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

Summary: Neil P. Osnato of Persistence Analytics Group LLC supports the Commission's focus on improved software and grid-enhancing technologies to increase market efficiency. However, he argues that software must be paired with rigorous verification of underlying assumptions—specifically distinguishing between announced and durable load—to prevent the propagation of speculative data into grid planning.