NERC & Grid Reliability Change Watch

Purpose and scope

Why this page exists

Utilities, transmission planners, large-load customers, and consultants face a growing set of reliability-related standards, projects, guidelines, and alerts. This page is a structured watch list for engineering interpretation — not a compliance portal and not a substitute for reading the official requirements.

GR tracks emerging topics that may affect study assumptions, modeling, protection practices, operations readiness, and cybersecurity boundaries. Entries are added only when supported by a supplied or official primary source.

Scope includes: transmission planning, large and emerging loads (including data centers), modeling and validation, ride-through and disturbance response, protection and remedial-action considerations, and selected CIP-related control-center topics — as those subjects become verified.

Engineering perspective

Prepared by Dr. Sudhir Agarwal, drawing on more than 35 years of experience in power-system planning and reliability, probabilistic methods, utility studies, reliability software, and engineering-study automation. The objective is to translate changing requirements into practical questions about models, studies, controls, evidence, and implementation.

Prepared independently from publicly available NERC, FERC and industry materials. General Reliability is not affiliated with or endorsed by NERC. This information provides engineering interpretation and does not constitute legal advice, compliance certification or a substitute for review of the official requirements.

How to read the tracker

Status legend

Effective

Requirement or document is in effect according to the official source. Confirm effective date and applicability in the primary text.

Approved / Future Effective

Approved or filed path exists, with a future effective date or implementation timeline still to be confirmed from the official source.

Proposed / Under Development

Project, draft, or proposal is under development or industry review. Content may change before finalization.

Guideline / Alert

Guidance, white paper, lesson learned, or alert — useful for engineering awareness, not automatically a mandatory standard.

Structured tracker

Change watch table

Selected developments are shown because they may materially affect utilities, transmission planners, data centers, and other large-load stakeholders. Status and dates were checked against NERC primary sources and the NERC One-Stop-Shop workbook; applicability still requires review of the governing documents.

Current attention — October 2026

Status checked September 27, 2026. NERC has moved from broad large-load risk identification into specific proposed registration language and draft Reliability Standards for computational loads. That does not mean every data center is a NERC-registered entity, that Computational Load Owner or Operator functions are already effective, or that draft CLO text is enforceable. An initial ballot that has concluded is not approval of an effective Reliability Standard. Final applicability, approvals, and effective dates remain unresolved. Deadlines and draft text should be reconfirmed on NERC’s official pages before acting. For facility electrical and POI context, see Data-Center Power & Grid Reliability and Load Behavior & Grid Interaction.

October 8, 2026 verification note — new and continuing actions.

Project 2026-02: NERC's project page continues to describe the September 18 initial ballot as concluded, with drafting-team review of comments and next steps pending. NERC's September 19 announcement reported preliminary passage of the foundational computational-load standards at initial ballot. This is not final approval, FERC approval, or an effective compliance requirement. Official project · NERC announcement.

October 22 deadline: Two Large Loads Working Group draft Standard Authorization Requests remain open for comment through October 22, 2026: computational-load event reporting, model validation and model quality assessment; and studying computational-load loss in planning and operational reliability studies. These are SARs for proposed work, not effective standards. NERC Large Loads Action Plan.

Related standards-process consultation: NERC's proposed Standards Processes Manual revisions have a comment deadline of October 26, 2026 and an initial ballot window of October 16–26. This is standards-process modernization, not a new computational-load technical requirement. Official project.

GR engineering interpretation: The two large-load SARs strengthen the case for study-quality models that connect point-of-interconnection disturbances, protection/transfer behavior, rapid load loss and reconnection, and consequences to grid customers and useful computing. These are research and planning questions; do not represent the draft SARs as mandatory requirements. See Integrated Grid–Data Center Reliability.

A. Project 2026-02 — draft standards under development; initial ballot concluded

NERC’s Project 2026-02 Computational Loads page, checked September 27, 2026, states that initial ballots for the standards, implementation plans, and non-binding VRF/VSL polls concluded at 8:00 p.m. Eastern, Friday, September 18, 2026. The formal comment period was August 19–September 18, 2026. Ballot-pool formation was August 19–September 3, 2026 (through 8:00 p.m. Eastern). The same page states that the drafting team will review all responses received during the comment period and determine the next steps. Project 2026-02 remains a standards-development project. The drafts are not effective Reliability Standards.

On September 19, 2026, NERC’s newsroom reported preliminary results indicating that the foundational Computational Loads Reliability Standards had passed initial ballot, and said NERC would validate the ballot results and post the report of comments the following week (newsroom item). As of September 27, 2026, the project page posts the initial-ballot quorum and weighted-segment values below. It does not state that the drafts have been approved as Reliability Standards, filed with FERC, or made effective. NERC also said the drafting team would continue reviewing comments toward a planned filing in the last quarter of 2026. A planned filing is not a completed filing.

