EL26-71-000 · 2026-08-03 · DCR Transmission, L.L.C.

Motion to Hold Filing Obligation in Abeyance of DCR Transmission, L.L.C

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
California Independent System Operator 
Corporation  
Citizen S-Line Transmission LLC  
Citizens Sunrise Transmission LLC  
Citizens Sycamore-Penasquitos Transmission 
LLC  
City of Anaheim, California  
City of Azusa, California  
City of Banning, California  
City of Colton, California  
City of Pasadena, California  
City of Riverside, California 
DCR Transmission, L.L.C.  
DesertLink, LLC  
GridLiance West LLC  
Horizon West Transmission, LLC 
LS Power Grid California, LLC  
Morongo Transmission LLC  
Pacific Gas and Electric Company  
San Diego Gas & Electric Company  
Southern California Edison Company  
Startrans IO, L.L.C.  
SunZia Transmission, LLC  
Trans Bay Cable LLC  
Valley Electric Association, Inc.  
Viridon Path 15, LLC  
Western Area Power Administration 
 
) 
) 
) 
) 
Docket No. EL26-71-000 
MOTION TO HOLD FILING OBLIGATION IN ABEYANCE  
OF DCR TRANSMISSION, L.L.C. 
Pursuant to Rules 206, 212, and 213 of the Federal Energy Regulatory Commission’s 
(“FERC” or “Commission”) Rules of Practice and Procedure,1 DCR Transmission, L.L.C. 
(“DCRT”) respectfully submits this motion for abeyance of the above-captioned proceeding 
established by the Commission’s June 18, 2026, Order Instituting Proceeding Under Section 206 
 
118 C.F.R. §§ 385.206, 385.212, and 385.213 (2026).

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of the Federal Power Act (“FPA”) (the “OSC”).2  Consistent with the OSC and as explained herein, 
DCRT requests the Commission hold this proceeding, including the deadline for responding to the 
briefing questions, in abeyance for ninety (90) days, up to and including November 16, 2026, so 
that DCRT may fully respond to the issues raised in the OSC and submit any necessary filings 
with the Commission.  The deferral of DCRT’s deadline to respond to the OSC would allow DCRT 
to coordinate with the relevant stakeholders, including the California Independent System 
Operator Corporation (“CAISO”) and, as necessary, DCRT’s interconnecting utilities in Arizona 
(as explained below), to comprehensively analyze the issues identified by the Commission and 
prepare any necessary submissions to the Commission, including an FPA section 205 filing 
revising DCRT’s Transmission Owner (“TO”) Tariff.   
I. 
BACKGROUND  
DCRT is a Participating Transmission Owner (“PTO”) and thus a TO under the CAISO 
Open Access Transmission Tariff (“CAISO Tariff”).  DCRT owns and manages the 125-mile, 500 
kilovolt Ten West Link Transmission Line (“Ten West Link”), which runs from Arizona Public 
Service Company’s (“APS”) Delaney Substation to Southern California Edison’s (“SCE”) 
Colorado River Substation.  In 2015, DCRT won the CAISO’s competitive solicitation leading to 
the development of Ten West Link.  Ten West Link entered commercial operation in June 2024, 
and is currently one of the few interconnections between Arizona and southern California.  
Approximately 100 miles of Ten West Link are in Arizona.  
The entirety of Ten West Link, including the portion located in Arizona, is part of the 
CAISO Balancing Authority Area (“BAA”) and is subject to the CAISO’s operational control, 
with transmission-related service over the line provided under the CAISO Tariff and DCRT’s TO 
 
