page":15,"startToken":4217,"endToken":4525,"text":"15 \nreflects the operational dynamics of serving either: (1) an electrically proximate large load; or (2) \na co-located load, as defined in this order, that has a high peak load (i.e., large co-located loads \nthat are 50 MW or greater).”23 Such a deficiency would only be addressed by ensuring that \nresources that are similarly situated in their interest and ability to serve a specific large load have \naccess to an interconnection study process and generator interconnection service that enables \nthem to provide more limited service to a particular load, and that specifies any conditions to \nsuch access. If the new generator interconnection study process and services are broadly \navailable to resources willing and able to provide such limited service, the reforms will be \nexpansive enough to achieve the Commission’s aims, as discussed above, by avoiding unneeded \ntransmission infrastructure build-out, providing reliability benefits, reducing the cost impacts, \nand enhancing speed-to-power. The reforms would be right-sized to the scale of the problem, \nbecause sufficient generation can be interconnected through the generator interconnection \nreforms to enable significant numbers of large loads to utilize the new transmission services, \nwhich in turn, mitigates the impacts of large load interconnections.  \nYet later in the Orders, the Commission appears to suggest that a much more limited set \nof generator interconnection reforms may be sufficient to address the deficiency. The \nCommission suggests that “another potentially reasonable approach to address our concerns” \ncould include (i) allowing new generating facilities to interconnect with a new load behind an \nexisting generator’s point of interconnection or (ii) allowing a new generating facility and a new \nload to interconnect behind the same new point of interconnection.24 While Eolian is not opposed \nto these as potential additional pathways to enable a generating facility to receive limited \n \n23 MISO Order to Show Cause, at P 113. \n24 Id. P 116."},{"page":16,"startToken":4525,"endToken":4719,"text":"16 \ninterconnection service in order to serve a particular load, the Commission’s suggestion that \nthese very constrained pathways may be sufficient to ensure just and reasonable rates in light of \nthe extreme pace of large load additions in regions across the country is illogical. There is no \nbasis to believe that providing such reforms would eliminate the need for an appropriate \ninterconnection study process for co-located or electrically proximate generation and load pairs. \nAny flexibility to tailor the generator interconnection reforms to the unique \ncircumstances of the region must be paired with an obligation on the RTO/ISO to show that the \nset of reforms it proposes will enable a pathway for significant generating capacity to provide \nload-limited interconnection, in light of the pace of large load additions and their projected \ngrowth in the region. Without such a limitation to ensure that the scope of the reforms matches \nthe scope of the problem in the region, the Commission’s Orders will not ensure just and \nreasonable and not unduly discriminatory rates.    \n \nIII. \nCONCLUSION \nFor the foregoing reasons, Eolian respectfully requests that the Commission grant the \nrequested clarifications or, in the alternative, grant rehearing. \n \n \nRespectfully submitted,"},{"page":17,"startToken":4719,"endToken":4755,"text":"17 \nKim Smaczniak \nMiles Farmer \nAvi Zevin \nRoselle LLP \n300 New Jersey Ave. NW, Suite 300 \nWashington, DC 20001 \nkim.smaczniak@rosellellp.com \nmiles.farmer@rosellellp.com \navi.zevin@rosellellp.com \n \nCounsel for Eolian L.P."},{"page":18,"startToken":4755,"endToken":4814,"text":"CERTIFICATE OF SERVICE \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary of the Commission in these \nproceedings. \n \nDated: July 20, 2026 \n/s/ Nathan Lobel \nNathan Lobel \nRoselle LLP \n300 New Jersey Ave. NW, Suite 300 \nWashington, DC 20001 \nnathan.lobel@rosellellp.com"},{"page":19,"startToken":4814,"endToken":4889,"text":"ATTACHMENT A \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nPJM Interconnection, L.L.C., et al. \nDocket No. EL26-67-000 \nNew York Independent System Operator, Inc., \net al. \nDocket No. EL26-69-000 \nMidcontinent Independent System Operator, \nInc., et al. \nDocket No. EL26-70-000 \nCalifornia Independent System Operator \nCorporation, et al. \nDocket No. EL26-71-000 \nISO New England Inc., et al. \nDocket No. EL26-72-000 \nAFFIDAVIT OF \nANDREW LEVITT  \nON BEHALF OF \nEOLIAN, L.P. \nJuly 20, 2026"},{"page":20,"startToken":4889,"endToken":5290,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 2 of 10 \nI. \nQUALIFICATIONS \n1 \nMy name is Andrew Levitt. I am a Senior Consultant at The Brattle Group (Brattle).  \n2 \nI am an expert on wholesale market design and reliability implications of changes in the power \n3 \nsystem. I have consulted for Independent System Operators and Regional Transmission \n4 \nOrganizations (ISO/RTOs) such as the Midcontinent Independent System Operator (MISO), the \n5 \nNew York Independent System Operator (NYISO), the Alberta Electric System Operator \n6 \n(AESO), and the Independent Electricity System Operator (IESO) of Ontario, and helped other \n7 \nclients navigate ISO/RTO changes nationwide. Prior to joining Brattle in 2022, I was on staff at \n8 \nPJM for seven years (most recently as Lead Market Designer), where I developed reforms to \n9 \nreliably integrate new resource types. I hold an MMP from the University of Delaware and a BSc \n10 \nin physics from the University of Toronto. \n11 \nI have worked extensively on the benefits of co-located loads and generation and how such \n12 \narrangements can be facilitated to reduce costs, achieve faster connection of new loads and \n13 \ngeneration, and ensure reliability. This includes co-authored affidavits and reports in prior filings \n14 \nbefore the Federal Energy Regulatory Commission (FERC or Commission) on co-location, \n15 \nincluding an affidavit on behalf of Eolian filed in FERC Docket No. RM26-4-000 \n16 \non Interconnection of Large Loads to the Interstate Transmission System and a report on behalf \n17 \nof Bloom Energy filed in Docket EL25-49-000 on Accelerating the Integration of New Co-\n18 \nlocated Generation and Loads.1 \n19 \nII. \nASSIGNMENT \n20 \nI was asked by Eolian, L.P. to assess the five recent Commission Orders on co-located and \n21 \nelectrically proximate generation and load pairings, issued June 18, 2026 in the above-captioned \n22 \ndockets. In particular, I was asked to assess how Load-Limited Generator Interconnection \n23 \nService (LLGIS) can facilitate the efficiency, speed, and reliability benefits of new generation \n24 \n \n1  \nAffidavit of Andrew Levitt, Aniruddh Mohan, Ryan Quint, and Sirisha Tanneeru on Behalf of Eolian Energy, \nInc., before the Federal Energy Regulatory Commission in the matter of Interconnection of Large Loads to the \nInterstate Transmission System, Docket No. RM26-4-000, November 21, 2025; A. Levitt, J. Pfeifenberger, and \nA. Mohan, Accelerating the Integration of New Co-located Generation and Loads, prepared for Bloom Energy \nas part of Docket No. EL25-49-000, April 23, 2025."},{"page":21,"startToken":5290,"endToken":5632,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 3 of 10 \nco-located with new load (“co-location arrangements”), consistent with the Commission’s \n1 \nobjectives.  \n2 \nIII. \nBACKGROUND \n3 \nIn a set of six orders issued June 18, 2026, the Commission initiated separate show-cause \n4 \nproceedings for each wholesale market region, requiring each ISO/RTO and its transmission \n5 \nowners to submit tariff revisions to address (or demonstrate how current tariff provisions already \n6 \naddress): 1) the application process, study procedures, and ongoing operational requirements \n7 \nassociated with transmission service on behalf of large loads; 2) transparency associated with the \n8 \ncosts of Network Upgrades necessary to provide transmission service to large loads; 3) new firm \n9 \nand non-firm transmission services for large loads co-located with generation, and for flexible \n10 \nlarge loads. Five of the regions (all but SPP) addressed an additional tariff reform need: 4) new \n11 \nresource interconnection service for generation serving electrically proximate large load or co-\n12 \nlocated load. My focus is this last item.  \n13 \nIV. \nPERMANENT LOAD-LIMITED GENERATOR INTERCONNECTION SERVICE  \n14 \nIV.A. Lack of a Permanent Load-Limited Generator \n15 \nInterconnection Service Option Would Work Against the \n16 \nPurpose of Non-Firm Transmission Service \n17 \nIn these show-cause orders, the Commission identifies the opportunity to achieve speed-to-power \n18 \nby offering a new type of accelerated interconnection for a new generator that is dedicated to \n19 \nproviding power to a large load, and is co-located with or electrically proximate to it. This Load-\n20 \nLimited Generator Interconnection Service (LLGIS) is premised on the generator’s commitment \n21 \nto limiting its output to match the consumption of the load it is supporting. The Commission \n22 \nfinds that “[w]here a generating facility’s output is matched to the demand of the electrically \n23 \nproximate large load or large co-located load or if the generating facility’s output is limited to \n24 \nensure no new injection, the impacts to the transmission system of interconnecting the generating \n25 \nfacility to serve that electrically proximate large load or large co-located load may be limited, \n26"},{"page":22,"startToken":5632,"endToken":6117,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 4 of 10 \nthereby potentially reducing the need for Network Upgrades, which can accelerate the generator \n1 \ninterconnection process.”2 I concur with the finding that this service achieves expedited \n2 \nconnection of new supply and new large loads. It also improves the cost-effectiveness of the \n3 \ninterconnection process by avoiding unneeded network upgrades associated with the \n4 \ninterconnection process for the new load-limited generation. This is true because a) no \n5 \ndeliverability is needed for injections from the generator to the broader grid, and b) the large load \n6 \nis presumably included in the model used for studying the new generation, thus limiting net \n7 \nflows on the broader grid.  \n8 \nHowever, these benefits of LLGIS would be limited if it were structured only as an interim \n9 \nservice. While FERC has not categorically ruled out that this service is available both on an \n10 \ninterim and permanent basis (and indeed embraces a permanent approach in the case of co-\n11 \nlocated supporting generation taking LLGIS), FERC may expect that service to be mostly \n12 \ninterim in the case of electrically proximate generation taking LLGIS.3 The issues with interim-\n13 \nonly LLGIS would be two-fold.  \n14 \nFirst, if a developer taking LLGIS is obligated to obtain network resource interconnection \n15 \nservice (NRIS) or energy resource interconnection service (ERIS) later, it will be obligated to \n16 \npay the interconnection costs associated with that NRIS or ERIS. However, this obligation \n17 \nintroduces a sequencing problem because of the accelerated timeline made possible by the \n18 \nsimplified LLGIS process, such as the 90-day timeline for SPP’s High Impact Large Load \n19 \nGeneration Assessment (HILLGA) process. Specifically, the potentially high cost of the \n20 \nobligatory NRIS or ERIS network upgrades is unlikely to be known at the time that LLGIS is \n21 \n \n2  \nPJM Interconnection L.L.C., et al., 195 FERC ¶ 61,211 (2026) at P 95 (internal citations omitted) (PJM Show-\nCause Order).  \n3  \nPJM Show-Cause Order at P 97 (“To the extent that the interconnection customer’s generating facility is \nserving an electrically proximate large load, we believe that the generator interconnection service should be of \nan interim nature until the interconnection customer obtains Energy Resource Interconnection Service (ERIS) or \nNetwork Resource Interconnection Service (NRIS). To the extent that the interconnection customer’s \ngenerating facility is serving a large co-located load, it may be reasonable for the generator interconnection \nservice to be permanent because there will be no injections onto the transmission system and therefore it does \nnot present operational or planning risks for reliability”); Midcontinent Independent System Operator, Inc.,195 \nFERC ¶ 61,212 at P 115 (2026); California Independent System Operator Corp., 195 FERC ¶ 61,214 at P 115 \n(2026); New York Independent System Operator, Inc., 195 FERC ¶ 61,216 at P 123 (2026); ISO New England \nInc., 195 FERC ¶ 61,215 at P 113 (2026)."},{"page":23,"startToken":6117,"endToken":6501,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 5 of 10 \ngranted and the developer must commit to building its generator. This is a substantial cost \n1 \nuncertainty that would likely materially reduce the commercial viability of LLGIS.  \n2 \nSecond, the network upgrades associated with mandatory NRIS or ERIS would be unnecessary \n3 \nand inefficient if the lower-cost LLGIS arrangement can reliably accommodate the load-limited \n4 \ngeneration and its associated load on a permanent basis, and if permanent non-firm service is \n5 \nacceptable to the customer. Indeed, if the load is taking permanent non-firm transmission service \n6 \n(such as Non-Firm Contract Demand Service) as enabled by the LLGIS generation, the \n7 \nrequirement for NRIS or ERIS is inconsistent with the large load’s permanent reliance on the \n8 \nload-limited generation. Therefore, offering LLGIS only as an interim service works against the \n9 \npurpose of non-firm transmission services for loads that rely on load-limited generation, and \n10 \nresults in construction of unnecessary transmission facilities, which is inefficient and \n11 \nunnecessarily costly.  \n12 \nTo avoid these inefficiencies, the LLGIS that an ISO/RTO proposes must include both interim \n13 \nand permanent options. \n14 \nIV.B. \nRequiring an Option for Permanent Load-Limited Generator \n15 \nInterconnection Service Improves Efficiency and Speed-to-\n16 \nPower without Impacting Grid Reliability \n17 \nEnsuring that regions provide a permanent LLGIS option will improve the efficiency and \n18 \nattractiveness of non-firm transmission service for co-located loads.  Doing so will remove a \n19 \nsubstantial and unnecessary risk for investment in new supply, yielding the benefits the \n20 \nCommission cited in supporting its determination in the show-cause orders.4 In fact, a scenario in \n21 \nwhich the Commission requires full deliverability (NRIS) or injection (ERIS) rights for load-\n22 \nlimited generators runs counter to the Commission’s own holding by not reflecting the \n23 \n \n4  \nPJM Show-Cause Order at P 96 (“As commenters in the ANOPR proceeding have recognized, the status quo \nmay result in inefficient and unnecessary development of infrastructure, which leads to unnecessarily higher \nNetwork Upgrade costs that may result in unjust and unreasonable rates. The Commission has already \ndetermined in the PJM Co-Location Order that without the new transmission services that reflect the operational \ndynamics of co-location arrangements, there could be unnecessary, costly, and inefficient Network Upgrades, \nincreasing Network Upgrade costs”)(internal citations omitted)."},{"page":24,"startToken":6501,"endToken":6873,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 6 of 10 \n“operational dynamics” of the paired arrangements, leading to “unnecessary, costly, and \n1 \ninefficient Network Upgrades.” Mandating that LLGIS service be temporary would require the \n2 \ngenerator to ultimately pay for the construction of network upgrades for permanent service, even \n3 \nthough the Commission has identified such upgrades as “inefficient.”5 \n4 \nWhen describing the potential for permanent LLGIS, the Commission distinguishes between \n5 \ngenerators supporting co-located large loads versus those supporting electrically proximate \n6 \nloads. In the case of co-located loads, the Commission finds that these arrangements do not \n7 \n“present operational or planning risks for reliability,” as there “will be no injections onto the \n8 \ntransmission system.”6 The Commission describes several arrangements that would fit under this \n9 \nframework while using a series of special protection schemes to limit injections on the broader \n10 \ngrid and thereby maintain reliability.7  \n11 \nThe co-location requirement for permanent LLGIS would disqualify many configurations that \n12 \npresent the same simplified reliability profile as co-located arrangements, but offer better \n13 \ncommercial viability because they avoid any commercial complexity associated with a shared \n14 \npoint of interconnection. FERC could substantially improve the commercial viability of LLGIS \n15 \n(expanding its benefits) without materially changing its reliability features by taking a slightly \n16 \nless restrictive approach to the locational eligibility for permanent service. To avoid \n17 \nunnecessarily narrowing eligibility for permanent LLGIS, it should include generators at \n18 \ninterconnection locations that are “electrically equivalent” to the load’s point of interconnection, \n19 \nrather than limiting it