Institution of Section 206 Proceeding and Refund Effective Date: California Independent System Operator Corp., Citizen S-Line Transmission LLC, Citizens Sunrise Transmission LLC, et al.

The Global Capacity Alliance (GCA), a nonprofit association, is requesting intervenor status to advocate for a "Front-of-the-Meter (FTM) Netting" framework. They argue that this framework allows large loads (like data centers) to privately mitigate curtailment risks through co-located resources, improving grid visibility and reliability without requiring ratepayer subsidies.

Lisa Melton, filing as L.M. Marlowe, is a private citizen and independent researcher who supports the proposed action by providing technical specifications for grid reliability and cost allocation. She argues for a rigorous evaluation of large-load integration based on physical stability, observability, and cost-causation standards.

Lisa Melton, 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 data.

Lisa Melton (L.M. Marlowe), an independent author and developer of a stability framework, supports the Commission's consideration of cost-allocation methodologies that assign reliability burdens to the specific loads that cause them. She argues that current structures unfairly socialize costs onto residential and small-commercial ratepayers and notes her proprietary interest in the diagnostic framework.