Requesting Post-Conference Comment: Increasing Market and Planning Efficiency through Improved Software

David Luke Oates, representing MISO, supports the Commission's goal of improving market and planning efficiency through better software and forecasting for large loads like data centers. He outlines MISO's current efforts, including the use of AI for uncertainty management and collaborative data-sharing initiatives with stakeholders.

Gregory J. Poulos, Executive Director of Consumer Advocates of the PJM States, Inc. (CAPS), supports the action to improve load forecasting software to ensure accurate and verifiable data center load projections. He argues that accurate forecasting is critical to preventing over-investment in capacity, which currently leads to significant cost increases for consumers in the PJM region.

LineVision Inc., a grid-enhancing technology company, supports the conference's focus on using improved software to increase market and planning efficiency. They argue that Dynamic Line Ratings (DLR) are a critical, cost-effective tool for unlocking transmission capacity, improving grid reliability, and lowering costs for consumers.

John D. Wilson, Vice President of Grid Strategies LLC, provides testimony on improving large load forecasting practices. He advocates for the adoption of common metrics, project maturity assessment frameworks, and the creation of a shared national database to improve forecast accuracy and transparency.

Amazon Web Services (AWS) supports the use of cloud-based technologies and machine learning to improve load forecasting accuracy for data center growth and grid reliability. They argue that these technologies enable more efficient grid planning, protect ratepayers from speculative costs, and facilitate the integration of new energy resources.

Michael Craig of Great River Energy, a not-for-profit generation and transmission cooperative, shares his experience using grid enhancing technologies (GETs) to improve reliability and lower costs. He supports the exploration of these technologies but cautions that they must be implemented thoughtfully and only where they are economically justified.

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.

Neil P. Osnato, Founder of Persistence Analytics Group LLC and United Grid, supports the proposed action to improve market and planning efficiency through software. He argues that software should be used to distinguish between different types of load (e.g., announced vs. persistent), track evidence for assumptions, and identify the consequences of forecast failures to ensure more reliable infrastructure planning.

Daniel C Berkowitz, an individual, supports the Commission's inquiry into transmission technologies by advocating for the use of a stochastic Total Cost of Ownership (TCO) framework. He argues that this methodology better accounts for long-term benefits, uncertainties, and life-cycle costs of advanced conductors and Grid Enhancing Technologies compared to traditional first-cost analyses.