only to generators that are located behind the same point of interconnection \n20 \n \n5  \nPJM Show-Cause Order at P 96 (“As commenters in the ANOPR proceeding have recognized, the status quo \nmay result in inefficient and unnecessary development of infrastructure, which leads to unnecessarily higher \nNetwork Upgrade costs that may result in unjust and unreasonable rates. The Commission has already \ndetermined in the PJM Co-Location Order that without the new transmission services that reflect the operational \ndynamics of co-location arrangements, there could be unnecessary, costly, and inefficient Network Upgrades, \nincreasing Network Upgrade costs”)(internal citations omitted). \n6  \nPJM Show-Cause Order at P 97.  \n7  \nPJM Show-Cause Order at P 98."},{"page":25,"startToken":6873,"endToken":7451,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 7 of 10 \nas the load.8 Electrically equivalent interconnection points are defined to be functionally \n1 \nidentical for reliability purposes, as demonstrated by use of this concept in several ISO/RTOs \n2 \ntoday. Even a narrow electrical-equivalence test—such as same substation and same voltage \n3 \nlevel—would materially improve commercial workability by allowing the generation and load \n4 \nsites to be developed separately, without requiring shared property or a common physical POI. \n5 \nFor example, PJM applies the electrical equivalence concept in its generation replacement \n6 \nprocess, requiring an interconnection at either the same electrical bus or an “electrically \n7 \nequivalent bus” as the deactivating generating facility.9 Similarly, MISO’s process allows a \n8 \nreplacement generator to utilize a different point of interconnection when it meets test criteria \n9 \ndemonstrating that the new connection point is electrically equivalent to the original location.10 \n10 \nAs FERC recognized in it order approving the MISO process, these test criteria “limit potential \n11 \nimpacts to flow in the transmission system,” “will not cause new constraints in the contingency \n12 \nanalysis,” will “minimize impacts to flow and therefore other projects in the interconnection \n13 \nqueue,” all “without subjecting other projects to an unreasonable risk of causing network \n14 \nupgrades.”11  SPP similarly defines electrical equivalence as “a relationship between Points of \n15 \nInterconnection (POI) that are (1) at the same substation and nominal voltage level, (2) on the \n16 \nsame branch or on a collection of in series two-terminal branches and associated buses and \n17 \nfacilities, or (3) on the same radial branch and associated facilities.”12  \n18 \n \n8  \nThe Commission could broaden permanent LLGIS further to include electrically proximate arrangements. \nThese would not create further reliability issues as compared to temporary LLGIS. Given the inherent front-of-\nthe-meter structure of (non-co-located) proximate generation and load pairings, the grid operator would retain \nthe ability to manage the system in operations, including by curtailing individual load and/or generation as \nneeded to preserve reliability where intervening transmission facilities are impaired. In that respect, permanence \ndoes not remove the operational tools that grid operators already use to address transmission constraints or other \nsystem conditions on an interim basis. That said, electrically proximate arrangements may present some \nadditional considerations relative to co-located arrangements, because they rely on facilities between the load \nand generation rather than being located entirely behind a single point of interconnection. \n9  \nSee PJM Tariff Part VIII, Subpart J § 437(A)(4). \n10  FERC states that MISO considers a point of interconnection electrically equivalent to that of an existing \ngenerating facility when it will: “(1) interconnect at the same voltage level as the Existing Generating Facility \nunless that voltage level is not available by the commercial operation date; (2) not cause new constraints, as \ndemonstrated by a contingency analysis performed in accordance with the Generator Interconnection Business \nPractices Manual 015 (BPM); and (3) not change the power distribution factor (DFAX) by more than 5% on \nany branch unless it is a zero impedance element or a line of the shortest path without queued interconnection \nrequests from the existing point of interconnection to the new point of interconnection.” Midcontinent \nIndependent System Operator, Inc., 191 FERC ¶ 61,154 (2025); MISO Tariff Attachment X, Section 3.7.1(i)(a).  \n11  Midcontinent Independent System Operator, Inc., 191 FERC ¶ 61,154 (2025). \n12  SPP, Generator Interconnection (DSIS) Manual, Version 4.4 (March 31, 2026) at 7."},{"page":26,"startToken":7451,"endToken":7971,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 8 of 10 \nGenerators seeking replacement treatment and those requesting permanent LLGIS are similarly \n1 \nsituated with respect to the electrical-equivalence test. In generator replacement, the test asks \n2 \nwhether moving the point of injection from Point A to Point B materially changes transmission \n3 \nimpacts. For permanent LLGIS, it asks the same question about locating new generation at Point \n4 \nA (behind the load’s point of interconnection) or at Point B. In each case, the central planning \n5 \nquestion is whether the alternate generation connection point produces material grid impacts: \n6 \nnew constraints, materially different power flows, or harm to queued projects. Therefore, if the \n7 \ntest fails in either case, the generator must go through the standard interconnection queue \n8 \nprocess. With permanent LLGIS, electricity may flow across a short segment of public \n9 \ntransmission between the generator and load, but that fact alone does not establish the kinds of \n10 \nregional impacts addressed by the full interconnection queue.13 Rather, as with generator \n11 \nreplacement, the test of interest is whether the arrangement creates material grid impacts. \n12 \nMISO’s and SPP’s generator replacement tests for electrical equivalence reflect that impact-\n13 \nbased approach, and it can be applied with equal effectiveness to similarly-situated load-limited \n14 \ngenerators connecting close to their paired loads. \n15 \nExpanding permanent LLGIS eligibility to generators with paired loads at electrically equivalent \n16 \ninterconnection points will not, by definition, create incremental adverse reliability impacts. As \n17 \nin the case of the mandated temporary service,14 the tariff should set out the principles guiding \n18 \nthe need for operational net load reductions, including restatement of the authority grid operators \n19 \nhave to take actions necessary to maintain reliability when operational circumstances dictate. As \n20 \ncompared to co-located arrangements, electrically equivalent generation/load pairings may \n21 \n \n13  A separate point of interconnection for the resource taking LLGIS may require review of intervening-facility \noutages, protection coordination, stability, short-circuit impacts, and the response to a load trip. Those are \nlocalized issues suitable for targeted LLGIS studies and operating requirements—not grounds for studying the \ngenerator as though it had unrestricted ERIS or NRIS injection rights. Where the substation is newly built for \nthe load and generator, the transmission owner can design the topology, breakers, relays, telemetry, and controls \nto limit contingency impacts. Eligibility for permanent LLGIS could require that, following relevant \ncontingencies, the pair remain coupled, isolate together, or automatically reduce generation or load. Indeed, \nsimilar controls may also be required for a generator that is co-located behind the load’s point of \ninterconnection to prevent unintended injection following a load trip. \n14  PJM Show-Cause Order at P 97 (“we remain concerned that the Tariff may be unjust and unreasonable without \nany uniquely tailored interconnection study process and/or generator interconnection service to recognize the \nreduced transmission system impacts that may result from the interconnection of a generating facility where the \ninterconnection customer has committed, in an interconnection agreement, to limit the generating facility’s \noutput to match the hourly forecast of an electrically proximate large load or large co-located load.”)"