2 Cal. Independent Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (“OSC”).

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Tariff.  Therefore, Ten West Link is integrated into the CAISO transmission system, and, in fact, 
extends the CAISO footprint into the retail franchise territory of APS, a state-franchised utility 
that is not a PTO and that operates its own BAA and is regulated by the Arizona Corporation 
Commission.  This means a large load seeking transmission service from the Arizona portion of 
DCRT’s facility would sit within the retail service territory of a state-franchised utility, outside the 
CAISO BAA, while interconnecting to a facility that is part of the CAISO controlled grid.   
As the Commission understands, the OSC raises a wide range of issues for industry 
participants, especially transmission-only companies (“Transcos”) like DCRT.  Tariff provisions 
that presume a traditional franchised public utility model (e.g., a retail tariff, traditional native load 
customers, a retail regulator) do not properly apply to Transcos.  DCRT is a prototypical example: 
DCRT is not a Load Serving Entity (“LSE”), has no network customers, and every mile of its 
transmission facility is part of the CAISO controlled grid, even though most of its facilities are in 
Arizona, across a state boundary and within the retail franchise territory of APS.  APS is not fully 
integrated into the CAISO footprint.3   
DCRT’s differences from a traditional utility with a franchised service territory are a 
structural feature of DCRT’s Commission-approved role as a transmission-only PTO, not a defect 
in DCRT’s existing TO Tariff.  It does mean, however, that the potential tariff provisions DCRT 
develops in response to the OSC may not necessarily be adapted from the integrated-utility model; 
they must be drafted for the transmission-only context, and this distinction is what primarily drives 
DCRT’s requested abeyance.  DCRT’s TO Tariff revisions must not only address DCRT’s 
obligations under the CAISO framework but also interface with the retail framework of a state-
 
3 APS voluntarily participates in the CAISO-administered Western Energy Imbalance Market; that 
participation does not place APS’s transmission facilities under CAISO operational control.

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franchised utility in whose non-CAISO-controlled territory a large load sits.  DCRT must balance 
these obligations without displacing that utility’s franchise and without converting DCRT, or any 
other wholesale entity, into a retail supplier in Arizona. 
DCRT’s operational circumstances are equally distinct.  Ten West Link currently 
contributes significantly to the westbound delivery of Arizona resources to California load, and a 
large load withdrawing energy at or near the Arizona portion of the line would run counter to those 
prevailing flows.  DCRT’s network upgrade, cost-causation, and curtailment analyses that the OSC 
directs must provide for that configuration. 
II. 
MOTION FOR ABEYANCE 
A. 
The OSC Requires Substantial Coordination by Multiple Stakeholders and 
Time to Address DCRT’s Unique Circumstances 
DCRT understands the Commission is focusing on the integration of large loads into the 
bulk power system and the national and regional economies.  DCRT commends the Commission 
for focusing on this issue to promote the greater national interest.  DCRT believes that the 
interconnection and provision of transmission service to Eligible Customers on behalf of large 
loads in the CAISO region can be faster, more cost-effective, and ultimately better for transmission 
customers.  DCRT appreciates the Commission’s desire for prompt action and the invitation to be 
the “first wielder of the pen.”4    
In the OSC, the Commission states that it will consider requests for abeyances of up to 90 
days, which should “include both (1) a robust description of the content of a potential future filing 
under FPA section 205 and (2) a reasoned and specific explanation of when such a filing is 
 
4 OSC at LaCerte Concurrence, P 5.

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expected to be made.”5  DCRT is evaluating its TO Tariff and recognizes that it likely needs to 
make certain tariff amendments to respond to the OSC; however, DCRT needs additional time to 
ensure that any potential filing addresses the Commission’s concerns and objectives for large load 
interconnection.  DCRT therefore respectfully requests an abeyance until November 16, 2026, so 
that DCRT can conduct the process described above thoughtfully and thoroughly, yet with “all due 
deliberate haste,”6 to promote cost-effective economic growth in DCRT’s footprint.  Below, DCRT 
explains the process it must complete to prepare this filing and why the abeyance is needed. 
Consistent with the OSC’s objectives, DCRT will consult with the CAISO, other TOs, and 
relevant stakeholders, such as large load developers, to evaluate potential tariff revisions that 
address the OSC’s concerns.7  Moreover, DCRT may need to draft new tariff provisions and 
processes, including new pro forma contract(s), and incorporate study and application processes 
tailored to large loads interconnecting to the transmission system.8   
As a CAISO PTO, DCRT must ensure that its tariff proposal is consistent with and 
supportable by the CAISO.  The CAISO’s July 20, 2026 Informational Report describes a 
stakeholder process running through Board action on October 28, 2026, with CAISO Tariff 
amendments to be filed in November 2026.9  An abeyance for DCRT is warranted on the same 
schedule.  Coordination with other stakeholders, such as other TOs, other California Investor-
Owned Utilities, and other independent, non-load-serving transmission owners, will also likely be 
necessary.  This means that DCRT may not be able to finalize its large load procedures and tariff 
 
5 OSC at P 35. 
6 OSC at Swett Concurrence, P 8. 
7 OSC at P 37.  
8 OSC at P 56 (identifying the types of tariff revisions that may be necessary).  
9 Cal. Independent Sys. Operator Corp., Docket No. EL26-71-000, “California Independent System 
Operator Corporation Informational Report,” at 15 (filed July 20, 2026) (“CAISO Informational Report”).

