Comments of Persistence Analytics Group LLC/ United Grid related to the Commission-Led Technical Conference re PJM Governance and Stakeholder Reforms under AD26-7.

Summary: Persistence Analytics Group LLC / United Grid, an infrastructure risk analytics firm, supports the PJM governance and stakeholder reforms by advocating for a focus on evidence quality and load validation. They argue that governance reforms should include mechanisms to distinguish between different types of large-load demand (e.g., announced vs. durable) to ensure more accurate planning, cost allocation, and reliability assessments.