Example #1: Interconnection & Demand Flexibility to Support Large Loads
The State Energy Office has been asked by the Governor’s staff to identify practical options to accelerate the interconnection of proposed data centers while maintaining system reliability. Transmission constraints and substation upgrade timelines are currently creating delays. The Director understands that demand flexibility, including curtailable load, managed charging, and on-site generation, may help reduce near-term upgrade needs. However, she lacks a clear view of how other states and utilities have structured these approaches, how they are reflected in interconnection studies, or what regulatory changes may be required.
Given limited staff capacity and the urgency of pending interconnection requests, she requests support from the National Labs. Within six weeks, she connects with a team of SMEs and over the next few weeks defines a focused statement of work for the following six months that includes the following:
- Assess the state’s current interconnection process, study assumptions, and queue backlog;
- Review recent large load studies to identify the specific technical constraints driving upgrade costs and delays;
- Evaluate where operational flexibility—such as interruptible service, ramp rate limits, minimum load commitments, or behind-the-meter storage—could reduce peak impacts or defer upgrades.
- Prepare a briefing paper summarizing leading practices regarding how flexible load commitments can be incorporated into interconnection studies, methods to quantify capacity relief from demand response, contractual mechanisms like non-compliance penalties, and coordination strategies during system events.
- Deliver a technical workshop for Commission staff, State Energy Office staff, and utility engineers with sessions covering example load profiles and scenario results comparing inflexible and flexible operations.
- Provide a concise options memo to guide decision-makers on next steps, whether through a technical conference, rulemaking, or pilot program.
Example #2: Cost Allocation & Cost Recovery Associated with Large Loads
A manager at the Public Utility Commission (PUC) has been tasked by one of her Commissioners to urgently analyze options for mitigating the significant financial risks posed to general ratepayers by the rapid interconnection of large-volume data centers. She is acutely aware that as these energy-intensive facilities join the grid, the costs for necessary infrastructure upgrades could disproportionately fall on residential and small commercial customers if not managed correctly. While she understands that strict cost allocation frameworks and dedicated large load tariffs are tools which are beginning to be used elsewhere, she lacks granular details regarding their specific design, legal defensibility, and implementation nuances.
Facing strict time constraints and the immediate pressure of a growing interconnection queue, she cannot conduct a comprehensive multi-state review herself. To address this, she applies for support from the National Labs. A little over a month later, she receives notification that her request is granted and immediately begins collaborating with a team of subject matter experts. Together, they define a statement of work covering the next five months designed to equip the PUC with actionable regulatory tools that includes the following elements:
- Prepare a detailed report on the latest industry practices regarding cost allocation and cost recovery focusing on how specific mechanisms—such as separate internal tracking and reporting of data-center induced transmission costs, portfolio-based cost allocation, contribution-in-aid-of-construction, or marginal cost pricing—can insulate non-data center customers from financial exposure.
- Develop and deliver two interactive training sessions for Commissioners and their staff that highlight real-world experiences and lessons learned from other states who have already navigated similar challenges.
- Lead a series of facilitated discussions with Commissioners and their staff to synthesize this knowledge and support efforts to develop a robust straw proposal for a new dedicated large load customer class, complete with essential tariff design elements like minimum bill provisions and contract term requirements to ensure long-term ratepayer protection.
Example #3: Leveraging Smart Inverters to Improve Distribution System Reliability
A manager at the PUC has been tasked to better understand how smart inverters can improve reliability via distribution system planning efforts and hosting capacity analyses. The state has seen a marked increase in the adoption of rooftop and community solar resources, at the same time the regulator has implemented a more robust integrated distribution system planning process. The resulting utility analysis suggests there are locations on the system where voltage reactive power (Volt-Var) controls in smart inverters could benefit the system by avoiding localized voltage problems and future capital investments.
Two weeks after submitting a request for support, a nationally recognized Lab expert in interconnection emails the PUC manager to clarify what assistance is needed, identify how the information will be subsequently used, and thus determine what content and material would be most beneficial to provide. Based on that interaction, the SME provides the following support over the next three months:
- Develop a presentation outline for the manager’s review and approval;
- Deliver the presentation to the manager and her Commissioners
- Facilitate a conversation between the manager and her Commissioners about how the state could consider altering its current processes to leverage this new standard.
Example #4: EV Charging Station Ownership & Operation Issues
A manager at the PUC is working with a counterpart at the state energy office to develop a policy on who can own and operate EV charging stations. He understands that this a complex issue with both short-term and long-term implications for competition, price, and service, but doesn’t have the background to fully understand the options and tradeoffs associated with different approaches.
About a week after submitting his request, a leading researcher on EV business models and utility regulation emails the manager to learn more about the policy that is under development and determine how she can best support the joint PUC and SEO effort. Based on that conversation, the SME agrees to do the following over the next two months:
- Deliver a memo highlighting the opportunities and challenges associated with allowing IOUs to own and operate charging stations; and
- Present the contents of the memo to a number of PUC Commissioners and SEO leaders and facilitate a discussion regarding what it might mean for this state’s policy.