},{"page":27,"startToken":7971,"endToken":8256,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 9 of 10 \nimprove reliability outcomes compared to the behind-the-meter frameworks that the Commission \n1 \nhas already required to be permanent, as a result of the improved metering, telemetry, \n2 \nscheduling, and control required of the various front-of-the-meter components of the paired \n3 \nLLGIS facilities. \n4 \nAccordingly, I recommend that the Commission require the broader locational eligibility for \n5 \npermanent LLGIS (to accommodate a larger set of commercially feasible arrangements to \n6 \nsupport faster connection of new load-limited supply) to include loads and generation at \n7 \nelectrically equivalent locations as an available option. \n8 \nIV.C. \nReliable and Resource-Neutral Load-Limited Generator \n9 \nInterconnection Service Must Include Studies of Storage \n10 \nCharging \n11 \nTo ensure LLGIS maintains resource and technology neutrality, the service must be accessible to \n12 \nstorage resources. Consistent with NRIS and ERIS today, the LLGIS application process will \n13 \ntherefore need to include study provisions associated with reliable energy withdrawals for \n14 \ncharging of a potential storage resource (analogous to the ESR-LA process for storage in SPP, \n15 \nwhich is included in the HILLGA process15). This study would need to be included in the LLGIS \n16 \ninterconnection process even if the storage resource does not reserve transmission service (i.e., \n17 \nbecause it is charging pursuant to the provision of a grid service).  \n18 \nThese charging studies—which reflect the dispatch capability of storage—are already conducted \n19 \nas part of the ISO/RTO generator interconnection processes for storage requesting NRIS and \n20 \nERIS. It is important that they be extended to storage requesting LLGIS. \n21 \n \n22 \n \n15  See e.g., SPP, Generator Interconnection (DSIS) Manual, Version 4.4 (March 31, 2026) at § 5."},{"page":28,"startToken":8256,"endToken":8310,"text":"Affidavit of Andrew Levitt \nDocket Nos. EL26-67-000 etc. | Page 10 of 10 \n \n1 \n \n2 \nAffidavit of Andrew Levitt  \n \nI, Andrew Levitt, do hereby swear that I have authored this Affidavit, and that the \nstatements contained therein are true and accurate to the best of my knowledge and belief.  \n \nAndrew Levitt  \n \n \nDate: July 20, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":1774,"startToken":0,"endToken":801},{"p":3,"at":1774,"title":"I. CONCISE STATEMENT OF ISSUES AND SPECIFICATION OF ERRORS","method":"printed heading","endPage":4,"endAt":1080,"startToken":801,"endToken":1003},{"p":4,"at":1080,"title":"II. ARGUMENT","method":"printed heading","endPage":4,"endAt":1095,"startToken":1003,"endToken":1005},{"p":4,"at":1095,"title":"A. The Commission’s Orders Seek to Address Urgent Problems Due to Large","method":"printed heading","endPage":12,"endAt":461,"startToken":1005,"endToken":3431},{"p":12,"at":461,"title":"B. Absent modification or clarification, the Commission’s Orders unreasonably","method":"printed heading","endPage":14,"endAt":1181,"startToken":3431,"endToken":4107},{"p":14,"at":1181,"title":"C. The Orders fail to require broad enough reforms to the generator","method":"printed heading","endPage":16,"endAt":1093,"startToken":4107,"endToken":4695},{"p":16,"at":1093,"title":"III. CONCLUSION","method":"printed heading","endPage":16,"endAt":1099,"startToken":4695,"endToken":4696},{"p":16,"at":1099,"title":"CONCLUSION","method":"printed heading","endPage":18,"endAt":0,"startToken":4696,"endToken":4755},{"p":18,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":19,"endAt":0,"startToken":4755,"endToken":4814},{"p":19,"at":0,"title":"ATTACHMENT A","method":"printed heading","endPage":20,"endAt":73,"startToken":4814,"endToken":4901},{"p":20,"at":73,"title":"I. QUALIFICATIONS","method":"printed heading","endPage":20,"endAt":1691,"startToken":4901,"endToken":5156},{"p":20,"at":1691,"title":"II. ASSIGNMENT","method":"printed heading","endPage":20,"endAt":2435,"startToken":5156,"endToken":5266},{"p":20,"at":2435,"title":"A. Mohan, Accelerating the Integration of New Co-located Generation and Loads, prepared for Bloom Energy","method":"printed heading","endPage":21,"endAt":182,"startToken":5266,"endToken":5315},{"p":21,"at":182,"title":"III. BACKGROUND","method":"printed heading","endPage":21,"endAt":188,"startToken":5315,"endToken":5316},{"p":21,"at":188,"title":"BACKGROUND","method":"printed heading","endPage":21,"endAt":1147,"startToken":5316,"endToken":5460},{"p":21,"at":1147,"title":"IV. PERMANENT LOAD-LIMITED GENERATOR INTERCONNECTION SERVICE","method":"printed heading","endPage":28,"endAt":334,"startToken":5460,"endToken":8310}]}