Institution of Section 206 Proceeding and Refund Effective Date: New York Independent System Operator, Inc., Central Hudson Gas and Electric Corp., Consolidated Edison Co. of New York, Inc., et al.

The Global Capacity Alliance (GCA), a nonprofit association, is requesting 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, an independent researcher and private citizen, submits technical comments regarding the integration of large loads and grid reliability. She proposes specific engineering standards for frequency-response absorption and coupling-discrimination to ensure that large-load costs are accurately assigned to the parties responsible rather than being socialized among ratepayers.

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