CLO-001-1 initial ballot — quorum 92.57; weighted segment value 81.58
CLO-002-1 initial ballot — quorum 92.53; weighted segment value 77.93
CLO-003-1 initial ballot — quorum 92.26; weighted segment value 82.40
FAC-001-5 initial ballot — quorum 91.40; weighted segment value 95.45
FAC-002-5 initial ballot — quorum 91.40; weighted segment value 95.45

The project page also posts initial-ballot results for the associated implementation plans and non-binding VRF/VSL polls. Those posted figures are initial-ballot statistics. They do not make the drafts effective.

The proposed package posted for comment (all draft Reliability Standards / proposed revisions under development, not final or effective) includes:

CLO-001-1 — Computational Load Interconnection, Studies, & Modeling Data
CLO-002-1 — Computational Load Operational Data and Communications
CLO-003-1 — Computational Load Protection Coordination & Disturbance Monitoring
Limited proposed updates to FAC-001-5 (Facility Interconnection Requirements) and FAC-002-5 (Facility Interconnection Studies)
Associated implementation plans, technical rationale, and VRF/VSL materials

Engineering significance of the draft package (paraphrased): clearer expectations around interconnection requirements and studies; modeling-data ownership and exchange; operating data and communications; protection coordination; disturbance monitoring; and the interface between proposed computational-load entities and existing planning/interconnection functions. Treat every CLO/FAC item as proposed draft language until NERC’s standards and regulatory processes conclude.

B. Registration-criteria proposal — Rules of Procedure

NERC’s Proposed Changes to Rules of Procedure page states that it conducted public comment periods on proposed revisions to Appendices 2, 5A, and 5B that would add Computational Load Owner and Computational Load Operator registry functions: April 1–May 15, 2026, and August 19–September 18, 2026. The August 19–September 18, 2026 comment period has closed. NERC states that it reviewed comments received at the conclusion of the August posting and will post its consideration of comments soon. As of September 27, 2026, that consideration-of-comments document for the August posting was not yet posted.

These functions and criteria remain proposed, not yet effective. Closing the comment period does not approve the criteria. Whether any facility or organization would be registered will depend on the final approved registration criteria and governing process—not on draft language alone. See also the Large Loads Action Plan.

C. Disturbance Performance for Computational Loads — Standard Authorization Request

NERC’s Large Loads Working Group issued a Standard Authorization Request (SAR) on Disturbance Performance for Computational Loads on 26 August 2026. Comments were requested through 24 September 2026. That comment period has closed. A SAR proposes or frames possible standards work; it is not itself an effective Reliability Standard and does not establish enforceable requirements.

The SAR focus, as described by NERC, relates to disturbance-related computational-load performance—including concerns associated with rapid or simultaneous load reduction, oscillatory behavior, ride-through/disturbance response, and bulk-power-system consequences. As of September 27, 2026, the Large Loads Action Plan still links the August 26, 2026 SAR PDF and comment matrix and does not post a Standards Committee acceptance, rejection, or other disposition of this SAR. Confirm the next posted disposition on that hub. Official SAR PDF: Disturbance Performance for Computational Loads SAR; comment matrix: SAR comment matrix (XLSX).

D. Additional SARs now posted for comment

Separate from the closed Disturbance Performance SAR, the Large Loads Action Plan states that, on September 22, 2026, the RSTC Executive Committee accepted two additional draft SARs for posting for a 30-day public comment period. The comment period is September 23–October 22, 2026:

These are proposed SARs under comment, not effective Reliability Standards and not a disposition of Project 2026-02. NERC’s details link is Requests for Comment. Status checked September 27, 2026.

E. Completed workshop — Load Modeling Working Group

The Load Modeling Working Group Workshop on Data Center Load Modeling was a two-day workshop and is now listed under prior events on the Large Loads Action Plan:

Session 1: September 15, 2026, 12:00–5:00 p.m. Eastern
Session 2: September 16, 2026, 12:00–5:00 p.m. Eastern

Microsoft Teams. Official event: 09-15-26 LMWG Workshop. Official agenda: Data Center Load Modeling Workshop agenda (PDF). This was a workshop, not a standards ballot or effective requirement.

