The rapid growth of data centers, cryptocurrency mining and other computational loads is creating new challenges for interconnection, system studies, modeling and reliability. NERC is responding with proposed registration requirements and new reliability standards for certain large computational loads. For utilities and organizations planning or supporting these connections, understanding these changes now can help inform upcoming projects, studies and compliance planning.
NERC Large Load Registration
NERC is proposing that certain large loads be registered and subject to mandatory reliability requirements. Its initial focus is on “Computational Loads,” including data centers and cryptocurrency mining operations, following significant system disturbances associated with operational behaviors of these types of loads.
Who Will Be Required to Register?
NERC proposes a 50 MW threshold, modified from the original 20 MW proposal, as the size of load for considering it as a “large load” because it captures majority of large load entities that pose identified risks to the Bulk Power System. The threshold encompasses those Computational Loads that have been shown to create problematic dynamic behaviors when connected at Bulk Power System voltage levels. Comments on the proposed computational load definition and registration criteria are due on September 18, 2026.
New Large Load Standards
On August 19, 2026, NERC initiated a comment period, for its three new proposed foundational reliability Standards in a new standards family – Computational Load Organization (CLO) which includes:
- CLO-001-1: Computational Load Interconnection, Studies & Modeling Data
- CLO-002-1: Computational Load Operational Data and Communications
- CLO-003-1: Computational Load Protection Coordination & Disturbance Monitoring
Now, two new registration entities are being proposed: Computational Load Owner (CLO) and Computational Load Operator (CLOP).
Additionally, NERC has identified needed modifications to FAC-001-5, Facility Interconnection Requirements and FAC-002-5, Facility Interconnection Studies needed to address the interconnection criteria and studies needed for connecting large new loads to the Bulk Electric System.
NERC has provided Technical Rationale for the requirements in all three of the new standards which is worth reviewing to understand the implications for various bulk power system functions and the organizations responsible.
Additionally, NERC has identified needed modifications to FAC-001-5, Facility Interconnection Requirements and FAC-002-5, Facility Interconnection Studies needed to address the interconnection criteria and studies needed for connecting large new loads to the Bulk Electric System.
NERC has provided Technical Rationale for the requirements in all three of the new standards which is worth reviewing to understand the implications for various bulk power system functions and the organizations responsible.
FERC Emphasis and Subsequent Timeline
To underline the importance of the NERC Large Load initiative, FERC issued an Order directing NERC to file the registration process changes and the large load foundational standards by December 31, 2026. NERC also has to file a plan of action for future large load standards by March 31, 2027.
For utilities and large-load stakeholders, this creates an important planning window. Now is the time to evaluate how proposed registration, modeling, operational and compliance requirements could affect upcoming transmission projects and existing processes.
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Next Steps: TRC Can Help
With the NERC activities well underway and now visible to the industry, the regulatory foundation for defining the means to achieve reliable service to large loads is moving ahead on an accelerated timeline. This regulatory activity is being undertaken to facilitate large load integration which is occurring faster than ever and at a scale never seen before. NERC considers these significant new processes and mandatory reliability rules essential for the reliable design and operation of the Bulk Power System.
TRC has the regulatory expertise to help your company implement new obligations under CLO-001-1, CLO-002-1, CLO-003-1 to consider the large new loads seeking to interconnect to the bulk power system. We can help your team navigate the evolving landscape, from system studies and project design to NERC compliance support. Our 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 your NERC compliance obligations as it relates to aspects of your business. We apply advanced technology solutions to help clients adapt to a rapidly evolving regulatory landscape with confidence.
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About TRC’s NERC Compliance Practice
The regulatory foundation for large load interconnection is being redefined and rebuilt quickly. Utilities must closely track NERC registration and standards developments as they unfold and assess how the changes affect their interconnection processes, system planning and compliance programs, particularly as mandatory NERC standards that address reliability risk related to large loads come into view.
TRC practitioners 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 with accurate planning and design. TRC helps you adopt programs that address your technical and scheduling goals and ensures compliance with changing NERC guidelines, as well as industry “best practices” and latest technology developments.
This regulatory update is a part of TRC’s commitment to keeping utility clients informed about developments and providing peace of mind.
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