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Register entry No. 0033Data releaseDocket No. RD26-7-000; 196 FERC ¶ 61,031

NERC petitions FERC to register 50-MW data centers, Docket No. RR27-1-000; comments due Nov. 20

The Oct. 21 petition would add Computational Load Owner and Operator to NERC's registry. The three CLO standards those entities would follow cleared NERC's board Oct. 26 but had not been noticed at FERC as of Nov. 6, ahead of a Dec. 31 deadline set in Docket RD26-7-000.

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Summary

NERC estimates that 68,288 megawatts of data center and other computational load, about 86 percent of what it projects for the end of 2027, would fall under a registration proposal it filed with the Federal Energy Regulatory Commission on October 21, 2026, according to two law firm analyses of the filing [12, 13]. The North American Electric Reliability Corporation’s petition, Docket No. RR27-1-000, seeks approval of revisions to its Rules of Procedure “Regarding Computational Load” and asks for expedited action; comments are due November 20 [2]. It answers part of a July 16 FERC order under Federal Power Act section 215 that set December 31 for both the registry changes and the first mandatory standards for such loads [1].

What the record shows

The FERC directive. The July order in Docket No. RD26-7-000 relies on section 215(d)(5), which lets the Commission order NERC to submit a standard “that addresses a specific matter,” and on section 215(f), which governs changes to NERC’s own rules [1, 6]. It directs NERC to file by December 31, 2026 one or more new or modified Reliability Standards addressing risks from integrating computational loads, along with Rules of Procedure changes “including registry criteria, necessary for registration of computational load entities” [1]. A workplan for a second phase of standards is due March 1, 2027 [1].

The Commission said it agreed with NERC “regarding the urgent need for action” and that it is “imperative” for NERC to act “with greater certainty than provided by voluntary timelines” [1]. The order lists five commissioners: Chairman Laura V. Swett and Commissioners David Rosner, Lindsay S. See, Judy W. Chang and David LaCerte [1].

The registration petition. FERC’s notice describes the October 21 filing as a “Petition of the North American Electric Reliability Corporation for Approval of Revisions to the NERC Rules of Procedure Regarding Computational Load and Request for Expedited Action,” Accession No. 20261021-5204 [2]. As the American Public Power Association and two law firms describe it, the petition creates two registered functions, the Computational Load Owner (CLO) and Computational Load Operator (CLOP) [10, 12, 13]. Registration would turn on a “Computational Load Site” with at least 50 MW of total connected load supplied through equipment connected to the Bulk-Power System at 100 kV or higher, from one or more points of connection [7, 12].

An ERCOT working-group briefing dated October 15 reproduces the site definition: buildings or installations that primarily contain information technology infrastructure used for software applications and services, “artificial intelligence training, deployment, and delivery,” “cryptocurrency mining,” or “other computational activities at a data center” [7]. Davis Wright Tremaine reports that the voltage test looks to the high side of the supplying transformer, which may differ from the interconnection point, and that the petition drops a stand-alone definition of “computational load” for registry purposes [13]. The thresholds rose during drafting. NERC’s first proposal used 20 MW and 60 kV, according to POWER [8].

The three standards. NERC Project 2026-02 produced CLO-001-1, CLO-002-1 and CLO-003-1, plus revisions to FAC-001-5 and FAC-002-5 so the interconnection standards do not duplicate the new ones [8]. The ERCOT briefing reports the final ballot results against the 66.67 percent needed to pass [7]:

Standard Subject Affirmative vote
CLO-001-1 Interconnection studies and modeling data 81.58%
CLO-002-1 Operational data and communications 77.93%
CLO-003-1 Protection coordination and disturbance monitoring 82.40%
FAC-001-5 / FAC-002-5 Conforming revisions 95.45% each

Under CLO-001-1, planners must study new computational loads with steady-state, short-circuit and dynamics studies, and modeling data must be updated at least every 13 months [7]. CLO-002-1 requires owners and operators to comply with operating instructions from transmission operators, balancing authorities and reliability coordinators [7]. POWER reports that an operator unable to comply must notify the issuing entity, and that NERC says the standard does not convert firm service to non-firm service [8]. CLO-003-1 requires sequence-of-events recording and puts fault and dynamic disturbance recording on whoever owns the main power transformer [7, 8].

NERC’s board adopted the three standards on October 26, according to APPA and Pillsbury [11, 12].

Where it sits in the process

Has NERC filed the data center standards with FERC yet?

