The North American Electric Reliability Corporation Large Load Working Group has published its second white paper, “Assessment of Gaps in Existing Practices, Requirements, and Reliability Standards for Emerging Large Loads.”
“As the North American electric system evolves, emerging large loads are challenging the reliability, resilience, and security of the North American bulk power system (BPS). These large load facilities are rapidly increasing in number, scale, and operational complexity, creating challenges under existing NERC Reliability Standards, interconnection practices, and system planning assumptions that were not designed to account for their unique characteristics,” NERC noted in posting the “Assessment of Gaps in Existing Practices, Requirements, and Reliability Standards for Emerging Large Loads” white paper.
To respond to this evolving landscape, NERC commissioned the Large Loads Working Group of NERC’s Reliability and Security Technical Committee (RSTC) to identify potential gaps related to large load integration in Reliability Standards, interconnection requirements, and Institute of Electrical and Electronics Engineers (IEEE) Standards, as well as in utility practices like load forecasting and load modeling practices.
This paper comes after previous work that outlined the characteristics of large loads and identified the reliability risks they may present to the BPS, NERC said this month.
NERC's Assessment of Gaps in Existing Practices, Requirements, and Reliability Standards for Emerging Large Loads evaluates gaps related to the following:
• Interconnection processes and requirements
• Planning and resource adequacy
• Balancing and operations
• Disturbance ride-through, stability, and power quality
• Security
• Resilience and event analysis
• Load modeling
Furthermore, this white paper categorizes the risks to the BPS related to large loads to determine the appropriate mitigations.
Overall, the white paper finds that the existing reliability standards and the existing processes and requirements related to BPS planning, operations, security, and other areas are inadequate to address the risks posed by emerging large loads that are forecasted to make up a significant portion of the future grid.
This inadequacy exists because the regulatory regime was established at a time when most significantly sized loads had different operating characteristics when compared to the data center or cryptocurrency mining and other emerging large loads currently seeking interconnection, NERC said.
“This paper serves as a foundational step in updating industry practices to address the challenges of integrating large loads into the evolving electric grid,” NERC said.
Alongside the Large Loads Task Force Characteristics and Risks of Emerging Large Loads white paper, it performs Step 1 of the RSTC Standard Authorization Request (SAR) Process.
The RSTC or others may consider developing SARs or other mitigating measures to mitigate the reliability gaps discussed in this paper, NERC said.
The following provides a summary of the LLWG recommendations based on the gaps assessed in the new white paper:
• Recommendation 1: There are multiple high-impact risks to the BPS from large loads that NERC registered entities cannot adequately address. The LLWG recommends that NERC pursue registration of a type of entity (or types of entities) that is able to perform specific functions to address the risks.
• Recommendation 2: The LLWG and other groups should propose SARs to address the unmitigated risks to the BPS related to emerging large loads.
• Recommendation 3: The LLWG should identify potential mitigations to risks posed by emerging large loads through improvements to existing planning and operations processes and interconnection procedures for large loads as planned for the LLWG’s work item titled Reliability Guideline: Risk Mitigation for Emerging Large Loads.
• Recommendation 4: Registered entities should coordinate and collaborate with large load entities and update their practices to address the gaps discussed in this paper.
• Recommendation 5: To address the gaps discussed in this paper, Transmission Owners (TO) should coordinate with other registered entities as applicable to update their interconnection requirements; Planning Coordinators (PC) and Transmission Planners (TP) should update their interconnection study processes.
• Recommendations 6-8: The NERC Load Modeling Working Group should work to address the applicable gaps identified in this paper. Additionally, the Security Working Group and the System Protection and Control Working Group should further assess applicable gaps and propose mitigations to address the gaps.
• Recommendations 9-10: Federal and/or state regulators, as applicable, should consider the gaps identified in this paper and coordinate with utilities to assess whether incorporating additional interconnection requirements and/or studies are appropriate to reliably support integration of large loads. State regulators should work with regulated utilities to review how new loads and planned additional generation impact existing planning and risk assessment frameworks. States may need to adjust their resource adequacy criteria and/or work with their utilities on energy infrastructure expansion.
• Recommendation 11: Policymakers should review interactions between interconnection requirements, existing state regulations and planning processes, and regional grid operator requirements. Additionally, policymakers should work to better understand the full impact of large load integration in their jurisdiction, and review requirements for large load customers to provide operational data and information to TOs, TOPs, TPs, and other entities.