F. Continuing items (positioned accurately)

Level 3 Essential Action Alert issued May 4, 2026: NERC identified seven actions for applicable registered entities. The registered-entity response deadline was August 3, 2026 and has passed; retain response evidence where applicable and monitor subsequent findings/follow-up. The Alert does not imply that every data center is a NERC-registered entity or was directly subject to the Alert. Official announcement and Alert PDF.
Reliability Guideline: Risk Mitigation for Emerging Large Loads remains non-binding guidance.
Project 2026-02 remains a standards-development project. The initial ballot and comment period have concluded. Posted initial-ballot statistics and NERC’s September 19 preliminary “passed initial ballot” statement do not make the drafts effective. Final applicability and effective dates are unresolved.
Past events: the 27 August 2026 Project 2026-02 industry webinar and the 15–16 September 2026 LMWG workshop are completed informational sessions, not ballots or effective requirements.

NERC Large Loads Action Plan (official hub) · Project 2026-02 · Proposed Rules of Procedure changes

Topic	NERC document or project	Status	Important date	Who may be affected	Why it matters	Practical action	Official source
Draft computational-load Reliability Standards	Project 2026-02: proposed CLO-001-1, CLO-002-1, CLO-003-1; limited proposed FAC-001-5 and FAC-002-5 updates; implementation plans	Draft standards · initial ballot concluded	Initial posting authorized August 19, 2026. Comment period August 19–September 18, 2026 has closed (8:00 p.m. Eastern). Ballot-pool formation August 19–September 3, 2026 has closed (8:00 p.m. Eastern). Initial ballots and non-binding VRF/VSL polls concluded September 18, 2026. Project page posts initial-ballot quorum and weighted-segment values; NERC’s September 19 newsroom called the standards results preliminary and said validation and the comment report would follow. Drafting team to review comments and determine next steps. Not approved, filed, or effective. Status checked September 27, 2026. FERC year-end directive context remains December 31, 2026.	Utilities, planners, operators, interconnection hosts, and organizations that may later fall under proposed Computational Load Owner/Operator criteria—if and when approved	Draft package addresses interconnection/studies/modeling data, operational data and communications, and protection coordination & disturbance monitoring, plus limited FAC clarity—still proposed, not enforceable CLO standards.	Compare study assumptions and data ownership with the draft package without treating drafts or initial-ballot statistics as binding. Follow the next posted drafting-team step on the project page. Inventory models, telemetry, protection, and disturbance-monitoring evidence. See What organizations should do now.	NERC Project 2026-02
Proposed Computational Load registration criteria	Proposed Rules of Procedure revisions (Appendices 2, 5A, 5B) — Computational Load Owner and Computational Load Operator	Proposed ROP / registration criteria	August 19–September 18, 2026 comment period has closed. NERC states it reviewed comments and will post its consideration of comments soon. Proposed Computational Load Owner and Computational Load Operator functions are not yet effective. Status checked September 27, 2026.	Potential future Computational Load Owners/Operators; coordinating utilities, planners, and operators	Proposed entity types would frame who may become subject to related reliability obligations—if approved. Applicability depends on final criteria and process.	Determine transmission- vs distribution-connection and which entity owns interconnection, planning, operating, protection, and model obligations. Do not assume automatic registration.	Proposed Changes to Rules of Procedure · Large Loads Action Plan
Disturbance performance standards scoping	Standard Authorization Request: Disturbance Performance for Computational Loads (Large Loads Working Group)	SAR · comment period closed	Issued August 26, 2026. Comments were requested through September 24, 2026; that period has closed. No Standards Committee disposition was posted on the Action Plan hub as of September 27, 2026. A SAR is not an effective Reliability Standard.	Planners, operators, large-load stakeholders, and future standards-development participants	Frames further work on disturbance-related computational-load behavior (e.g., rapid/simultaneous reduction, oscillations, ride-through/disturbance response) without creating draft enforceable requirements by itself.	Assess fast load-reduction, oscillation, ride-through, protection, transfer, reconnection, and rebound behavior with study-appropriate models. Confirm any later SAR disposition on the Action Plan hub. Do not invent requirements from a closed comment period.	SAR PDF · Comment matrix · Action Plan hub
Immediate computational-load risk actions	Level 3 Essential Action Alert: Computational Load Modeling, Studies, Instrumentation, Commissioning, Operations, Protection, and Control	Essential Action Alert	Issued May 4, 2026. NERC identified seven actions for applicable registered entities. Registered-entity responses were due August 3, 2026; the deadline has passed. Monitor subsequent findings and follow-up. Status checked September 27, 2026.	Registered entities identified by NERC for the Alert; coordination may involve large-load customers and equipment providers. Does not mean every data center was subject to the Alert.	NERC cited rapid customer-initiated load reductions and oscillations that can leave little time for real-time response.	Preserve Level 3 Alert response evidence where applicable. Monitor NERC follow-up concerning models, studies, instrumentation, commissioning, operations, protection and controls.	NERC announcement · Alert PDF
Risk mitigation for emerging large loads	Reliability Guideline: Risk Mitigation for Emerging Large Loads	Non-binding guideline	Published 30 April 2026	Utilities, grid operators, large-load owners/developers, and equipment manufacturers	The guideline recommends coordinated practices to integrate industrial-scale loads while protecting grid stability. Guidelines do not create mandatory Reliability Standard obligations by themselves.	Benchmark interconnection, modeling, ride-through, communications, and operating practices against the recommendations—without treating the guideline as enforceable.	NERC Reliability Guidelines
Planning-model data requirements	MOD-032-2 — Data for Power System Modeling and Analysis	Future enforcement	Effective 1 April 2028; Requirements R2-R4 transition on 1 April 2029	Planning Coordinators, Transmission Planners, and entities that provide modeling data	Revised data requirements and reporting procedures support planning-horizon case development and more consistent system analysis.	Inventory required data, owners, formats, validation checks, submission workflows, and evidence well before transition dates.	NERC MOD-032-2
Steady-state and dynamic model validation	MOD-033-3 — Steady-State and Dynamic System Model Validation	Effective	Effective 1 April 2026	Reliability Coordinators and other applicable registered entities identified in the standard	The standard establishes a process for model validation to support model accuracy.	Confirm validation procedures, actual-system comparison methods, discrepancy handling, responsibilities, and retained evidence.	NERC MOD standards
Transmission Owner Control Center classification	CIP-002-8 — Cyber Security: BES Cyber System Categorization	Future enforcement	Effective 1 July 2028	Transmission Owners with applicable real-time control capabilities; CIP and operations teams	The revised Control Center definition can bring certain Transmission Owner facilities with qualifying real-time control capability into TOCC classification and CIP scoping. An ordinary computational-load data center does not automatically become a Transmission Owner Control Center.	Assess whether applicable facilities meet the revised Control Center definition; document real-time monitoring and control functions, operating authority, system architecture and BES Cyber System categorization.	NERC CIP-002-8
Operational data and information specifications	TOP-003-7 — Transmission Operator and Balancing Authority Data and Information Specification and Collection	Future enforcement	Effective 1 October 2026	Transmission Operators, Balancing Authorities, and entities supplying requested operational data	The standard supports the data and information needed to plan, monitor, and assess reliable operation.	Confirm data specifications, providers, collection processes, quality checks, delivery timing, and evidence before the effective date.	NERC TOP standards

