Request Summary
Program Consideration of Data Center Additions and Other Large Non-Conforming Loads
Co-sponsors
Description Of Issue
A substantial portion of projected utility load growth is driven by large, non-conforming, high-load-factor resources such as data centers. As these loads represent an increasing share of the WRAP footprint, existing modeling practices and policy frameworks may require adjustment. WRAP should explicitly incorporate this trend when establishing Forward Showing capacity obligations for Participants. Furthermore, WRAP must ensure that Participants introducing these loads earlier, or maintaining portfolios with higher concentrations of such resources, are not disproportionately burdened with capacity requirements necessary to achieve the regional 1-in-10 LOLE reliability standard.
Proposed Solution
Potential program adjustments could include:
-Separate treatment of large non-conforming loads. Participants with significant loads meeting defined criteria may be permitted to bifurcate these loads in Forward Showing submissions. These loads could require a distinct PRM or capacity requirement reflecting their non-weather-sensitive, high-load-factor characteristics while maintaining the 1-in-10 LOLE standard.
-Loads with curtailment provisions in their utility service agreements are not included in a Participant's Forward Showing.
-Locally resource-adequate loads are treated as demand response by the program, or not included in a Participant's Forward Showing.
Specific Document And Language
Suggested Language Update
Benefits
Studying the impact of load growth from this customer category offers multiple benefits for Participants and strengthens WRAP’s credibility. Analysis may show that lower capacity requirements for these loads are feasible without compromising the 1-in-10 LOLE standard, provided they meet program-defined criteria.
Even if no policy changes result, Participants will gain publicly available resources to support discussions with regulators and prospective customers considering these load types.
Data Or Information
Load service for this customer class is frequently highlighted in industry and traditional media. Industry assessments, including WECC’s resource adequacy reports, attribute a significant share of forecasted load growth to these customers.