The rapid growth of artificial intelligence and hyperscale data centers has elevated computational loads to the short list of emerging reliability issues that FERC has determined warrant Commission-directed standards development. FERC's directive in Docket No. RD26-7 (2026) directing NERC to develop Reliability Standards addressing computational loads represents only the latest example of the Commission using one of its least frequently used reliability authorities: Section 215(d)(5) of the Federal Power Act.
Since Congress established the Electric Reliability Organization ("ERO") framework in the Energy Policy Act of 2005, the development of mandatory Reliability Standards has generally followed a "bottom-up" process. NERC, through its industry-led stakeholder process, identifies reliability needs, develops standards, and submits them to FERC for approval. That structure reflects Congress's judgment that mandatory reliability requirements are best developed through a technically focused, industry-driven process, while preserving FERC oversight and the ability to act when necessary.
Section 215(d)(5) provides FERC with a limited backstop authority. It allows the Commission to direct NERC to develop and submit a new or modified Reliability Standard or Standards when FERC determines such action is necessary to address a reliability concern. In practical terms, Section 215(d)(5) allows FERC to accelerate or focus the standards process when the Commission determines that reliability concerns require attention beyond the ordinary stakeholder-driven timeline.
Importantly, a Section 215(d)(5) directive does not necessarily mean that NERC or industry failed to recognize an issue. In several instances, NERC and stakeholders were already evaluating the issue through the ordinary standards development process. Indeed, the issues that ultimately result in Section 215(d)(5) directives are often issues that NERC and industry have already identified as important; the question is whether FERC determines that additional direction, focus, or speed is warranted.
FERC has exercised this authority only a handful of times. Those instances provide insight into the types of reliability concerns that have resulted in Commission-directed standards efforts.
In Order No. 779 (2013), following the 2012 Carrington-class solar storm that narrowly missed Earth and amid growing scientific and federal concern regarding the potential impacts of severe geomagnetic disturbances, FERC directed NERC to develop GMD Reliability Standards. The resulting TPL-007, Transmission System Planned Performance for Geomagnetic Disturbance Events, established requirements for assessing and mitigating the impacts of severe geomagnetic disturbances on the Bulk-Power System.
Following the April 2013 physical attack on PG&E's Metcalf Substation, FERC issued Docket No. RD14-6-000 (2014) directing NERC to develop Reliability Standards addressing physical security risks. That directive resulted in CIP-014, Physical Security, which requires applicable transmission owners and operators to identify critical facilities and develop, implement, and maintain physical security plans for those facilities.
In Order No. 829 (2016), FERC directed NERC to address supply chain cybersecurity risks arising from increasing concerns regarding cyber threats and vulnerabilities associated with vendors and third-party suppliers. Unlike the Metcalf directive, this action was not prompted by a single event. Rather, it reflected an evolving cybersecurity threat environment and recognition that existing Reliability Standards did not adequately address risks introduced through the supply chain. The resulting CIP-013, Cyber Security — Supply Chain Risk Management, established mandatory requirements for responsible entities to develop and implement supply chain risk management plans addressing cybersecurity risks associated with vendor relationships and procurement activities.
In Order No. 901 (2023), FERC addressed a different type of emerging reliability challenge: the changing performance characteristics of inverter-based resources. A series of grid disturbances involving inverter-based resources—including the 2016 Blue Cut Fire and the 2021 Odessa, Texas events—highlighted the need for more comprehensive approaches to IBR modeling, data availability, planning, and performance requirements. FERC directed NERC to develop new and modified Reliability Standards addressing IBR data sharing, model validation, planning and operational studies, and performance capabilities.
FERC's computational loads directive recently issued in Docket No. RD26-7 (2026) represents the latest example of this rare exercise of authority. Like the earlier directives, it reflects a determination that an emerging reliability issue has reached a level of significance requiring focused national attention. Unlike some prior actions, however, the directive is not tied to a single triggering event or a demonstrated failure of existing Reliability Standards. Instead, it reflects FERC's judgment that the pace and scale of change in the electric system—including unprecedented load growth, changing operating characteristics, and the rapid expansion of AI and other computational infrastructure—warrant a formal standards effort that proceeds with appropriate urgency.
The significance of these proceedings is not that FERC is replacing the NERC-led standards process—it is not. Rather, these rare Section 215(d)(5) actions illustrate the circumstances in which the Commission determines that an emerging reliability concern has become sufficiently significant, widespread, or consequential to warrant Commission-directed action.
Section 215(d)(5) does not establish a bright-line test. But FERC's limited use of this authority suggests a consistent theme: the issue must present a meaningful Bulk-Power System reliability concern, extend beyond the interests of a single entity or region, and require a coordinated response that FERC determines warrants focused national attention.
Computational loads have now joined that short list of issues—including geomagnetic disturbances, physical security, supply chain cybersecurity, and inverter-based resources—that FERC has determined warrant Commission-directed standards efforts.
