Article 220 is all about load factors and that is essentially what this proposal addressees. We also talk about design issues throughout Article 210 with all of the required circuits so this is not unexplored territory. Backdooring these changes in the energy code only adds to confusion.
I agree natural gas and fossil fuel generation is now as big an issue in the PNW but that is not where most people live. With the exception of Niagara Falls, there is not a lot of hydro east of the Rockies. It is also very unlikely we will ever build another big dam. They are tearing out existing ones to restore natural river flow.
