Operational Data and Communications: The Final Draft of NERC's Proposed Standard for Computational Load Sites

The North American Electric Reliability Corporation (NERC) has published the final draft of a proposed Reliability Standard, CLO-002-1, titled "Computational Load Operational Data and Communications." Its pages are dated October 2026, and it calls itself "the final draft of proposed standard for a 6-day ballot." Its timetable lists that final ballot for October 9 to 14, 2026, and board adoption in the fourth quarter of 2026, both under anticipated actions. Parts of the draft and of its implementation plan follow, not the whole.

The draft defines a Computational Load Site as one or more buildings, structures or installations at a single location that primarily contains information technology infrastructure used for the purposes it lists, among them "artificial intelligence training, deployment, and delivery" and "cryptocurrency mining," and that is supplied through electrical equipment connected to the Bulk-Power System. Two new entities go with it. The Computational Load Owner is "The entity that owns and maintains a Computational Load Site." The Computational Load Operator is "The entity that operates a Computational Load Site."

As facilities, the draft would apply to "Computational Load Sites with a total connected Load greater than or equal to 50 MW that are supplied through electrical equipment connected at a voltage level greater than or equal to 100 kV from one or more points of connection."

Each Operating Instruction

The draft modifies the definition of an Operating Instruction. As modified, it is "A command by operating personnel responsible for the Real-time operation of the interconnected Bulk Electric System to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System or a Computational Load Site." A discussion of general information and of potential options or alternatives to resolve Bulk Electric System operating concerns, it adds, "is not a command and is not considered an Operating Instruction."

Under Requirement R8, each Computational Load Operator "shall comply with each Operating Instruction issued by its Transmission Operator(s), Balancing Authority, or Reliability Coordinator unless such action cannot be physically implemented or it would violate safety, equipment, regulatory, or statutory requirements." Under R9 the operator "shall inform" the one that issued an instruction "of its inability to comply with the Operating Instruction issued."

On request, the operator would make available evidence that it complied with each Operating Instruction, such as dated operator logs, voice recordings or electronic communications. Where it could not comply because of a safety, equipment, regulatory or statutory requirement, it would provide copies of that requirement. The duty in R8, with the records that go with it, is one a lease and a loan on the campus would have to make room for.

Data, and Interpersonal Communication

The draft's stated purpose has two parts. One is that each Transmission Operator, Balancing Authority and Reliability Coordinator has the site data "it needs to plan, monitor, and assess the reliable operation of the Bulk Power System." The other is "to establish Interpersonal Communication capabilities at Computational Load Sites with predefined communications protocols to ensure prompt action to prevent or mitigate occurrences that adversely impact the reliability of the Bulk Power System."

The Transmission Operators, Balancing Authorities and Reliability Coordinators would each keep and distribute specifications for the site data they need. Each owner and operator that receives one "shall satisfy the obligations of the documented specifications."

Each Computational Load Operator would need Interpersonal Communication capability with its Balancing Authority and its Transmission Operator. It would train each of its operating personnel who can receive an oral two-party, person-to-person Operating Instruction, before that person receives one, to repeat it, "not necessarily verbatim," and receive confirmation that the response was correct, or to ask the issuer to reissue it. When it receives such an instruction during an Emergency, excluding "written or oral single-party to multiple party burst Operating Instructions," the operator would do one or the other.

When It Would Apply

The draft's timetable anticipates board adoption in the fourth quarter of 2026. The implementation plan says the standard "is expected to have wide ranging impact on Computational Load Operators, as existing and new Computational Load Sites would be required to implement interpersonal communications capabilities with Balancing Authorities (BA) and Transmission Operators (TOP)." Computational Load Owners, the plan adds, "are expected to be registered beginning in 2027," on the basis of planned changes to NERC's Rules of Procedure and a filing with FERC that it calls imminent.

The standard and two of its definitions "would become effective the first day of the first calendar quarter following regulatory approval, with a phased-in compliance timeline spanning twelve (12) months from the effective date." "Where approval by an applicable governmental authority is not required," the plan says, they would take effect on the first day of the first calendar quarter after the standard is adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction. Requirements R8 to R15, which include the duty to comply with Operating Instructions, would apply twelve months after the effective date.

The plan also sets out a "Process for Requesting an Extension" from those dates. An entity with an applicable site in service no later than twelve months after the effective date "may request an extension from the above-listed compliance dates for Requirements R8-R15 if circumstances beyond its control prevent the establishment of Interpersonal Communication capability and associated protocols at one or more of its Computational Load Sites." Such circumstances, the plan says, "may include supply chain delays associated with the procurement, engineering, installation, or commissioning of Interpersonal Communication equipment."