Institution of Section 206 Proceeding and Refund Effective Date: AEP Oklahoma Transmission Co., Inc., AEP Southwestern Transmission Co., Inc., Deseret Generation and Transmission Co-operative, Inc., et al.

The Global Capacity Alliance (GCA), a nonprofit association, requests to intervene in the proceedings and urges the Commission to incorporate "Front-of-the-Meter (FTM) Netting" frameworks into RTO and ISO compliance strategies. They argue that this framework allows large loads (like data centers) to privately fund and manage their own capacity while maintaining grid visibility and reliability.

Lisa Melton, filing as L.M. Marlowe, is a private citizen and independent researcher who supports the Commission's Show Cause Orders by proposing specific technical standards for grid reliability. She argues for a "Frequency-Response Absorption Standard" and a "Coupling-Discrimination Protocol" to ensure that large-load integration is evaluated against physical stability and cost-causation requirements.

Lisa Melton (filing as L.M. Marlowe), an independent researcher and private citizen, supports the Commission's efforts to address reliability and cost-allocation issues regarding large computational loads. She proposes a specific "boundary-verification" framework to ensure grid stability and cost-causation without requiring access to proprietary internal facility data.

Lisa Melton (writing as L.M. Marlowe) is an independent author and developer of a diagnostic framework for electric load stability. She argues that the Commission should adopt cost-allocation methodologies that assign reliability and cost burdens to the specific large loads that cause them, rather than socializing those costs onto residential and small-commercial ratepayers.