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revisions until the CAISO has completed its process, and DCRT may need to coordinate with other 
CAISO stakeholders to finalize its filing.   
When developing these tariffs and processes, DCRT will also need to evaluate state-
jurisdictional retail load tariffs, agreements, rates, and processes.10  In addition to CAISO-specific 
issues, DCRT must consider the inter-relationship of the CAISO and APS transmission systems 
when evaluating large load interconnections.11  DCRT supports the OSC’s concern for speedy 
filing of proposed additional or revised tariff provisions related to, among other things, study 
processes to service large load,12 as reiterated in two concurrences, but DCRT must ensure that its 
coordinated processes and procedures reflect the unique regional characteristics of the CAISO and 
APS systems, as recognized in the OSC and in Chairman Swett’s concurrence.13  
Clear and consistent provisions between the CAISO, CAISO stakeholders, DCRT, and 
likely APS serve regulatory and process certainty, fairness, and efficiency for large loads and 
transmission customers alike, and the Commission has stated that it expects the CAISO and the 
PTOs to coordinate with each other, as appropriate, in developing their responses to the OSC.14  
DCRT will participate in that coordination in good faith, and it expects that much of the resulting 
framework can, and should, be common across the CAISO network.  At the same time, the 
Commission chose to proceed through individualized show cause orders rather than a generic 
rulemaking, an approach that, as Chairman Swett explained, allows solutions “tailored to the 
 
10  OSC at P 41 (recognizing that “that resolution of issues related to large load additions will require the 
involvement of both federal and state actors, including the Commission, state public utility commissions, 
and other state and local entities”). 
11 References in this motion to prospective coordination or consultation do not represent the views or 
commitments of the CAISO, APS, the Arizona Corporation Commission, or any other entity. 
12 OSC at P 35; OSC at Swett Concurrence, P 5; OSC at LaCerte Concurrence, PP 5-6. 
13 OSC at P 35; OSC at Swett Concurrence, P 6. 
14 OSC at P 37.

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specific, varied circumstances” of each region rather than “a one-size-fits-all rule.”15  A uniform 
framework has real value only to the extent it can accommodate the diversity of circumstances 
across the CAISO network, including those of non-LSE transmission owners whose facilities cross 
retail franchise boundaries.  Accordingly, DCRT will work toward consistency between its tariff 
provisions and those of the CAISO and other PTOs wherever appropriate, and any section 205 
filing will propose provisions tailored to DCRT’s particular circumstances where a uniform 
approach does not accommodate them.   
Lastly, DCRT has been coordinating within the CAISO stakeholder process relating to its 
filing in response to the OSC, and DCRT is aware that certain other California TOs are submitting 
their own joint filing.  While DCRT reserves the right to join any joint filing by the other California 
TOs, DCRT is seeking its own abeyance for a final deadline of November 16, 2026 because of its 
unique status as a Transco in CAISO that also crosses state lines.  
III. 
PROPOSED TO TARIFF REVISIONS 
The following subsections describe the content DCRT anticipates proposing in its section 
205 filing to address each of the Commission’s preliminary findings.  The description provided in 
this section is intended to satisfy the OSC’s requirement of a robust description of a potential future 
filing; it is not intended to, and does not, prejudge the specific rates, terms, and conditions that 
DCRT will propose and support in the section 205 filing itself.   
A. 
Transmission Service to Eligible Customers on Behalf of Large Loads 
The OSC made a preliminary finding that the CAISO and/or TO Tariffs “appear to be 
unjust and unreasonable because they lack provisions that address, with sufficient clarity and 
consistency, how the CAISO and/or the Participating TOs will timely study . . . the provision of 
 
