Supplemental Comments of Persistence Analytics Group LLC in response to FERC’s Third Supplemental Notice of Commission-Led Technical Conference re PJM Governance and Stakeholder Reforms under AD26-7.

Summary: Neil P. Osnato, Founder of Persistence Analytics Group LLC / United Grid, supports the proposed PJM governance and stakeholder reforms but argues they must go beyond process mechanics to include rigorous verification of infrastructure assumptions. He advocates for independent verification of large-load growth, transparent cost-causation reviews, and stronger state access to decision-grade evidence to protect ratepayers.