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Suggest revising 5.1 to the following: A WRAP-wide established load growth rate (or set of established growth rates) could potentially account for location, weather, Participant type, Participant customer composition (balance between retail, commercial, and industrial). The established growth rate is currently set at 1.1%. Changes to the established growth rate for the
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SRP requests clarification on which growth drivers are accounted for in the existing 1.1% growth rate. A 1.1% growth rate may be a reasonable proxy for current expectations but may quickly become outdated as expectations for growth increase along with the national trends of industrial onshoring and data center expansions; as seen this past year where growth forecasts doubled according to the National Load-Growth Report-2023 (gridstrategiesllc.com). Therefore, SRP suggests WRAP be actively updating the Load Growth Factor annually and SRP recommends incorporating a mechanism to adjust the growth rate regularly, to include more localized and current data. Underestimating load growth reduces the requirements for participants and may cap the amount participants are required to share at a level below what is needed for adequacy. In addition, SRP suggests eliminating “could potentially” from the sentence “A WRAP-wide established growth rate (or set of established growth rates) could potentially account for location, whether Participant type, Participant customer composition (balance between retail, commercial, and industrial)” and replacing it with “may.”
By way of example, the 2023 Western Assessment of Resource Adequacy report conducted by WECC projects a 1.64% compound average annual growth rate for WECC peak demand growth and 1.74% compound average annual energy growth from 2024-2033, based on SRP’s calculation of a 9-year anticipated growth rate from values provided by the report (wecc.org). These figures reflect the latest load forecasts provided to WECC by regional load serving entities. Referencing this WECC report or a published analysis with similar expectations for annual updates may provide opportunities for updating growth rates to prudently meet anticipated reliability needs.
The 2023 Western Assessment of Resource Adequacy also provides load growth rates at a sub-regional level, which could be mapped to WRAP participants to better reflect expected growth within the WRAP footprint.

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