Not as of FERC’s November 6 notice of electric reliability filings. That notice lists two NERC petitions filed November 2, Docket No. RD27-1-000 for FAC-011-5 and TOP-003-9 and Docket No. RD27-2-000 for TPL-001-6, with comments due December 2 [3]. Neither is the CLO package. Utility Dive reports that NERC said it will file the standards with FERC and coordinate with Canadian authorities [9].

Under section 215(d)(2), a standard “shall take effect upon approval by the Commission,” and FERC must find it just, reasonable, not unduly discriminatory and in the public interest [6]. Rule changes under section 215(f) take effect only after “notice and opportunity for comment” [6]. Pillsbury notes the standards and their implementation plans need FERC approval separately from the registry changes [12].

How long would data centers have to comply?

POWER’s account of the implementation plans, counted from each standard’s effective date [8]:

  • CLO-001-1: three months for planning coordinators to define qualified changes and data specifications; six months for transmission owners, distribution providers and generator owners to set interconnection requirements; nine months for the remaining obligations.
  • CLO-002-1: six months for operators’ data specifications; generally 12 months for load owners and operators.
  • CLO-003-1: 36 months for recording at existing sites; new sites have until 15 months after the effective date or their in-service date, whichever is later. Protection coordination starts at nine months.

A parallel comment window

FERC’s annual reliability technical conference on October 21, Docket No. AD26-8-000, opened with a panel on “Operational Challenges of Integrating Large Loads,” whose listed questions included whether lessons learned point to “validated dynamic load models” and “mandatory disturbance monitoring at points of interconnection” [4]. This site covered the September notice for that conference alongside DOE’s bulk-power equipment inquiry (earlier coverage). A notice scheduled for November 9 publication invites post-conference comments within 30 days of its November 3 date, which by this report’s count is December 3 [5].

What the record does not show

The package sets no industry-wide minimum voltage and frequency ride-through requirement, according to POWER, which reports separate work on that and three further Standard Authorization Requests [8]. The ERCOT briefing calls ride-through “a high-priority item” [7]. POWER also notes that CLO-002-1 does not list contractual limits on an operator’s control of tenant equipment as grounds for not following an instruction, a gap that may matter at multitenant sites [8].

The record cited here does not say how quickly FERC will act on the request for expedited treatment, or what effective date NERC proposes for the registry changes. It does not show how many sites or companies the 50 MW and 100 kV thresholds would capture, as opposed to megawatts.

Penalties are a further open point. Once standards are effective, registrants would face NERC audits and enforcement, including possible penalties under the Federal Power Act [12]. Pillsbury writes that contracts can allocate those responsibilities between owners, tenants and operators but cannot remove them [12].

Positions on the record

NERC’s own filings, as the July order quotes them, describe demand growth “higher than at any point in the last two decades” and “a need for quick and decisive action to address potential reliability impacts” [1]. In a March 20 letter signed by CEO James B. Robb, NERC said it would “initiate efforts to update registry criteria and develop initial Reliability Standards to include large loads” [1]. APPA reports that the October petition calls its approach targeted and says NERC exercises prudence in expanding its registry [10].

NERC has cited specific events. POWER reports a July 2024 Eastern Interconnection incident in which about 1,500 MW of data center load dropped nearly at once, and a January 2026 NERC review of 26 cryptocurrency mining load reductions above 100 MW in ERCOT [8]. Davis Wright Tremaine reports that the petition also cites a nearly 3,900 MW PJM disconnection in July 2026 [13]. NERC issued a Level 3 alert with seven essential actions on May 4 [8, 13].

On the ballot, CLO-002-1, the standard requiring compliance with operating instructions, drew the lowest support of the five, at 77.93 percent [7]. APPA notes that Kyle Turpin, its manager for energy policy and reliability standards, served on the drafting team [11]. No filing by a data center operator appears in the record this report draws on. Interventions in Docket No. RR27-1-000 are due November 20 [2].

Reading-room questions

Questions readers bring to this record, answered from the documents cited below.

When are comments due on NERC's data center registration petition?
5 p.m. Eastern on November 20, 2026, in FERC Docket No. RR27-1-000 [2]. The same deadline applies to motions to intervene and protests [2, 12].
Which data centers would have to register with NERC?
Owners and operators of a Computational Load Site with total connected load of at least 50 MW supplied through equipment connected at 100 kV or above, according to reports on the petition [10, 12]. The site definition covers facilities used for software services, AI training and deployment, and cryptocurrency mining [7].
Are the NERC data center reliability standards in effect?
No. NERC's board adopted CLO-001-1, CLO-002-1 and CLO-003-1 on October 26, but they take effect only after FERC approves them [6, 11]. FERC set December 31, 2026 as the date NERC must file them [1].
How long would existing data centers have to install disturbance recording under CLO-003-1?
Thirty-six months after the standard's effective date for existing sites, according to POWER's account of the implementation plan [8]. New sites would get until 15 months after the effective date or their in-service date, whichever is later [8].
Does registering with NERC give a data center transmission rights?
No. Registration would not confer interconnection or transmission rights, and it would not make a data center a generator, according to Pillsbury's reading of the petition [12].

