Skip to content

Menu

Network by SubjectChannelsBlogsHomeAboutContact
AI Legal Journal logo
Subscribe
Search
Close
PublishersBlogsNetwork by SubjectChannels
Subscribe

NERC Seeks FERC Approval of New Registration Categories Related to Computational Loads

By Monica Sterling & Alexander Kaplen on November 11, 2026
Email this postTweet this postLike this postShare this post on LinkedIn

On October 21, 2026, the North American Electric Reliability Corporation (NERC) submitted a Petition with FERC seeking approval of proposed Rules of Procedure revisions that add two new functional entity types to the NERC Compliance Registry—Computational Load Owner (CLO) and Computational Load Operator (CLOP).  NERC proposed these Rules of Procedure revisions in response to emerging concerns over the electrical behavior of computational loads and FERC’s July 16, 2026 order directing NERC to address Bulk-Power System (BPS) reliability risks associated with the integration of computational loads.

Under NERC’s Rules of Procedure revisions, a CLO is the entity that “owns and maintains” a “Computational Load Site,” while a CLOP is the entity that “operates” one.  NERC proposed to define a Computational Load Site as “one or more buildings, structures, or installations at a single location that (1) primarily contain information technology infrastructure used for: software services; artificial intelligence training and delivery; cryptocurrency mining; or other data center computational activities; and (2) is supplied through electrical equipment connected to the BPS.”  NERC proposed registering CLOs or CLOPs of a Computational Load Site with a total connected load of at least 50 MW that is supplied through electrical equipment connected at a voltage of 100 kV or greater from one or more points of connection.

NERC asserts that this threshold addresses the aggregate risks posed by computational loads without capturing smaller entities that pose less risk to the BPS.  According to NERC, the threshold would capture approximately 68,288 MW of Computational Load Site CLOs and CLOPs, which equals approximately 86% of the total computational load projected to be in service by the end of 2027.  Once registered, CLOs and CLOPs would be subject to compliance and enforcement of applicable Reliability Standards. 

NERC requested expedited action on its Rules of Procedure revisions so that it may more effectively engage with new potential registrants and provide targeted outreach, while encouraging entities to engage with NERC and the Regional Entities.  NERC’s Petition also noted that it would file proposed Reliability Standards to address computational load at a later date along with associated implementation plans.

NERC’s Petition, submitted in Docket No. RR27-1-000, is available here.

Photo of Monica Sterling Monica Sterling

Monica focuses her practice on energy regulatory matters, representing natural gas pipelines, electric cooperatives, municipal utilities, and renewable energy developers in matters before the Federal Energy Regulatory Commission (FERC) and state regulators. She provides litigation support in FERC rate proceedings and advises on…

Monica focuses her practice on energy regulatory matters, representing natural gas pipelines, electric cooperatives, municipal utilities, and renewable energy developers in matters before the Federal Energy Regulatory Commission (FERC) and state regulators. She provides litigation support in FERC rate proceedings and advises on compliance with the Federal Power Act, the Natural Gas Act (including Section 7 abandonment authorizations), and related federal statutes.

Read more about Monica Sterling
Show more Show less
Photo of Alexander Kaplen Alexander Kaplen

Alexander advises clients on all aspects of regulatory issues. With experiences in both the public and private sectors, he applies a deep understanding of the legal, regulatory, and strategic challenges facing stakeholders in the energy sector.

Read more about Alexander KaplenAlexander's Linkedin Profile
  • Posted in:
    Energy
  • Blog:
    Washington Energy Report
  • Organization:
    Troutman Pepper Hamilton Sanders LLP
  • Article: View Original Source

LexBlog logo
Copyright © 2026, LexBlog. All Rights Reserved.
Legal content Portal by LexBlog LexBlog Logo