Meeting Summary - 02/27/2025 Senate Business & Commerce

▶️ - Texas Energy Fund Update - PUCT Chairman Thomas Gleeson

• There are currently 72 applications, with 17 advancing to due diligence, representing approximately 8,900 megawatts of new generation.
• A project by ENGIE was withdrawn due to lack of direct line of sight to necessary components, leading to its withdrawal.
• Staff plans to present an option at the next open meeting to backfill the lost megawatts, restoring the capacity closer to the original 9,700 megawatts.
• Three program rules from Senate Bill 2627 have been adopted, though work is ongoing on the backup power promise portion.
• Concerns were raised about the tight timelines for projects, specifically regarding the first disbursement deadline by December.
• Projects are expected to come online between 2026 and 2029, making current timelines challenging.
• Chairman Gleeson suggested flexibility with project timelines, as longer timelines may avoid worthwhile projects dropping out.

▶️ - Extra High Voltage Update - PUCT Chairman Thomas Gleeson

• ERCOT has provided two plans in response to House Bill 5066: one for existing 345kV model, another for upgrading to 765kV statewide.
• ERCOT conducted a study with two cost scenarios: $32.99 billion for 765kV and around $30 billion for 345kV, with specific costs for the Permian region.
• A workshop is scheduled to address uncertainties around the 765kV option, focusing on timeline, supply chain, and costs.
• Chairman Thomas Gleeson emphasized the importance of timely execution and efficiency regardless of the voltage chosen.
• A self-imposed deadline of May 1 is set for a decision, with defaulting to the 345kV if a consensus is not reached.
• Concerns were raised about the reliance on extrapolated cost estimates from MISO's experience for 765kV.
• The discussion highlighted the need for empirical scrutiny and public confidence in the decision-making process.
• TDUs can file for using 765kV if approved by the PUC; this situation arises from provisions around regional transmission plans.
• The committee discussed if the move to 765kV in the Permian would scale to other parts of the state.

▶️1 - SB6 King | et al.

• Senator King introduced SB6, addressing Texas's exponential electric load growth.
• The state's electric demand has significantly increased, requiring the grid to accommodate 50 gigawatts by 2030, up from 10 gigawatts previously estimated.
• Businesses, especially large data centers and AI facilities, are driving this surge in electricity demand.
• Concerns addressed include inaccurate load forecasting, the impact of large loads on the existing grid, and proper allocation of grid costs.
• Four main challenges were identified: lack of accurate load forecasting, large loads taking existing generators offline from the ERCOT market, insufficient load-shedding protocols during emergencies, and improper allocation of grid costs.
• Proposed solutions include improved criteria for large load interconnection processes, PUC approval for generators wanting to remove megawatts from the ERCOT market, and updated cost allocation methods.
• The proposal advocates transparency in load forecasting, enhancing grid reliability protections, ensuring residential outage protections, and improved cost allocation.
• A committee substitute is expected shortly.

▶️1 - Pablo Vegas, ERCOT, Invited Testimony

• The bill provides helpful direction for managing grid reliability today and in the future.
• Load forecasting is critical, and the bill enhances data quality for real-time and future planning.
• Expecting a significant increase in load in the next forecast cycle.
• The bill addresses reliability issues associated with large loads by defining three categories:
• First category involves large loads with backup generation used as demand response during scarcity.
• Second category offers a voluntary service program with compensation for participating in scarcity situations.
• Third category includes non-participating large loads expected to partake in load shed events to mitigate residential and small business impacts.
• The bill introduces a flexibility concept to better model grid risks and improve data accuracy.
• ERCOT supports the bill and offers input and assistance to the bill authors and committee.

▶️1 - Barksdale English, PUCT, Invited Testimony

• The bill presents both opportunities and challenges with respect to economic development and grid reliability.
• A key focus is balancing economic opportunities with reliable grid operations.
• Ensuring all transmission system users contribute to costs is emphasized.
• The PUC is required to establish planning standards for new large loads.
• Avoiding the loss of generation capacity when new large loads are added is critical.
• The bill aims to safeguard the power supply for Texans' health and safety.