Status checked September 27, 2026. Source base: official NERC Project 2026-02 page (including posted initial-ballot statistics), the September 19, 2026 NERC newsroom item on those preliminary ballot results, Proposed Changes to Rules of Procedure, Large Loads Action Plan hub (including the September 23–October 22, 2026 SAR comment notice), linked Q2 2026 update / FAQ / SAR PDFs, LMWG workshop event and agenda, Level 3 Alert announcement and Alert PDF, Reliability Guidelines, and FERC order context. Confirm applicability, later revisions, and deadlines in the controlling NERC documents before acting. This page remains a selected tracker, not a complete NERC inventory.

GR engineering interpretation

What organizations should do now

The following is independent engineering interpretation—not legal advice, not official applicability determination, and not compliance certification. Draft CLO language and proposed registration criteria are not binding. GR does not determine whether an organization must register with NERC or certify compliance.

Clarify connection and ownership

Determine whether the facility is transmission- or distribution-connected
Identify which entity owns interconnection, planning, operating, protection, and model obligations
Document data-sharing, confidentiality, telemetry, and operating-coordination boundaries

Compare drafts to existing evidence

Compare agreements and study assumptions with the draft CLO/FAC package—without treating drafts as binding
Inventory static, dynamic, protection, control, communications, and disturbance-monitoring data
Identify model owners, parameter sources, validation evidence, and update responsibilities

Assess disturbance behavior and process

Assess fast load-reduction, oscillation, ride-through, protection, transfer, reconnection, and rebound behavior
Follow the posted September 23–October 22, 2026 SAR comment window and later project milestones; reconfirm deadlines on NERC pages
Preserve Level 3 Alert response evidence where applicable

How this connects to GR services

Where helpful, GR can support engineering review through Load Behavior & POI Model Assessment, Grid Capacity & Flexibility Assurance, Architecture & Reliability, independent study review, model/data-gap assessment, probabilistic reliability and nonperformance analysis, and study automation / evidence organization. See also Power-System Reliability & Large-Load Engagements.

