Comments of Persistence Analytics Group LLC re Load Forecasting, Improved Software, and Assumption Verification under AD10-12.

Summary: Neil P. Osnato, Founder of Persistence Analytics Group LLC, supports the Commission's efforts to improve market and planning efficiency through software but emphasizes that software must be paired with rigorous verification of underlying assumptions. He argues that planners should distinguish between announced and durable load to prevent stranded infrastructure and distorted cost allocations.