EL26-68-000 · 2026-07-22 · Southwest Power Pool, Inc.

Answer of Southwest Power Pool, Inc. in opposition to Motion for the Establishment of Settlement Procedures and Convening of a Settlement Conference, or, in the Alternative, for the Appointment of a Settlement Judge of L.M. Marlowe

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
Southwest Power Pool, Inc. 
) 
Docket No. 
EL26-68-000 
) 
ANSWER OF  
SOUTHWEST POWER POOL, INC. 
Pursuant to Rules 213 of the Rules of Practice and Procedure of the Federal Energy 
Regulatory Commission (the “Commission” or “FERC”), 18 C.F.R. §§ 385.213, 
Southwest Power Pool, Inc. (“SPP”) submits this answer to the Motion for the 
Establishment of Settlement Procedures and Convening of a Settlement Conference, or, in 
the Alternative, for the Appointment of a Settlement Judge of L.M. Marlowe (“Movant”)1 
filed in this proceeding. The Commission should deny the Marlowe Motion as described 
below and allow SPP to move forward with responding to the Commission with regional 
solutions to the issues outlined in this docket.  
1
Motion for Establishment of Settlement Procedures and Convening of a Settlement 
Conference, or, in the Alternative, for the Appointment of a Settlement Judge of 
L.M. Marlowe, Docket No. EL26-68-000 (July 8, 2026) (“Marlowe Motion”). L.M.
Marlowe is also known as Lisa Melton.

2 
I.
BACKGROUND
On June 18, 2026, the Commission issued show cause orders to SPP2 and all other
regional transmission organizations and independent system operators (collectively “Show 
Cause Orders”).3 Each of the Show Cause Orders are tailored specifically to each of the six 
regional grid operators under the Commission’s jurisdiction. In the Show Cause Orders, 
the Commission directed each regional grid operator and its transmission owners to, within 
sixty (60) days, justify why their current tariffs remain just and reasonable in the absence 
of clear and consistent provisions for large load customers or, alternatively, to propose 
changes.4 Numerous entities have filed motions to intervene in the Show Cause Orders 
dockets.   
 In the Marlowe Motion, the Movant requests that the Commission: (1) establish 
settlement procedures and convene a settlement conference of the participants pursuant to 
Rule 601 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §§ 385.601; or 
in the alternative, and if the if the Commission finds settlement-judge procedures 
appropriate, appoint a settlement judge pursuant to Rule 603 of the Commission’s Rules 
of Practice and Procedure, 18 C.F.R. §§ 385.603, to facilitate settlement of the matters 
2
Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026) (“SPP Show Cause Order”). The 
Show Cause Order directed SPP to provide, within thirty days, a detailed 
informational report. 
3
See, PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026); N.Y. Indep. Sys. 
Operator, Inc., 195 FERC ¶ 61,216 (2026); Midcontinent Indep. Sys. Operator, 
Inc., 195 FERC ¶ 61,212 (2026); California Independent System Operator 
Corporation, 195 FERC ¶ 61,214 (2026); ISO New England Inc., 195 FERC ¶ 
61,215 (2026). 
4
SPP Show Cause Order at P 3.

3 
presented.5 The Movant claims, without justification or legal support, that the 
establishment of settlement proceedings in these dockets would allow the participants in 
these dockets of the Show Cause Orders the ability “to work toward mutually acceptable 
reliability, observability, and cost-allocation methodologies under the guidance of a 
neutral, rather than through protracted contested proceedings alone.”6  
Of note, through the Movant’s Marlowe Motion and other filings in the docket, the 
Movant’s interest in the proposed settlement procedures appears to be based, at least in 
part, on the Movant’s own commercial interests.7 As stated in the Marlow Motion, the 
“Movant is the author and rights-holder of a framework responsive to these questions, and 
seeks its consideration.”8 These commercial interests provide no basis to support a 
nationwide settlement proceeding. 
On July 15, 2026, the Southwest Power Pool Transmission Owner Group filed an 
answer in response to the Marlowe Motion.9 Although not responding to the SPP TO Group 
5
Marlow Motion at 1. 
6
Marlowe Motion at 1. 
7
See Marlowe Motion at 1; see also, Supplemental Technical Comment and 
Reservation of Rights of L.M. Marlowe at 1-2 (July 8, 2026) (“Commenter is an 
independent author and developer of a published, timestamped analytical 
framework addressing deterministic reliability invariants, real-time observability of 
computational load behavior, dependency mapping, and the allocation of reliability 
and capacity burdens created by large computational loads. Commenter’s published 
work — including the Architecture of Dependency and Autonomy™, the 
MARLOWE™ 
Invariant-Based 
Diagnostic 
Framework, 
Intent-Aware 
Telemetry™, Continuous Invariant Validation™, Execution Sovereignty™, and 
the associated Ghost Load™ dependency analysis — bears directly on the 
reliability and cost-causation questions presented in these dockets.”) 
8
Marlowe Motion at 2. 
9
Answer of the Southwest Power Pool Transmission Owner Group, EL26-68-000, 
et al. (July 15, 2026) (“SPP TO Group Answer”).