▶️1 - Senator King to Barksdale English, PUCT - PUCT Resources and Responsibilities 

• Senator King discussed how the PUC has been assigned a significant amount of work since 2021 and has completed much of it, but still has tasks pending.
• Concerns were raised about the ability to complete tasks such as the four CP reevaluation in a timely manner.
• Barksdale English discussed whether additional resources are necessary to meet these demands.
• Assurance was given that the organizational capacity and expertise have increased over time.
• Confidence expressed in executing tasks effectively and expeditiously once approved by relevant authorities.
• Request for 7 new full-time employees at a cost of around $1,000,000 per year to ensure timely completion.

▶️1 - Senator Schwertner to Barksdale English, PUCT - Grid Reliability Concerns

• Senator Schwertner expressed concerns about grid reliability related to loss of generation and financial discussions between large companies and ratepayers.
• Barksdale English confirmed that currently the PUC cannot prevent contracts that might impact grid reliability by removing large megawatts.
• Legislation is needed for the PUC to manage the removal of large megawatts from the grid.
• The envisioned process involves assessing the balance between new load introductions and loss of capacity to ensure grid reliability.
• Consideration of the timing and geographic location of new generators is key to preventing negative impacts on system reliability.
• Provisions may require resources taken offline to be available for statewide service restoration.

▶️1 - Senator Schwertner to Pablo Vegas, ERCOT - Potential Load Loss from Contractual Obligations

• Senator Schwertner's discussion focused on the reliability and maintenance of grid operations as a primary obligation for ERCOT.
• Addressed potential loss of large megawatts from the grid due to contractual obligations.
• Pablo Vegas discussed a bill providing four pathways to effectively handle load loss situations.
• One approach involves situations where a load with backup generation can disconnect from the grid to serve its own load, allowing the grid to benefit from adjacent generation capacity.
• The bill includes provisions that allow ERCOT to require loads to use their own generators during scarcity periods.
• ERCOT has a mechanism called 'reliability must run analysis' to evaluate the impact of generation resource loss on local transmission systems.
• During peak periods, if generation loss poses an instability risk, mechanisms exist to require generation continuation or develop alternatives.
• The bill particularly considers data centers, allowing their backup generation to ensure full capacity service from adjacent generation.

▶️1 - Senator Schwertner to Barksdale English, PUCT - Minimum Transmission Charges and 4CP Methodology Reevaluation

• Senator Schwertner’s discussion on having a minimum transmission charge to address cost allocation related to large loads and new transmission.
• Requirement to reevaluate the 4CP methodology due to potential gaming of the system.
• Barksdale English discusses how the bill aims to ensure that large loads do not unfairly impact residential and small consumers.
• Exploration of balancing fixed versus variable costs in transmission charges.
• The Commission had already planned to examine this issue in the current calendar year.
• Suggestion to combine considerations into a comprehensive directive to study transmission costs holistically.
• Goal to achieve a nuanced understanding of minimum charges versus other cost methodologies like 4CP or 12CP.

▶️1 - Senator Schwertner King to Pablo Vegas, ERCOT - Invitation to Comment on Cost Allocation and Transmission Costs

• ERCOT focuses on the impact from a reliability perspective.
• Ensuring that protocols are efficient and cost-effective in achieving reliability goals.
• Cost allocation is considered a commission issue, typically managed under PUC's purview.
• PUC is recognized for balancing interests of various customer classes and sizes.

▶️1 - Senator Campbell to Pablo Vegas, ERCOT - Accuracy of Load Forecasts and Impact of Minimum Transmission Rate on Generation Incentive 

• Senator Campbell inquired about the reliability of the 2029 forecast asserting a load of 150 gigawatts and if the load profile from last year's forecast remains accurate.
• Preliminary data suggests that the future load could be significantly higher than the 150 gigawatts estimate for the 2030-2031 period.
• ERCOT is working on tightening forecasting methods, but they currently lack improved data to validate specific forecasts.
• Discussion included whether incentives exist for loads with backup power to contribute to grid reliability. 
• Currently, data centers primarily use their backup for their own reliability needs.
• The lack of participation in voluntary programs is noted.
• Many data centers focus on using backup power solely for self-reliance during demand response scenarios.
• Senator Campbell questioned if the minimum transmission rate acts as a disincentive for co-located generators. The answer suggests it depends on whether the load depends on the grid for service at times or not.
• Discussion about whether loads should pay for grid services, based on their reliance on the grid, to ensure fairness.

▶️1 - Senator King - Comment

• If a data center is completely islanded and not using the grid, they should not incur charges.
• If connected to the grid, even for backup purposes, they should share costs.

