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NERC filed comments with the Federal Energy Regulatory Commission (FERC) today on the Advance Notice of Proposed Rulemaking (ANOPR) addressing the reliable interconnection of large loads. Through the work of the Large Loads Task Force and stakeholder technical committees, NERC continues to identify effective pathways for the reliable integration of large loads with the grid. NERC’s comments highlight this ongoing work and NERC’s important role in supporting a reliable grid that enables innovation and maximizes the integration of technologies that support and power the North American economy. NERC’s comments cover three main topics:
- NERC Supports Addressing Large Loads and Appreciates Recognition of NERC’s Role: NERC supports FERC addressing the rapid growth of large loads and appreciates the ANOPR’s recognition of NERC’s role in ensuring grid reliability to advance innovation and the U.S. economy. NERC’s 2024 Long-Term Reliability Assessment identified that demand growth is higher than at any point in the last two decades. Large loads, such as data centers for cryptocurrency mining and artificial intelligence, present unique challenges to demand forecasting and grid planning due to their substantial size and rapid construction.
Other challenges include large load performance issues that have caused grid disturbances. Accordingly, the ANOPR asks NERC to consider whether new NERC Reliability Standards are needed to address the emerging demand, including whether existing and additional entities must comply with standards. Reliability Standards benefit such entities by clarifying expectations and providing consistency and scalability as well as assurance that all those engaging with the interconnected grid understand their role in preserving the reliable operation of the bulk power system. Registration also benefits entities by clearly defining responsibilities and facilitating an accurate representation of anticipated performance.
- FERC Should Reference the Full Scope of NERC Authority: While NERC declines to comment on jurisdictional principles raised in the ANOPR outside its purview, NERC requests any future FERC actions reference NERC’s full authority as the Electric Reliability Organization under section 215 of the Federal Power Act to include users, owners, and operators of the bulk power system. While NERC’s risk-based approach to regulation does not necessarily mean Reliability Standards expand to the full extent of its authority, NERC’s comments note that any risk assessment of reliability impacts to the bulk power system needs to consider all those under NERC’s reliability authority.
- NERC is Actively Collaborating with Stakeholders to Assess Risks and Mitigation: As a collaborative organization, NERC works with a variety of stakeholders, including large load entities, to expeditiously identify risks and any necessary mitigation. In initiating its Large Loads Action Plan, NERC aims to thoughtfully identify practical performance recommendations while responding promptly to the urgent challenge of integrating large loads. NERC’s filing details a timeline of actions through 2028 to promptly and deliberately address identified reliability concerns. NERC continues to expand its stakeholder outreach and encourages all interested parties to engage with NERC under the Large Loads Action Plan. Addressing large loads is a top priority for NERC and the Regional Entities.