4 
Answer in this filing, SPP supports the SPP TO Group Answer in its request for the 
Commission to deny the Marlowe Motion as being premature and a profound disruption 
the Commission’s well-reasoned decision to address the challenge of large load additions 
on a regional basis through Show Cause Orders. 
II.
ANSWER
A.
The Motion Is Inconsistent with the Commission’s Regional Approach
As stated in the SPP Show Cause Order, the “[i]ndividual show cause proceedings 
will allow the Commission to ensure that solutions to the problems the Secretary [of the 
Department of Energy] identified are tailored to the specific, varied circumstances and 
market constructs of each region.”10 The Commission goes on to state that the Show Cause 
Orders “reveals the many ways in which those orders are customized for each market’s 
unique circumstances and progress (or lack thereof) towards serving large load…and 
“leave room for each market to tailor operational requirements for large loads that are 
particular to their region [] and otherwise account for incumbent regional differences on 
topics such as cost allocation and cost transparency, study processes, and network upgrade 
procedures..”11 The Commission found that “[p]roceeding via [the Show Cause Order] 
allow the markets (and their respective transmission owners) to explain, in the first 
instance, how to address the Commission’s concerns.” 12 
The Movant’s request for the establishment of a nationwide settlement procedures 
and convening of a settlement conference to facilitate resolution all of dockets the 
10
SPP Show Cause Order at P 6. 
11
Id. 
12
Id. at P 7.

5 
Commission issued Show Cause Orders would contravene the ability for each of the 
regional grid operators to appropriately respond to the Commission’s Show Cause Orders 
as it relates to the just and reasonableness of each entities regional open access transmission 
tariff. Because of the vast regional differences in such things as cost allocation, cost 
transparency, study processes, network upgrades, and market operations, it would be 
impossible to resolve all the issues presented by the Commission in the Show Cause Orders 
in a single settlement proceeding.  
Although Movant in the Marlowe Motion claims that the Commission’s 
establishment of a nationwide settlement proceeding would be timelier resolution than 
“protracted contested proceedings,”13 the Movant provides no justification to this claim. In 
reality, it would be impracticable, if not impossible, to effectively manage settlement 
proceedings involving the hundreds of parties that are expected to participate in the Show 
Cause Order proceedings. SPP and its stakeholders’ time is better spent working together 
on solutions to potential issues outlined in the SPP Show Cause Order rather than being 
required to participate in convoluted national settlement proceedings that will not result in 
solutions specific to the SPP region. 
There is simply no basis provided in the Marlowe Motion for the Commission to 
grant the Movant request. Although the Commission has the discretion whether to establish 
settlement procedures, hold a settlement conference, or appoint a settlement judge, nothing 
in the Commission’s rules requires that action.14 This is especially the case when the 
13
 Marlowe Motion at 2. 
14
18 C.F.R. § 385.601(a) (“The Commission…may convene a conference of the 
participants in a proceeding at any time for any purpose related to the conduct or

6 
settlement procedures would be detrimental to regional solutions the Commission desires 
from its findings in the Show Cause Orders. 
B.
The Motion is Premature
The Commission has only recently instituted these proceedings. Pursuant to the 
SPP Show Cause Order, SPP is currently evaluating the issues identified by the 
Commission and preparing its response. The Commission specifically afforded SPP the 
opportunity to utilize its stakeholder process to develop potential tariff revisions and, if 
appropriate, request additional time to do so. That process has not yet run its course. 
Because no proposed tariff revisions have been filed and no administrative record has been 
developed, there is presently no concrete controversy suitable for settlement. Settlement 
procedures are designed to facilitate resolution of identified disputes—not to substitute for 
the initial development of proposals that may ultimately become the subject of Commission 
review. Granting the Motion at this early stage would invert the ordinary sequence 
contemplated by Sections 205 and 206 of the FPA by requiring settlement discussions 
before parties have articulated the proposals that might ultimately require resolution. 
Finally, Although Rules 601 and 603 of the Commission’s Rules of Practices and 
Procedure authorize the Commission to convene settlement procedures or appoint a 
settlement judge, those rules are discretionary rather than mandatory. The Motion identifies 
no extraordinary circumstance warranting departure from the Commission's recently 
established procedural framework. General concerns regarding reliability and large load 
integration—issues that motivated issuance of the Show Cause Order itself—do not 
disposition of the proceeding, including submission and consideration of offers of 
settlement or the use of alternative dispute resolution procedures.”).

7 
establish that settlement is appropriate before the Commission has received the very 
responses it directed the regional transmission organizations to prepare. Moreover, to the 
extent the Motion seeks consideration of the movant's own technical framework, 
intellectual property, or proposed methodologies, those matters may be presented through 
the ordinary comment and stakeholder processes available in these proceedings. They do 
not provide a basis for compelling Commission-supervised settlement involving all 
participants. 
II.
CONCLUSION
SPP respectfully requests that the Commission accept this Answer and deny and
dismiss the Marlowe Motion. 
Respectfully submitted, 
/s/ Justin A. Hinton 
Justin A. Hinton 
Senior Attorney 
Meredith Powell 
Attorney 
Southwest Power Pool, Inc. 
201 Worthen Drive 
Little Rock, AR  72223-4936 
(501) 482-2468
jhinton@spp.org
Attorney for Southwest Power Pool, Inc. 
Dated:    __________
July 22, 2026

CERTIFICATE OF SERVICE 
I hereby certify that I have on this day served the foregoing document upon each 
person designated on the official service list compiled by the Secretary in this proceeding. 
Dated at Little Rock, Arkansas, this _________ day of July, 2026. 
/s/ Cassie Butler 
Cassie Butler 
Southwest Power Pool, Inc. 
201 Worthen Drive 
Little Rock, AR  72223-4936 
(501) 614-3200
22nd