▶️1: Senator Zaffirini to Pablo Vegas, ERCOT - Concerns of Kill Switch Provision Impacts on Grid and Public Safety

• Senator Zaffirini asked about concerns regarding the impact of the kill switch provision on the grid and public safety.
• Mr. Vegas responded that the kill switch provision could be beneficial for the grid by allowing more large loads to be included in a load shed scenario, thereby providing flexibility for transmission operators.
• The provision aims to allocate the burden of load shedding more fairly across customer classes.
• Mr. Vegas acknowledged concerns but emphasized that if managed safely, the shared burden during such events is fair.

▶️1 - Senator King - Comment

• Some utilities currently have the capability to manually disconnect specific loads through physical means at substations.
• There is ongoing effort to implement remote disconnection technology to manage loads more precisely.
• The estimated cost to integrate this remote technology into a project is around $1.5 million.
• Despite the high cost, this is seen as reasonable when compared to overall project budgets of $500 million to $1 billion.
• Some utilities are already mandating the implementation of remote disconnection capabilities.
• There is a push for standardization across the grid to ensure ERCOT can efficiently manage critical situations.

▶️1 - Senator Blanco to Pablo Vegas, ERCOT - Elaboration on Kill Switch Utilization Scenarios

• Senator Blano’s discussion focused on the use of the 'kill switch' and its applications during emergency situations.
• Pablo Vegas discusses the kill switch is an action of last resort, not used during normal operations or typical weather events.
• Its use is considered when there is an energy emergency, specifically at EEA (Energy Emergency Alert) level three.
• The process involves shedding load from the grid to maintain stability.
• Transmission operators are notified quickly and must act within minutes in an emergency.
• The approach follows a protocol based on load size, with larger operators having a higher proportion of load to shed.
• This rapid response is essential to prevent unstable grid conditions.
• Overall, the situation requiring the kill switch is very rare and emergent in nature.

▶️1.1 - Panel 1 - Taylor Kilroy (TPPA), Julia Harvey (TEC) , Walt Baum (Powering Texans), and Dan DiOrio (Data Center Coalition)

▶️1.1 - Julia Harvey (TEC) Testimony SB6

• Julia Harvey testified on behalf of Texas Electric Cooperatives regarding SB6.
• Co-ops generally support the goals of SB six, emphasizing the need for accurate load forecast validation measures.
• Importance of building transmission suited to actual needs was highlighted.
• Stressed the need to protect residential end users from power cuts before large, non-critical loads during load shedding.
• Agreed with reevaluating transmission cost allocation due to potential cost shifting in current 4CP methodology.
• Mentioned that 4CP behaviors allow some loads to pay less while still benefiting from the system.
• Recognized reliability benefits but noted cost shifting as a consequence of the current system.
• Discussed solutions in SB6, including the minimum transmission charge and 4CP evaluation.
• Highlighted Sections 3 and 5 addressing load forecast and load shed issues. 

▶️1.1: Taylor Kilroy (TPPA) Testimony SB6

• Taylor Kilroy testified on behalf of the Texas Public Power Association regarding a Senate Bill 6. 
• TPPA represents 72 municipally owned utilities serving over 5 million Texans. 
• TPPA broadly supports the new planning requirements for large loads in the bill. 
• They also support the bill's goal to reassess the allocation of transmission costs.
• There is a recommendation to move away from the 4CP methodology, as advised by the ERCOT Independent Market Monitor since 2015.
• TPPA supports the concept of a minimum transmission charge but insists that more work is needed to avoid regulatory confusion.
• Changing transmission cost allocation could lead to numerous rate cases, posing an administrative burden on the PUC and transmission service providers.
• Further instructions are suggested to be included in the bill to guide PUC on implementing the new charge and adjusting utility rates.
• Senate Bill 6 aims for fair cost distribution, potentially benefiting end-use residential customers in terms of cost and reliability.
• TPPA believes the concerns raised can be addressed without altering the bill's original vision and intent.