Boundary: GR provides engineering interpretation and scoped assessments. GR does not provide legal advice, does not determine official NERC applicability or registration, and does not certify compliance.

Outlook

What to Expect Through Year-End 2026

The following separates completed September windows from work that remains subject to NERC’s stakeholder, standards-development and regulatory processes. Dates and outcomes may change; controlling NERC and FERC documents govern. Status checked September 27, 2026. Reconfirm deadlines and drafts on NERC’s official pages.

Near-term process

Completed windows and remaining posted dates

September 3, 2026 — Project 2026-02 ballot-pool formation closed (8:00 p.m. Eastern)
September 9–18, 2026 — Project 2026-02 initial ballots and non-binding VRF/VSL polls concluded September 18 (8:00 p.m. Eastern). Initial-ballot statistics are posted; drafts are not effective
September 15–16, 2026 — LMWG Workshop on Data Center Load Modeling was held (prior event)
September 18, 2026 — Project 2026-02 formal comments and the August ROP registration-criteria comment period closed
September 24, 2026 — Disturbance Performance SAR comment period closed; no disposition was posted on the Action Plan hub as of September 27
September 23–October 22, 2026 — posted comment period for two additional computational-load SARs (RSTC Executive Committee acceptance September 22)
September 16, 2026 — previously noted Standards Committee meeting date has passed; the Project 2026-02 and Action Plan pages reviewed September 27 do not post a computational-load disposition from that meeting. October 21 and November 18, 2026 remain previously scheduled dates to reconfirm
December 31, 2026 — FERC-directed deadline associated with computational-load registration criteria and initial Reliability Standards/Rules of Procedure revisions

Past informational sessions: August 27, 2026 Project 2026-02 industry webinar and the September 15–16 LMWG workshop (both completed). Reconfirm later dates on NERC project, ROP, Action Plan, and event pages.

Under development

Work under development

Draft CLO-001-1 / CLO-002-1 / CLO-003-1 and limited FAC-001-5 / FAC-002-5 revisions: initial ballot concluded; drafting team reviewing comments; still a standards-development project
Proposed Computational Load Owner and Operator registration criteria (ROP Appendices 2, 5A, 5B); August comment period closed; consideration of comments not yet posted
Disturbance Performance for Computational Loads SAR — comment period closed; disposition not posted as of September 27, 2026
Two additional SARs in a posted comment period through October 22, 2026 — SARs, not effective standards
Continued work on load models, model validation and disturbance-performance information
Coordination among NERC, Regional Entities, planners, operators, utilities and large-load stakeholders

Specific drafts, ballots, approvals, filings and effective dates must be confirmed as NERC publishes them. Drafts are not final or enforceable CLO standards.

Monitor

Items to monitor

NERC analysis or follow-up resulting from Level 3 Alert responses
Changes to proposed entity registration and applicability thresholds
Ballot results, successive drafts, and any future-effective dates if standards are approved
Protection, control, instrumentation, ride-through and commissioning expectations
FERC action on NERC submissions and related large-load proceedings
Regional Entity and RTO/ISO implementation implications

These are monitoring topics, not promises that NERC will issue a final enforceable CLO standard by year-end.

Consulting connection

How GR Can Help

Translate emerging requirements into study questions

Map alerts, guidelines, and projects under development to planning cases, modeling checks, protection assumptions, and documentation needs — with engineers retaining judgment.

Organize evidence and engineering workflows

Connect assumptions, study outputs, checklists, and follow-up tracking so teams can show what was reviewed and when — without claiming compliance certification.

Assess transmission and computational-load implications

Evaluate how emerging topics may affect transmission systems, computational loads, data centers, and the grid–facility interface — distinguishing confirmed requirements from work still under development.

Probabilistic reliability and study review

Support probabilistic assessment and independent transmission-study review and QA where projects need decision-focused interpretation of power-flow, transient-stability, and reliability results.

Technical training

Provide specialist training and mentoring on reliability methods, study automation, and practical use of GR software where useful — connected to, not a substitute for, the official requirements.

Transmission & large-load services → · Advisory services →

Separate from operational AI frameworks

NERC reliability change watch focuses on grid reliability requirements and related industry materials. Operational AI risk frameworks for the electric sector are covered separately.

For an independent engineering discussion of EPRI’s SAFERai.power initiative, see SAFERai.power. That page does not replace NERC requirements.

Next steps

Confirm applicability against the governing standard or project
Current through 8 October 2026 — live tracker on this page
Discuss study or consulting support with GR

Discuss a reliability change topic

Contact GR to discuss how emerging reliability topics may affect your planning, modeling, protection, operations, or documentation workflows.

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