Request Summary
Program Consideration of Data Center Additions and Other Large Non-Conforming Loads
Co-sponsors
Description Of Issue
A significant amount of utilities’ anticipated load growth is attributed to large, non-conforming loads with high load factors such as data centers. WRAP modeling practices and policy may need to adapt as loads of this nature comprise a growing percentage of load within the program footprint. The WRAP will want to ensure it has considered this industry dynamic when establishing individual Participants’ Forward Showing capacity requirements. Furthermore, Participants and their regulators will be looking to WRAP to ensure Participants who bring these types of loads online earlier than other Participants, or Participants whose load profiles contain larger percentages of these types of loads are not shouldering an inequitable amount of capacity needed to support a 1-in-10 LOLE regional reliability metric.
Proposed Solution
Possible program changes could include:
-Participants with demonstrable significant loads which fit defined parameters may be allowed by the program to bifurcate these loads in their respective FS submittals, and these loads may have a separate PRM or associated capacity requirement. This separate PRM value or capacity requirement would reflect the non-weather-sensitive and high load factor attributes of this load while still supporting a 1-in-10 LOLE regional reliability metric.
-If loads of this nature are kept in the pool of existing program load, the program may adjust an individual Participant’s applicable PRM to reflect the proportion of these loads within a Participant’s P50 load forecast.
-If customer loads of this nature have curtailment provisions in their respective agreements with their local load-serving entity, some or all of the load may instead be treated as a DR program.
-Customer loads of this nature with behind-the-meter generation which can be called upon by the local utility in a reliability emergency (but cannot be injected into the grid), or, have curtailment provisions in their respective interconnection agreements may be considered “non-firm load” and thus excluded from the WRAP FS P50 load forecast. This would be similar to a Participant selling non-firm energy or capacity which can be recalled if needed to serve firm obligations.
Discussion and studies may arrive at different solutions not included in this list of possibilities.
Specific Document And Language
Suggested Language Update
Benefits
The WRAP devoting time and resources to study the effects of load growth associated with this category of customer has multiple potential benefits to Participants as well as the credibility of the program. The WRAP may conclude it can afford a lower capacity requirement associated with these loads without sacrificing regional reliability if a Participant can demonstrate the individual loads meet program-defined parameters.
Even if discussion and studies result in no change in program requirements to accommodate these types of loads, Participants will have public resources to reference in discussions with regulators as well as prospective customers who wish to connect this type of load.
Data Or Information
-The Western Electric Coordinating Council’s 2024 Assessment of Resource Adequacy is one of a number of public documents and statements from industry groups and utilities which highlight the amount of load growth associated with this category of customer.