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Parties File Comments To Establish Large Load Forecasting Criteria
As background the Public Utilities Commission of Texas (PUCT) opened this rulemaking to develop the new 16 TAC §25.370 to implement PURA 37.0561 by establishing criteria for large load customers (LLCs) to be included in ERCOT load forecasts for transmission planning and resource adequacy (RA) models and reports.
In response, parties filed comments on proposal for publication of new forecasting rule for LLCs.
Parties filed comments on proposal for publication of new forecasting rule for LLCs. The proposed rule would define LLCs as single sites with aggregate loads of 10MW or more behind one or more common points of interconnection (POI) or service delivery points.
The proposed conditions for inclusion in ERCOT load forecasts are that the LLC must one of the following sets of conditions: (1) have executed and securitized an interconnection agreement; and (2) meet the following requirements:
- disclose to the transmission/distribution service provider (TDSP) whether it is pursuing a separate request for electric service, the approval of which would result in materially changing, delaying, or withdrawing the interconnection request, and, if so, the location, size, and anticipated timing of energization associated with such request;
- demonstrate site control for the proposed load location to the TDSP;
- pay a study fee to the TDSP of $100,000 or a greater amount set by the applicable PUCT rule;
- demonstrate financial commitment by payment of one of the following: (i) a $1 per MW security; (ii) contribution in aid of construction; and (iii) security provided under an agreement that requires the LLC to pay for significant equipment or services in advance of signing a delivery agreement;
- provide a load ramping schedule, if applicable; and
- submit attestations to the TDSP of significant progress toward pre-energization required: (i) site-related studies and engineering services; and (ii) obtaining all necessary permits and approvals.
- The rule would also include requirements for submission of load forecast data and ERCOT’s use of the data, as well as direction to ERCOT to develop compliance protocols.
Excerpts from Comments Re: Proposed 25MW threshold for LLCs:
Several parties including Texas Competitive Power Association (TCPA) and Data Center Coalition (DCC) argue that Staff’s proposed 25MW threshold for LLCs “would be too expansive and likely cover entities not intended to be covered by the Legislature” and that the threshold should be 75MW as SB6 directs, barring determination “that a lower threshold is necessary to accomplish the purposes,”
However, ERCOT supported the 25MW threshold, noting that ~16GW of “individual loads that each have a peak demand of [25MW – 75MW] already exist in the ERCOT region today, and 81 entities proposing another [4GW] of load within this range have initiated studies to interconnect to the ERCOT System in the near future.”
Proposed Requirement To Provide Location, Size, Anticipated Timing & Interconnected LLC:
AEP objected to “the proposed requirement to provide the location, size, and anticipated timing of energization associated with a separate request for electric service as part of the criteria for inclusion in the ERCOT Load Forecast as it could result in the disclosure of sensitive information”
Oncor argued that “[t]he criteria that a load that has not executed and securitized an interconnection agreement must meet to be included in ERCOT load forecasts are based on the large load interconnection standards that will be set by the Commission in Docket No. 58481,” recommending either copying the language from that rule once adopted or incorporating it by reference, and Staff recommended adding a condition requiring interconnected LLCs to “disclose to the interconnecting TSP information about the customer’s on-site backup generating facilities,” with the TSPs passing that information on to ERCOT.
Use of Independent Third-Party Load Forecasts & Increasing Study Fee Amount:
CenterPoint recommended allowing utilities to: (i) use independent, third-party load forecasts; and (ii) “to require additional engineering and design information from a large load customer. CenterPoint also ”recommended increasing “the study fee amount from $100,000 to $150,000,” to match “The estimate to perform the studies needed.”
View all comments at docket link below.
58480
(Rulemaking To Establish Large Load Forecasting Criteria PURA 37.0561)