15 OSC at Swett Concurrence, PP 5-6.

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transmission service to Eligible Customers on behalf of large loads.”16  The OSC invites the 
CAISO and/or the TOs to revise their respective tariffs to outline “an application process, study 
procedures, and ongoing operational requirements that address the unique characteristics and 
challenges of providing transmission service to Eligible Customers on behalf of large loads.”17  
DCRT accepts this invitation. It will coordinate with the CAISO and the relevant stakeholders, as 
appropriate, and will submit responsive TO Tariff changes addressing these issues in its section 
205 filing.  DCRT will define “Large Load” when developing potential tariff revisions; however, 
it is not clear to DCRT that a 50 MW threshold is appropriate.18   
DCRT’s proposed revisions will outline the transmission service application process, study 
procedures, and ongoing operational requirements that the OSC invites, as applied to requests for 
transmission service from DCRT’s facilities, and will provide for such service in a manner that 
preserves the existing westbound delivery capability of Ten West Link and the deliveries it 
currently supports.  These procedures will contemplate the CAISO’s ability to curtail customers 
(if necessary).19  DCRT expects that it will also need to evaluate the scope of affected systems for 
CAISO non-adjacent utilities. 
As the Commission is aware, in CAISO, the TOs are responsible for interconnecting loads 
while the CAISO has operational control of most transmission assets.20  Thus, a high degree of 
coordination between TOs and the CAISO is required for many of the tariff revisions or additions 
directed by the OSC.  To address the concerns that the Commission has identified for transmission 
 
16 OSC at Section P 38. 
17 OSC at P 40.  
18 OSC at P 57; see also OSC at P 113 (referencing a 50 MW threshold for large co-located loads).  
19  OSC at P 63 (addressing the potential need to curtail large loads). 
20  OSC at PP 21-27.

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service for large loads, DCRT will need time to coordinate with the CAISO about allocating 
responsibility for studying, and for providing, transmission service to Eligible Customers on behalf 
of large loads.  To draft the necessary tariff amendments and revisions, among other things, the 
CAISO, DCRT and other TOs must craft mutually compatible processes so all parties understand 
what information should be evaluated to ensure that operational risks of providing transmission 
service to Eligible Customers on behalf of large loads are mitigated.   
Further, because of this division of responsibility between the CAISO and TOs, DCRT 
must also coordinate with the CAISO in determining the information required for large-load 
interconnection requests.  This is regardless of whether the large load is willing and able to limit 
its energy withdrawal under specific system conditions.   
DCRT and/or the CAISO will also likely need to tailor the new tariff provisions and study 
process concerning large load interconnection to the operational needs of large loads.  DCRT must 
also align with the CAISO about tariff additions addressing ongoing operational requirements for 
transmission customers taking transmission service on behalf of large loads.21  Some provisions 
may best be included in the CAISO Tariff while others may best be included in the TO Tariffs.  
For example, the OSC identifies the potential need for the CAISO to monitor large loads for 
impacts of fast-ramping load that may affect the transmission system too quickly to be captured 
by conventional data acquisition systems.22  This may necessitate provisions requiring TOs to 
install, and the responsible Eligible Customer to pay for, new equipment to enable such 
monitoring.  DCRT will also need to discuss with developers what kinds of mechanisms will 
successfully deter speculative or duplicative requests for transmission service while allowing 
 
21 OSC at P 37 (recognizing the need for coordination among TOs, the CAISO, and other stakeholders). 
22 OSC at P 63.

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commercially viable projects to be promptly interconnected without excessive and unnecessary 
network upgrades.23   
DCRT also is evaluating procedures for the use of alternative transmission technologies 
(“ATTs”) and determining when ATTs should be used over traditional network upgrades.24  Thus, 
before drafting pro forma provisions addressing these and other issues identified in the OSC, 
DCRT will need time to carefully consider the issues, both internally and in discussion with 
external stakeholders, such as the CAISO and large-load developers, whose knowledge and input 
are critical.  Doing so will require careful engineering and cost-benefit analysis to ensure the 
process protects reliability while consistently identifying the best solution for customers in the 60–
90 day timeframe targeted in the OSC.25   
B. 
Cost Shifting Risk Among Transmission Customers 
The OSC  states that the CAISO and/or TO Tariffs may be unjust and unreasonable because 
of “the apparent lack of (1) transparency regarding the assignment of network upgrades, and their 
associated costs, that are needed to provide transmission service to Eligible Customers on behalf 
of large loads; and (2) a pro forma cost recovery agreement between CAISO, the relevant 
transmission owner, and the Eligible Customer taking transmission service on behalf of large loads 
that help ensure that Eligible Customers bear the risk and are ultimately responsible for costs 
incurred to provide transmission service, including the cost of Network Upgrades.”26  DCRT will 
also address these cost-shifting concerns with proposed TO Tariff changes in its section 205 filing.  
 