▶️1.1 - Walt Baum (Powering Texans) Testimony SB6

• Walt Baum represents Powering Texans and discusses economic growth and grid reliability in Texas.
• Powering Texans is neutral on SB6 but agrees with many aspects of the bill.
• Believes interconnection requirements should be strengthened for better load forecasting.
• Supports data centers paying for grid services and using their backup generation.
• Calls for flexible load management and re-examination of TCOS allocation methods.
• Concerns regarding colocation with existing generators being subjected to different requirements.
• Believes backup generation should be considered in approval processes.
• Thinks stranded cost liability should apply both ways, with potential savings in transmission costs.

▶️1.1 - Dan DiOrio (Data Center Coalition) Testimony SB6

• Dan Diorio from the Data Center Coalition (DCC) testified on Senate Bill 6. 
• Expressing concerns about transmission level load shed and remote disconnect provisions without sufficient notification, which could impact public safety in Texas.
• Data centers are crucial for services like government, hospitals, and finance, requiring constant uptime; any interruption can have significant consequences.
• DCC suggests more stakeholder input from entities like ERCOT and PUC before deploying high-risk provisions.
• DCC supports using backup generation during critical times with proper notification but seeks relief from environmental regulations for exceeding air permits in emergency situations.
• Concerns include how backup generation is governed by regulations and the potential violation of these permits during emergencies.
• DCC seeks modifications to the bill to outline proper procedures and notifications for deploying backup generation.
• There is a need for flexibility in location of replacement generation, not restricted to the same zone, to better address generation needs such as those in the Permian Basin.
• Data centers commonly use diesel generators due to reliability and cost, but environmental limits on usage are a concern.
• Exploration of other backup technologies beyond diesel is ongoing, including natural gas and batteries.
• Senators acknowledged concerns about remote disconnect and the need for collaboration to optimize backup utilization while complying with regulations.
• Discussion on the bill's provisions related to transmission charges, interconnection costs, and the implications of colocating data centers next to power plants was raised.
• It was noted that colocating can avoid building new transmission but involves recognizing associated interconnection cost responsibilities.

▶️1.2 - Panel 2 - Lee Bratcher (Texas Blockchain Council), Mark Bell (AECT), Warren Lasher (TxOGA), Katie Coleman (TAM)

▶️1.2: Lee Bratcher (Texas Blockchain Council) Testimony SB6

• Supports Senate Bill 6 which aims to clear out the interconnection queue by removing phantom load.
• Advocates for more accurate visibility into load growth through added costs for load studies.
• Expressed concerns over uncertainty surrounding minimum transmission costs, which could slow investment.
• Supports empowering ERCOT to shed large loads during EEA three events.
• Unclear on whether the costs of disconnections will fall on loads, utilities, or be included in utilities' rate costs.
• Assumes ERCOT would have discretion over flexible loads that are already 90% curtailed before EEA one events.
• Expresses general support for the committee's efforts in SB 6 and a willingness to be a collaborative stakeholder.

▶️1.2 - Mark Bell (AECT) Testimony SB6

• Mark Bell testified on behalf of the Association of Electric Companies of Texas regarding SB6.
• AECT represents all segments of the electric industry, within and outside ERCOT.
• There is high interest from large load consumers wanting to connect to the ERCOT grid.
• Utilities have received numerous interconnection requests for the transmission system.
• AECT supports transparency and credibility in the load forecasting process.
• Emphasized the need to prioritize removing large loads from the grid before residential customers during an electric supply emergency.
• Supports serving large facilities at the transmission voltage level to avoid operational challenges.
• Endorsed the stakeholder process at the PUC and ERCOT for technical considerations.

▶️1.2 - Warren Lasher (TxOGA) Testimony SB6

• Warren Lasher represents the Texas Oil and Gas Association, the largest aggregate consumer of electricity on the Texas grid.
• TxOGA emphasizes the need for a reliable and cost-effective grid.
• Concerns are raised regarding the bill's establishment of a minimum transmission charge, preferring a holistic review of transmission cost allocation first.
• The bill should ensure the minimum transmission charge does not apply to legacy cogeneration facilities not included in utility forecasts.
• The minimum transmission charge should not discourage new customers from co-locating resources.
• Currently, the bill allows flexibility for the commission to set a threshold lower than 75 MW, which TxOGA believes could create uncertainty; they recommend setting 75 MW as the minimum.
• The disconnection language could pose operational and reliability risks for large industrial facilities.

