In a recent interview with APPA, Jim Robb, President and CEO of the North American Electric Reliability Corporation, details the actions that NERC is taking as it relates to large loads.
NERC is proactively taking steps to address potential reliability issues tied to large loads including the development of a large loads action plan.
In an episode of APPA’s Public Power Now podcast posted in late July, Robb said that data centers present three major issues “and I like to think of them in three different buckets,” he said.
There's the resource adequacy question, “which is where are we going to get the power and the fuel to support this new load? And that's something that we study. It obviously has implications in our long-term reliability assessment.”
Robb said that is “really something that the data center developers, the power generation developers, the utilities, and the regulators” need to figure out – “how to get power supply to the load.”
There is a second “very thorny bucket of issues, which are the terms and conditions under which these loads interconnect -- basically code for saying who's going to pay for what, what is going to be needed to get the load connected and who's going to pay for what part of it. That's really kind of up to FERC and the state regulators to sort out,” he said.
“And then there's this third issue where we're highly focused, which is the operating performance of the data center. How do we get that to not compromise and maybe even contribute to the reliability of the grid itself?”
NERC is “really focused in on the operational characteristics of the loads,” Robb noted.
The reason this is important is twofold. “One is the loads themselves that are contemplated and being developed right now are enormous. You frequently hear of data center campuses that have aspirations of growing to one to five to 10 -- I even heard one reference to one maybe getting up to 15 gigawatts of capacity,” he said.
“When you sit back and you think about a gigawatt being the load of a city the size of San Francisco, it kind of focuses the mind on how big these data centers can be.”
The second is data centers have also proven to be very sensitive to grid operating conditions, Robb said.
NERC in 2025 formed an executive advisory group consisting of C-suite executives from the power sector, from the data center sector, some of the trade associations “to really serve as a sounding board for us on kind of how we respond to our challenge…which is the operations of the grid,” he said.
“And the one thing that came clear in those conversations is everybody wants clarity of what do they need to be, how do they need to be able to perform? Second, they want consistency. They want it the same everywhere in the country, right? Because that allows them to scale their business models and processes. And third, they want it yesterday. So yesterday was obviously a little bit hard to deliver against, but we can deliver against clarity and we can deliver against consistency.”
So NERC decided that “we were going to really put our foot on the gas of how we respond to these efforts...when we formed this large load working group,” which consists of utility representatives, “but also engineers out of the data center community to really kind of tear apart these event reports and understand, okay, what do we really need to get in place so that these loads are contributing to reliability?”
NERC issued a Level 2 alert, which is basically a data gathering exercise.
“And we asked utilities around the country about their commissioning practices relative to large loads and hoped that we would see a lot of patterns and a lot of consistency in that, and we didn't. So that led us to say, okay, we need to step in,” Robb noted.
“In April, we issued two things really in kind of record time. The first was a reliability guideline from our technical committee that starts to lay out -- here are all the issues as we understand them that the industry needs to manage around these loads.”
Secondly, NERC issued a Level 3 alert. NERC has only issued three Level 3 alerts in its history. “The first was around winterization of power plants. The second was around inverter performance. And then this one on commissioning data centers.”
Robb noted that a Level 3 alert is not an enforceable standard, but a precursor to that. “It tells everybody, this is what we think you need to be doing and we expect you to be doing it and report back to us how you're implementing this…I think it kind of signals the seriousness and the pace with which we are moving.”
NERC has other efforts underway, which were referenced in a FERC order that FERC issued this summer.
“The first is we've started the process of developing criteria for registering the data center loads. And we don't go into this space lightly because we've never registered a load before. And by registration, I mean bringing them formally into the bulk power system reliability framework,” he said. “But given the scale of these loads and their behavior, we think that they need to have mandatory and observable operating commitments to the grid.”
That implies reliability standards “applying to them the same way they do to the balancing authorities, the reliability coordinators, the transmission owner and operators, and the generator owner operators,” he noted.
“We're working in parallel two fronts. One is to determine what the criteria should be for a load that needs to register. And then secondarily, the requirements for the utilities, the balancing authorities, the transmission owner operators, and the reliability coordinators to make sure that they are commissioned and integrated in a way that preserves reliability,” Robb said.
“We would probably normally do all this stuff sequentially over three or four years, and we're trying to get it all done this year and that's breaking some norms and making a lot of people, including us, uncomfortable. But it's really what is needed to rise to the occasion.”
NERC published its first pass at registration criteria earlier this year with a 45-day comment period.
“People raised a whole bunch of great issues around it and the issues that we're concerned about on registration are making sure that we get the lion's share of the load that creates the risk. And we don't want to cause people to have to register who don't cause problems. But it needs to be objective, right?”
In NERC’s first pass, “one of the things that was highlighted to us is that we might be bringing in a whole bunch of universities and their computing centers. Well, we don't really care about those -- those haven't been an issue. Some process manufacturing plants, chemical plants, pulp mills, we might have been pulling some of them in, inadvertently.”
The second thing “we have going on is we've agreed on a series of….foundational practices that need to be in place associated with integrating and commissioning these loads and we formed a drafting team. We have a very large advisory body around that drafting team,” he said.
In terms of recent developments since the interview, in September, NERC noted that its Large Loads Working Group has developed a draft Standard Authorization Request addressing disturbance performance for computational loads. Industry comments can be submitted through September 24.
Other topics discussed in the interview included, among other things, a wildfire action plan that NERC has filed with FERC and efforts by NERC to modernize its standards, processes, and procedures.