23 OSC at P 55.  
24 OSC at PP 60-61. 
25 OSC at P 62.  
26 OSC at P 65.

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Those revisions will address the transparency of network upgrade cost information and will 
provide a just and reasonable pro forma cost recovery agreement.   
With respect to transparency, DCRT, the CAISO, and other TOs will need to collaborate 
and assign responsibilities to enable the robust, accurate, and systematic provision of data on the 
CAISO’s website in a single location, and in an easily accessible format that is searchable and 
allows users to filter the data, regarding the cost for network upgrades needed to provide 
transmission service to Eligible Customers on behalf of large loads, as noted in the OSC.27  
The OSC has also identified an issue with the lack of a pro forma cost recovery agreement 
between the CAISO, the relevant TO, and the Eligible Customer taking transmission service on 
behalf of a large load, and invites tariff revisions to establish one.28  Such an agreement, by 
definition, requires alignment between the CAISO, TOs, and potentially other stakeholders both 
on the terms of the agreement and on whether the agreement needs to be included in one or both 
sets of tariffs.   
As stated above, DCRT is a single-asset Transco that crosses state lines; it must also 
consider federal-state jurisdictional cost-allocation issues when interconnecting large loads.  
DCRT must resolve the state-level issue of which entity will have the right to construct assets 
interconnecting with DCRT’s line when addressing required network upgrades and align with both 
California and Arizona regulatory regimes.  DCRT’s tariff provisions will address (and where 
appropriate, govern) the interface between its TO Tariff and the state-jurisdictional retail regimes 
of the franchise territories that its facility crosses, in a manner that preserves the retail franchises 
 
27 OSC at PP 66, 70. 
28 OSC at PP 34, 65.

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and retail regulatory authority of the affected states.  Drafting just and reasonable tariff provisions 
addressing these issues requires time to carefully analyze and balance all of these concerns.   
C. 
Co-Location Arrangements; Flexible Transmission Services; Electrically 
Proximate Large Load and Co-Located Load 
With respect to co-located loads, flexible loads, and large loads that are electrically 
proximate to new generation, the Commission has identified the following issues with respect to 
the CAISO Tariff, as opposed to the TO Tariffs.  First, the Commission noted that the CAISO 
Tariff appears to be unjust and unreasonable without “clear and consistent provisions addressing 
the rates, terms, and conditions that apply to co-location arrangements and for transmission 
services that reflect an Eligible Customer taking transmission service on behalf of Eligible Load 
that is willing and able to limit its energy withdrawals from the transmission system under certain 
conditions.”29  Second, the Commission found that the CAISO Tariff appears unjust and 
unreasonable because it does not include “transmission services that reflect Eligible Customers 
taking transmission service on behalf of flexible large loads that are willing and able to limit their 
use of the transmission system under certain conditions.”30  Third, the Commission found that the 
CAISO Tariff appears to be unjust and unreasonable because it does not contain provisions 
“allowing an interconnection customer to seek the generator interconnection service(s) that reflects 
the operational dynamics of serving either: (1) electrically proximate large load or; (2) a co-located 
load . . . that has a high peak load.”31   
 