▶️1.2 - Katie Coleman (TAM) Testimony SB6

• Katie Coleman from the Texas Association of Manufacturers mentioned the appreciation for efforts to find tailored solutions to identified problems.
• Three main areas of concern were highlighted for refinements in the bill:
1. Minimum Transmission Rate: Concerns about complicated implementation and suggestion to include it in the 4CP study for better handling.
2. Disconnect Device: Call for collaborative approach and slight language modification to better capture the role of firm load shed.
3. Backup Generation: Need for defining and bracketing backup generation to avoid impractical requirements.

▶️1.3 - Panel 3 - Michael McNamara (Lancium), Gideon Powell (Cholla Inc.), Sarah Axelrod (Crusoe), Bryn Baker (TEBA)

▶️1.3 - Michael McNamara (Lancium) Testimony SB6

• Michael McNamara is the CEO of Lancium, an energy infrastructure technology company involved in the Stargate project in Abilene.
• The Stargate project in Abilene is claimed to be the world's largest AI data center with 1.2 gigawatts under construction.
• There is a plan for a large on-site battery and co-located solar facility at Stargate.
• He stressed that transmission cost allocation should be borne by beneficiaries and highlighted the need to distinguish between new resources and co-location at existing assets.
• Lancium supports measures to identify and differentiate legitimate new electrical loads from "phantom loads" to improve planning and efficiency.
• McNamara mentioned concerns about potential market distortion from mandated generation deployment, particularly in relation to large loads with on-site resources during load shed events.
• Mr. McNamara discussed concerns regarding disconnect devices for large data centers, highlighting on-site generation and battery plans to support grid reliability.
• The Abilene data center project includes a 1,000 MW battery with 4,000 MWh capacity and natural gas backup to manage grid needs effectively.

▶️1.3 - Sarah Axelrod (Crusoe) Testimony SB6

• Sarah Axelrod leads Public Affairs for Crusoe, a vertically integrated AI infrastructure company.
• Crusoe’s approach involves locating data centers at sites of clean, low-cost, abundant energy, which brings investment and jobs to rural communities.
• Crusoe aims to avoid straining the grid by using an energy-first approach, including backup power generation and on-site power build-outs.
• Crusoe is involved in multiple Texas projects, contributing potential investments in tens of billions of dollars.
• Recent projects like Stargate have been highlighted, and data centers are being recognized for their critical role in national security and competitiveness.
• Crusoe advocates for a balanced approach to SB6 that incentivizes investment, ensures governance, and allows Texas to compete effectively.
• Proposes any regulations on large loads apply across all large load customers based on capacity, regardless of their interconnection type.

▶️1.3 - Gideon Powell (Cholla Inc.) Testimony SB6

• Gideon Powell, CEO of Cholla Inc., speaks from personal and professional perspectives.
• Advocates for flexible load as a significant change, aligning with the vision shared by many ERCOT members.
• Supports the initiatives outlined in Senate Bill 6.
• Proposes a voluntary new construct for large load interconnections to address current issues and reduce friction and costs for ratepayers.
• Emphasizes the potential benefits of inviting AI data centers and flexible loads into ERCOT's program.
• Compares urgency and importance of energy innovation to historical events, indicating a need for leadership in AI dominance.

▶️1.3 - Bryn Baker (TEBA) Testimony SB6

• Bryn Baker from the Texas Energy Buyers Alliance advocated for expanded transmission to meet energy needs and supported a minimum transmission fee on new loads receiving transmission level service.
• The testimony supported reassessing cost allocation for large loads connected post-2023.
• Emphasizing the willingness of new loads to contribute to grid costs.
• Implementation of an economic benefit test was discussed, highlighting the need to evaluate lifetime costs and benefits with a discount factor as would be done by a CFO.
• The importance of different voltage levels and grid enhancement through technologies like advanced conductors and software to reduce consumer costs and wiring needs was emphasized.
• Senator Keene emphasized the importance of submitting specific language for a substitute bill by a specified deadline to aid in effective legislative crafting.
• Discussion on flexible vs. less flexible loads, particularly concerning AI data centers, was highlighted, proposing stakeholder collaboration for mutually beneficial language.
• The role of AI and crypto industries in grid reliability was discussed, citing Bitcoin miners as a proven example of flexible load benefiting grid stakeholders.

