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NERC Computational Load Updates

By Linda Walsh & Emily Starobin on May 12, 2026
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Proposed “Computational Load Entity” Criteria Posted for Comments

Since North American Electric Reliability Corporation (NERC) launched Project 2026-02 to address reliability risks from computational loads, as discussed in our previous post, NERC has continued to manage the concerns raised by the emerging presence of large loads on the Bulk‑Power System (BPS).

On April 1, 2026, NERC proposed to establish a new category of registered entity, “Computational Load Entity,” subject to Reliability Standards, to include large loads with a material impact on the BPS. Currently, this entity would include loads that are 20 MW and greater, connected at 60kV, and contain more than 1 MW of IT load. To add a new functional entity category, NERC must revise Appendices 2, 5A, and 5B of its Rules of Procedure. More information on the proposed criteria and revised rules is available here.

Comments on the proposed criteria may be submitted to ROPcomments@nerc.net no later than May 15, 2026.

Level 3 Essential Action Alert for Computational Loads Posted for Comments

On May 4, 2026, NERC issued a Level 3 Essential Action Alert to Industry concerning Computational Load Modeling, Studies, Instrumentation, Commissioning, Operations, Protection, and Control. This rare Level 3 Alert – only the third time in NERC’s 58-year history that a Level 3 Alert was issued – comes after reports of large load events across the Eastern Interconnection and Texas Interconnection resulting from unexpected disconnection of computational loads.

In this Alert, NERC identified seven essential actions that registered entities must do to address the immediate risks posed by computational loads interfacing with the BPS. These actions include:

  • Develop modeling requirements for computational loads;
  • Complete system studies and planning improvements;
  • Update definition of “qualified change”;
  • Establish a commissioning process for computational loads;
  • Implement protection and coordination enhancements;
  • Install dynamic fault recording devices; and
  • Create Interpersonal Communication capabilities.

Registered entities have until August 3, 2026 to submit comments via the NERC Alert System. 

Voluntary Reliability Guidelines Issued

To further address large loads, NERC has introduced new voluntary guidelines aimed at maintaining grid reliability. The Reliability Guideline: Risk Mitigation for Emerging Large Loads recommends specific practices for various categories of registered entities, including utilities, grid operators, equipment manufacturers, and others. Recommended actions cover areas such as data collection and monitoring; interconnection studies and processes; long-term planning and resource adequacy; and resilience, system restoration, and load shedding. Moreover, these Guidelines serve as a temporary reliability measure while NERC works to update its official Reliability Standards.

Action Items

Proposed Computational Load Entity Criteria. Registered entities may submit comments to ROPcomments@nerc.net by May 15, 2026.

Level 3 Alert. Registered entities may submit comments through the NERC Alert System by August 3, 2026.

Voluntary Reliability Guidelines. NERC urges all relevant entities to adopt the recommended, non-binding risk mitigation strategies outlined here.

Links

  • Proposed “Computational Load Entity” Criteria: https://www.nerc.com/who-we-are/rules-of-procedure/proposed-changes-to-rules-of-procedure
  • Level 3 Essential Action Alert: https://www.nerc.com/globalassets/programs/bpsa/alerts/level-3-computational-load-alert.pdf
  • Voluntary Reliability Guideline with Risk Mitigation Strategies: https://www.nerc.com/globalassets/our-work/guidelines/reliability/RG_Risk-Mitigation-For-Emerging-Large-Loads.pdf
Photo of Linda Walsh Linda Walsh

Linda focuses on regulatory issues affecting the electric utility industry.

Linda counsels and advocates for clients on a broad range of federal regulations covering electric utilities. Her experience representing utilities before FERC informs strategies for clients developing new business opportunities, handling compliance matters…

Linda focuses on regulatory issues affecting the electric utility industry.

Linda counsels and advocates for clients on a broad range of federal regulations covering electric utilities. Her experience representing utilities before FERC informs strategies for clients developing new business opportunities, handling compliance matters or faced with litigation.

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Photo of Emily Starobin Emily Starobin

Emily handles energy regulatory matters, focusing on renewable energy, environmental compliance, and navigating evolving regulations for clients in a changing industry.

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