NERC’s Large Load White Paper in 5 Minutes: Gaps, Findings, and Next Steps

In March 2026 NERC released its second white paper on large load interconnection, assessing gaps in existing practices and mandatory standards for preserving grid reliability.

NERC’s Assessment of Gaps in Existing Practices, Requirements and Reliability Standards for Emerging Large Loads evaluates gaps related to:

• Interconnection processes and requirements
• Planning and resource adequacy
• Balancing and operations
• Disturbance ride-through, stability and power quality
• Security
• Resilience and event analysis
• Load modeling

Key findings include:

• Current resource adequacy practices may not fully account for the complexities introduced by large loads.
• Traditional planning focuses on mid-to long-term timeframes, while some large loads can connect in the near term.
• NERC standards do not require large loads or LSEs to provide data, leaving real-time operators unaware of Bulk Power System (BPS) risks.
• The absence of defined voltage ride-through requirements leads to inconsistent responses to system disturbances.
• Large load modeling practices are insufficiently accurate, and commonly considered scenarios may not be conservative enough for frequency stability studies.
• No NERC standards prevent bad actors from accessing or controlling operational systems tied to large loads.

White Paper Recommendations

The white paper offers eleven recommendations directed at NERC committees, policymakers and utilities managing large load projects.

Recommendation 1: NERC should pursue registration of a new entity type capable of addressing high-impact risks to the BPS that current registered entities cannot adequately manage.

Recommendation 2: NERC’s Large Load Working Group(LLWG) and other groups should propose SARs to address unmitigated BPS risks emerging from large loads.

Recommendation 3: The LLWG should identify risk mitigations through improvements to planning, operations and interconnection procedures, as outlined in its forthcoming Reliability Guideline.

Recommendation 4: Utilities (Registered entities) should coordinate with large load entities and update their practices to address identified gaps.

Recommendation 5: Transmission Owners should update interconnection requirements, while Planning Coordinators and Transmission Planners should revise their interconnection study processes.

Recommendations 6-8: The Load Modeling Working Group, Security Working Group and System Protection and Control Working Group should each assess applicable gaps and propose mitigations.

Recommendations 9-10: Federal and state regulators should assess whether additional interconnection requirements are needed and work with utilities to evaluate how new loads and generation affect planning frameworks. States may need to adjust resource adequacy criteria or support energy infrastructure expansion.

Recommendation 11: Policymakers should review the interactions between interconnection requirements, state regulations and regional grid operator rules and assess data-sharing obligations for large load customers.