Change Request 2025-CRF-014

(This comment submitted on behalf of Brandon Oyer, Director, AMER Energy & Water, Infra. Perf Services)

Amazon Data Services, Inc. (ADS) appreciates the opportunity to submit this Change Request form for the Western Power Pool’s (WPP) Western Resource Adequacy Program (WRAP). Most of ADS' load in Oregon is included in WRAP through Bonneville Power Administration as the transmission provider and Load Responsible Entity. ADS requests WPP to amend WRAP BPM 103 – “Participate Forward Showing Capacity Requirements” to clarify that loads with sufficient backup generation can elect to exclude their load from the Load Responsible Entity’s load forecast. 

Background

ADS develops and operates data centers to support cloud computing services offered by its affiliate Amazon Web Services (AWS). AWS provides the world’s most comprehensive and broadly adopted cloud computing services, offering over 240 fully featured services from data centers globally. Amazon.com, Inc. (“Amazon”), AWS’ parent company, has invested in over 600 renewable energy projects across 28 countries, and met its goal to match 100% of the electricity consumed by its global operations with renewable energy in 2023. 

ADS has been constructing and operating data centers in eastern Oregon since 2011 to serve AWS and its customers. Since 2012, AWS has invested $30.5 billion in the state and supported 7,400 estimated average full-time equivalent jobs at local businesses annually in eastern Oregon. In 2023, AWS contributed significantly to the local economy through property taxes and fee payments amounting to $54.2 million. 

ADS supports WRAP and appreciates the importance of firm and reliable load and resource planning. Like WPP, ADS values highly reliable electric supply to critical loads. As a customer-obsessed organization, ADS is keenly focused on maintaining the highest reliability possible for AWS customers and their critical business functions. ADS’ commitment to reliability has resulted in substantial investments in backup generation for its many data centers in the Pacific Northwest. At present, these resources represent a significant amount of regional standby generation. These investments ensure reliable load service to ADS facilities even in the most extreme reliability events by allowing ADS to disconnect from the grid and use backup generation to maintain service.

Despite these generators providing resource adequacy, WRAP has not recognized their capacity in its planning framework. In a reliability event, this substantial set of resources stand ready to ensure service to the related load. A robust resource adequacy program should recognize these resources and their related loads to more accurately reflect the region’s resource adequacy status.

Change Request

WRAP BPM 103 currently provides that a Participant, or Load Responsible Entity, may seek to exclude loads from WRAP participation if the Participant is not the exclusive wholesale electricity provider for such loads. However, the designation is optional and the term “exclusive wholesale electricity provider” lacks a clear definition. In the face of these ambiguities, Load Responsible Entities, such as transmission providers, will set independent policies and requirements that result in disparate and changing requirements for load exclusion across the region. Even worse, many transmission providers may simply choose not to exclude any load.

The WPP should clarify WRAP to ensure that loads with dedicated backup generation, or energy storage systems, are entitled to load exclusion from the Load Responsible Entities. WRAP’s failure to adequately recognize backup generation could have negative consequences for years to come. If no resource adequacy is associated with backup generation, large regional loads will be disincentivized from investing in these types of onsite resources. In future reliability events, this lack of investment would result in more grid-reliant loads, unable to self-serve, and further widen the gap between loads and reliable regional generation.

ADS requests WPP to acknowledge backup generation as a significant existing regional resource. WPP should amend BPM 103 to clarify that loads with sufficient backup generation to serve their entire load have a right to load exclusion from their Load Responsible Entities. 

ADS requests that WPP update BPM 103 to clarify that entities with adequate backup generation or onsite energy storage dedicated to that load are entitled to load exclusion from their Load Responsible Entity. The impacted load should have the right to elect such load exclusion.

BPM 103, section 7.

BPM 103, Section 7 should be revised to read in its entirety:

As described in BPM 108 FS Submittal Process, a Participant will include all loads in its FS Demonstration for which it is responsible: i.e. all loads within the Western Interconnect (that are not participating in another resource adequacy program or represented by another WRAP LRE) for which the Participant has an obligation to forward procure capacity to meet any portion of the load or for which the Participant is the exclusive wholesale electricity provider to a load serving entity.

A Participant shall may seek to exclude any loads from WRAP participation that a) provide proof of sufficient on-site backup generation or onsite storage to reliably serve the load and b) request such load exclusion from WRAP participation. A Participant may also seek to exclude loads from WRAP participation at the Participant’s discretion to the extent the Participant is not the exclusive wholesale provider for such load. This is distinct from a Participant modifying its P50 Peak Load Forecast to account for additions and removal of load. As part of its FS Demonstration, the Participant will attest that the Participant is not the exclusive wholesale provider for the load (see Appendix B - Load Exclusion). As part of its FS Demonstration, the Participant will also provide documentation of notice to the end-use customer of the Participant’s intent to exclude the load from WRAP in the form provided on the WPP website and acknowledged via signature by a senior official of the end-use customer. Excluded load may not be included in the Operations Program. Excluded load must be separately metered, such that the excluded load may be removed from load forecasting information to be provided in the Operations Program, as further discussed in BPM 202 Participant Sharing Calculation Inputs, and from the Historical Load Data utilized in Section 4. Loads may not be partially excluded.

The proposed amendment will encourage future investment in backup generation on onsite storage while improving grid reliability by recognizing these significant regional resources. This change would allow WRAP to recognize the robust investment and planning in backup generation certain loads have made over the years. 

This change, and any subsequent elections by large loads to pursue load exclusion, would also materially alleviate the projected regional shortfall in WRAP eligible capacity and lend credibility to any projections of load and resource deficits by taking into account this sizable and reliable resource.