▶️1.4 - Panel 4 - Bill Peacock, John Crowell (Switch Data Centers), and Pat Wood (HEN)

▶️1.4 - Bill Peacock Public Testimony SB6

• Bill Peacock testifies against SB 6, speaking on his own behalf.
• Peacock has 20 years of experience in ERCOT related policy development.
• He argues that SB6 continues the ineffective approach of addressing grid reliability issues caused by renewable energy over the past 15 years.
• Peacock believes wind and solar energy are pushing the grid toward unreliability and driving thermal generation out, resulting in increased costs and grid reliability challenges.
• Texas has attempted to solve these issues through significant market interventions: regulatory restrictions and raising electricity prices to stimulate investment in dispatchable generation.
• Peacock points out that consumer-funded thermal energy subsidies, totaling $53 billion, have not resolved the reliability problems.
• He suggests eliminating subsidies for both thermal and renewable energy, require wind and solar to pay their reliability costs, and remove market regulations to allow market forces to address the issues.

▶️1.4 - John Crowell (Switch Data Centers) Public Testimony SB6

• John Kroll represents Switch Data Centers which develops, owns, and operates large data centers throughout North America.
• Switch Data Centers currently has facilities in Houston and Austin, and is working on a major project in Texas Senate District 5.
• Customers of Switch Data Centers include Fortune 100 companies, banks, financial institutions, social media, and national security entities.
• Local clients in Austin include Dell Computers and the University of Texas, as well as Probabilities Electric Co-op.
• Focused on provisions related to large load shed and environmental impacts.

▶️1.4 - Pat Wood (HEN) Public Testimony - SB6

• Pat Wood, CEO of Hunt Energy Network, discussed the importance of on-site power solutions and dispersed on-site generation as critical for Texas.
• Emphasis on encouraging on-site power where possible and ensuring unfettered access to the ERCOT market for all on-site generators.
• Mentioned the importance of allowing on-site generators to be separately metered to fully participate in the market.
• Discussed the need for reforms related to the 4CP (Coincident Peak) method, considering alternate methods like monthly or seasonal peak assessments.
• Highlighted concerns that current transmission system fees do not adequately reflect reality and management practices could benefit from reform.
• Emphasized the necessity to establish new rules and regulatory frameworks swiftly due to changing energy demands and potential new large loads.
• Outlined the potential for legislating changes directly rather than deferring decisions to lengthy stakeholder processes.
• Discussed balancing the transmission cost allocation to be fair and linked to peak usage to appropriately assign costs.

▶️1.5 - Panel 5 - Benjamin Barkley (OPUC), Wade Chappell (Kings Branch Data), and Cyrus Reed (Sierra Club)

▶️1.5 - Benjamin Barkley (OPUC) Testimony SB6

• Benjamin Barkley, representing OPUC, served as a resource person available to answer questions.
• Discussion centered on whether Section 2 of SB6 would benefit small consumers and ratepayers.
• Benjamin Barkley believes the bill is favorable for small consumers and ratepayers.
• Clarification was suggested regarding the scope of Section 2, which pertains to small commercial and residential consumers.
• There was a mention of the minimum transmission charge, with some confusion around its intended meaning.

▶️1.5 - Wade Chappell (Kings Branch Data) Testimony SB6

• Wade Chappell represented Kings Branch Data, a data center development company based in Fort Worth.
• The company is focusing on developing a multibillion-dollar project targeting the AI market.
• Their model targets smaller AI clients rather than large hyperscalers.
• Kings Branch Data specializes in tailored services for emerging high-value AI clients.
• They aim to provide data center infrastructure at 100 megawatt increments.
• The company seeks to attract AI clients to Texas, facing competition from other states.
• Their first major project is in a smaller community, expected to add over $30 million annually in local taxes.
• Chappell emphasized the importance of regulatory frameworks for retaining smaller AI clients.
• He underscored the benefits for smaller communities from economic opportunities due to AI investments.

▶️1.5 - Cyrus Reed (Sierra Club) Public Testimony SB6

• Cyrus Reed emphasized the impact on residential consumers due to transmission costs.
• Concerns are raised about how transmission costs are determined, especially related to 4CP (Four Coincident Peak).
• Supports planning requirements and voluntary demand response services for large loads.
• Expresses concern about co-location and suggests better reporting on new loads' energy use, location, and backup power.
• Advocates for using new technologies like solar and storage, instead of mandating thermal dispatchable replacements.
• Recommends lowering reporting requirements to loads as small as 25 megawatts for improved transparency and planning.