29 OSC at P 85.   
30 OSC at P 104. 
31 OSC at P 113.

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While these three concerns are directed at the CAISO Tariff, they likely will have 
implications for the PTOs.32  As appropriate, DCRT will address these issues in its tariff 
revisions.33  For example, the CAISO’s tariff revisions regarding curtailment would require 
conforming changes to a TO Tariff. The CAISO’s revisions on BTMG may affect a TO’s 
associated interconnection processes in its tariff.  DCRT notes that it welcomes BTMG as an 
avenue that can improve interconnection times by reducing the impact of a new co-located load 
on the grid.  Further, DCRT will need to coordinate with the CAISO concerning electrically 
proximate large load or a co-located load that has a high peak load and evaluate whether the 
CAISO’s definitions of proximate and high-peak loads are acceptable to DCRT.  
DCRT understands that the CAISO plans to file its proposed tariff amendments in 
November 2026.34  DCRT’s TO Tariff will need to accommodate study processes for Eligible 
Customers taking any new flexible, co-located, or proximate transmission services the CAISO 
Tariff establishes.  DCRT cannot create new application processes and study processes for these 
new transmission services without knowing the characteristics of those services.  The roles, 
responsibilities, and processes to interconnect large loads taking new services will also depend on 
the revisions to existing services under the CAISO Tariff, such as generator interconnection and 
transmission planning.   
Here too, the division of responsibility, where the CAISO currently studies generation 
interconnection while the TOs study load interconnection, requires careful collaboration.  
Designing a new process for the interconnection of co-located load will therefore require allocation 
 
32 OSC at P 86. 
33 DCRT also anticipates addressing or explaining why the CAISO Tariff rather than the TO Tariff is the 
proper vehicle for, billing-determinant provisions concerning load with Behind-The-Meter Generation 
(“BTMG”). 
34 CAISO Informational Report at p. 15.

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of responsibilities between the CAISO and TOs, especially when considering the possibility of 
joint studies as suggested by Commissioner Rosner.35  The same applies when determining criteria 
for which loads may be jointly studied with electrically proximate generation and how to do so; 
and in determining clear and consistent provisions for the rates, terms, and conditions of service 
that apply to interconnection customers serving co-located load after they are interconnected.   
Based on the CAISO’s stakeholder process timeline, revisions to the CAISO Tariff will 
likely not be finalized until close to the requested November 16 filing deadline if the CAISO is 
granted an abeyance.  Under the timeline in the CAISO Informational Report, the CAISO Board 
is scheduled to act on October 28, 2026, with CAISO Tariff revisions filed thereafter in November 
2026.36  DCRT’s proposed November 16, 2026 filing will address each of the OSC’s directives 
that implicates DCRT’s TO Tariff, based on the CAISO proposal then before the Commission.  If 
the Commission’s ultimate action on the CAISO’s filing requires conforming changes to DCRT’s 
TO Tariff, DCRT will propose them promptly in the ordinary course under FPA section 205; no 
further extension of the abeyance is requested for that purpose.  
D. 
Briefing Questions 
The Commission also identifies several issues for further briefing.
37  DCRT requests that 
the deadline to respond to the briefing questions also be tolled for 90 days.
38  DCRT so requests 
because the briefing questions are inextricably linked with the issues to be addressed in DCRT’s 
forthcoming section 205 filing. 
 
35 OSC at Rosner Concurrence, PP 11-13.  
36 CAISO Informational Report at p. 15.  
37 OSC at Section IV. 
38 See OSC at P 35 (allowing a Participating Transmission Owner to request the Commission to “hold, for 
up to 90 days, all or certain aspects of this FPA section 206 proceeding in abeyance”).

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IV. 
CONCLUSION 
DCRT respectfully requests that the Commission grant this Motion for Abeyance and 
extend DCRT’s deadline to respond in full to the OSC to November 16, 2026, for the reasons 
described above.   
Respectfully submitted, 
 
 
 
 
Joseph C. Hall  
 
Joseph C. Hall 
Heather Harrison  
Shenghao Wang 
Kelly A. Cuthbertson 
Eversheds Sutherland (US) LLP 
700 Sixth Street, NW, Ste. 700 
Washington, DC 20001 
Tel: (202) 383-0915 
joehall@eversheds-sutherland.com 
heatherharrison@eversheds-sutherland.com 
shenghaowang@eversheds-sutherland.com 
kellycuthbertson@eversheds-sutherland.com 
Attorneys for DCR Transmission, L.L.C. 
     
 
 
 
Dated: August 3, 2026

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CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
Dated at Washington, D.C., this 3rd day of August 2026. 
 
Kelly A. Cuthbertson  
 
 
Kelly A. Cuthbertson  
Eversheds Sutherland (US) LLP 
700 Sixth Street, NW, Ste. 700 
Washington, DC 20001 
Phone: (202) 383-0246 
Email: kellycuthbertson@eversheds-sutherland.com