NERC recently released a new Reliability Guideline on Risk Mitigation for Emerging Large Loads. Though non-binding, the Guideline responds to an urgent reality. Large loads are connecting to the Bulk Power System (BPS) faster than mandatory standards can keep pace. It provides forward-looking technical guidance for designing the BPS to accommodate large loads and bridges the gap until formal standards can catch up. Utilities and industry organizations are already working to develop the technical requirements needed to make these connections work reliably.
The stakes are high. Implementing the Guideline’s recommendations can strengthen system resilience, reduce the risk of outages and streamline interconnection processes. The Guideline also identifies where Reliability Standards may need to be updated in the future, while making clear that the Guideline is intended to supplement, rather than replace, any existing or new mandatory reliability standards.
At its core, the Guideline outlines NERC’s recommended practices, technical insights and lessons learned for maintaining BPS reliability as large loads are integrated. It also offers concrete mitigation strategies for risks identified in NERC’s prior large-load related white papers.
Calls for New Layers of Accountability
The Guideline recognizes that end-use facility owners and operators have not historically been active participants in BPS reliability processes. However, given the scale of today’s large loads and the reliability risks they introduce, NERC is now calling on large load users to actively participate in the development and implementation of practices and processes that maintain and enhance BPS reliability.
Appendix A of the Guideline outlines accountability across the full life cycle of large load deployment, covering eight key areas:
- Data Collection
- Interconnection
- Long-Term Planning
- Operations and Balancing
- Stability
- Power Quality
- Physical and Cyber-Security
- Resilience
Level 3 Alert
NERC has also issued a Level 3 Alert, its most serious, requiring utilities to formally respond to a series of questions about their large load interconnection policies and practices. Utilities are actively working through these responses which will shape NERC’s and policymakers’ next steps on large-load interconnection reform.
What This Means for Utilities
Large-loads are connecting to the grid at unprecedented speed and scale and existing processes weren’t designed for this moment. New frameworks will be needed to support system design and operation. Processes must be updated to address the reliability risks large loads introduce to the BPS.
TRC advises clients to carefully review the Large Load Reliability Guideline alongside their Level 3 Alert response obligations. Utilities should take stock of where their interconnection processes, procedures and plans stand today and where gaps may exist. TRC is ready to help. From system studies and project design to compliance with emerging and mandatory requirements, we bring the technical depth and regulatory insight to help utilities navigate this shift with confidence
Resources
NERC Report: Risk Mitigation for Emerging Large Loads Large Loads Working Group Reliability Guideline
NERC Report: Risk Mitigation for Emerging Large Loads Large Loads Working Group Reliability Guideline May 2026
NERC Alert: Essential Action to Industry – Computational Load Modeling, Studies, Instrumentation, Commissioning, Operations, Protection, and Control
May 2026
Power System Studies Practice Overview
September 2024
About TRC’s NERC Compliance Practice
TRC’s power system planning approach integrates regulatory requirements, industry standards and operational goals with practical, cost effective solutions. Our experience with public and private sector utility clients is a testament to our understanding of NERC compliance related aspects of your business. We apply advanced technology solutions to help clients navigate a rapidly evolving regulatory landscape with confidence. Our experts help you stay ahead of regulatory changes by designing programs aligned with financial, technical, scheduling and compliance goals. Our power system experts help you stay ahead of changing regulatory expectations because they stay engaged with the regulatory process and know how to plan, design and install programs that address your financial, technical and scheduling goals including compliance with changing NERC standards and Guidelines as well as industry “best practices” and the latest technology developments.
This regulatory update is a service to TRC’s utility clients, helping keep you informed of issues that increase your company’s compliance risks along with related topics regarding future regulatory developments to help you achieve your company’s business goals.
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NERC’s Large Load White Paper in 5 Minutes: Gaps, Findings, and Next Steps
May 12, 2026
NERC’s latest white paper identifies critical gaps in how the grid plans for, connects, and operates alongside large loads.