Note on sourcing

This report does not draw on the text of NERC's October 21 petition in Docket No. RR27-1-000 or on the board-adopted text of CLO-001-1, CLO-002-1 and CLO-003-1. Their contents, including the 68,288-megawatt coverage estimate, the site definition and the implementation periods, are described as the American Public Power Association, POWER, Utility Dive, Pillsbury and Davis Wright Tremaine reported them. The board's October 26 vote is reported by APPA, Pillsbury and Utility Dive; no NERC board resolution is cited. Sources give the final ballot's close as October 14 or October 15. The roughly 3,900-megawatt PJM disconnection in July 2026 is reported by Davis Wright Tremaine alone and, by its account, remains under investigation. That no petition for the CLO standards had been noticed rests on FERC's combined notices through November 6; a later filing is possible. The December 3 date for post-conference comments in Docket No. AD26-8-000 is this report's count of 30 days from the notice's November 3 date; that notice is a public-inspection copy and its official publication is pending. No comments by data center operators or their trade groups appear in the record cited here.

Sources

  1. Order Directing the North American Electric Reliability Corporation to File Reliability Standard(s) Pertaining to Computational Load Integration, 196 FERC ¶ 61,031, Docket No. RD26-7-000Federal Energy Regulatory Commission, July 16, 2026 · ferc.gov
  2. Combined Notice of Filings #1 (Docket No. RR27-1-000), 91 FR 67562 (FR Doc. 2026-21877)Federal Energy Regulatory Commission, October 27, 2026 · govinfo.gov
  3. Combined Notice of Filings #1 (Docket Nos. RD27-1-000 and RD27-2-000), 91 FR 70080 (FR Doc. 2026-22718)Federal Energy Regulatory Commission, November 6, 2026 · govinfo.gov
  4. Reliability Technical Conference, Third Supplemental Notice of Commissioner-Led Technical Conference, Docket No. AD26-8-000Federal Energy Regulatory Commission, October 15, 2026 · ferc.gov
  5. Reliability Technical Conference; Notice Inviting Post-Technical Conference Comments, Docket No. AD26-8-000 (FR Doc. 2026-22762, public inspection)Federal Energy Regulatory Commission, Filed November 6, 2026; scheduled for publication November 9, 2026 · public-inspection.federalregister.gov
  6. 16 U.S.C. 824o, Electric reliability (Federal Power Act section 215)U.S. Congress, accessed 2026-11-08 · law.cornell.edu
  7. NERC Computational Load Update (ERCOT Large Load Working Group)Electric Reliability Council of Texas, October 15, 2026 · ercot.com
  8. NERC Reliability Standards for Data Centers and Crypto Loads Pass Final Ballot, Advance to Board ReviewPOWER Magazine, October 15, 2026 · powermag.com
  9. Reliability standards for AI data centers, crypto miners move closer to adoptionUtility Dive, October 15, 2026 (updated October 27, 2026) · utilitydive.com
  10. NERC Seeks FERC Approval to Add Two New Entities to Registry Criteria Tied to Large Computation LoadsAmerican Public Power Association, October 25, 2026 · publicpower.org
  11. Board of Trustees for NERC Adopts Foundational Computational Load Reliability StandardsAmerican Public Power Association, October 27, 2026 · publicpower.org
  12. NERC Proposes Federal Reliability Registration for Large Data CentersPillsbury Winthrop Shaw Pittman LLP, October 30, 2026 · pillsburylaw.com
  13. NERC Asks FERC to Fast-Track Data Center Registration RulesDavis Wright Tremaine LLP, November 3, 2026 · dwt.com

Subject headings

Cross-references

Other register entries filed under the same subject headings.

  1. No. 0034 · Report · 1 shared headingColumbia Gulf files Clark Project for EKPC's J.K. Smith station, Docket No. CP27-9-000, seeking rolled-in rates
  2. No. 0031 · Floor order · 1 shared headingSenate order sets Nov. 9 cloture vote on motion to proceed to H.R. 2347, the vehicle for a permitting package
  3. No. 0030 · Report · 1 shared headingFERC opens scoping on Longboard LNG import terminal off Oʻahu, Docket No. PF26-10-000