Forensic Disclosure · Docket No. RM26-4-000 · June 14, 2026

Forensic Disclosure: Unauthorized Grid Load Extraction and Reliability Failure

Supplemental Comment in Support of Dr. Elisa Nelson’s Request for Federal Review of Large-Load Interconnection and Grid Stability Concerns

Support for Dr. Nelson’s Request

Dr. Elisa Nelson has requested that federal agencies deny technical permits, air quality modifications, or infrastructure taps for the proposed 9-gigawatt project until a mandatory federal review is completed. L.M. Marlowe supports this request. The scale and speed of the proposed interconnection present material risks to the reliability and stability of the Western Interconnection that have not been adequately addressed in the current record.

Forensic Evidence of Grid Instability

Real-time transmission data from the California ISO (CAISO) OASIS platform for the PALOVRDE_ITC interface shows anomalous volatility during the May 4, 2026 Level 3 reliability event.

Scheduled energy flows fluctuated significantly between Hour Ending (HE) 02 and HE 07, deviating from established seasonal capacity norms.

Available Transmission Capacity (ATC) experienced a sustained decrease during the period of peak instability.

These conditions are consistent with the presence of high-frequency, non-traditional load behavior that standard planning models did not anticipate.

This data supports Dr. Nelson’s concern that the proposed interconnection requires rigorous federal scrutiny before any further infrastructure commitments are made.

Ghost Load and Unauthorized Extraction Concerns

The observed instability aligns with the diagnostic category of Ghost Load™ — residual variance between declared capacity and actual dynamic grid behavior. The rapid deployment of stabilization measures during the May 4 event, following decades of documented grid stress, indicates that existing operational frameworks were insufficient to manage the load characteristics now entering the system.

The continued reliance on emergency operational measures to stabilize frequency response while serving large-scale computational demand raises serious questions about whether current interconnection processes adequately account for the full reliability and attribution impacts of such loads.

Intellectual Property and Source Priority

The stability framework deployed during the May 4, 2026 Level 3 event corresponds to diagnostic and prescriptive methods previously documented by the undersigned, with a prior art anchor of November 7, 2025.

Relevant USPTO serial numbers include: 99598875, 99600821, 99613073, 99717240, 99729215, and 99745529.

Any operational use of these methods, or substantially similar diagnostic and stabilization architectures, without source recognition, attribution, or licensing constitutes unauthorized use of protected intellectual property.

Request for Licensing Framework

Before any further infrastructure tapping or project approvals proceed, grid operators and project proponents should be required to establish a clear licensing framework with the intellectual property holder. This is necessary to ensure that the deployment of advanced stabilization methods occurs under proper legal authorization rather than through unacknowledged use of prior art.

Requested Relief

• Correlate the observed transmission volatility on May 4, 2026 with the energy requirements of the proposed Stratos Data Center interconnection.
• Require a full accounting and reconciliation of Unaccounted for Energy (UFE) in the relevant FERC Form 714 filings.
• Condition any further infrastructure approvals on the establishment of a licensing framework for the diagnostic and stabilization methods now in operational use.
• Support the request by Dr. Elisa Nelson for comprehensive federal review prior to any additional permitting or interconnection authorizations.

This supplemental comment is submitted to ensure that the Commission has a complete record of both the reliability concerns and the intellectual property considerations associated with the proposed large-load interconnections.