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Subcommittee: material changes in use profile must be approved by APC; 'primary' removed
Summary
Subcommittee members agreed that changes to a data center's use profile — not just the 'primary' use — should require APC approval, debated 30‑ vs. 60‑day notice and whether software changes count as material.
The subcommittee agreed that any change in a data center's use profile — not only a change to the 'primary' use — should be subject to APC review and approval. Members removed the word 'primary' from the draft to avoid disputes over what qualifies as primary use.
Discussion focused on timing: some members favored 30 days notice before implementation; others worried the APC's internal review could need more time. The group also debated whether software or configuration changes (not just physical server counts) could constitute a material change that requires review. "Material changes in primary use profile shall, shall be subject to approval from APC," one committee speaker read from the draft during discussion before the group recommended edits to broaden the coverage and clarify timing.
The subcommittee asked staff to draft clearer language that captures both hardware and software changes that meaningfully alter the function or customer base of a facility, and to propose a workable notice and review timeline.
