On September 19, 2025, the North American Electric Reliability Corporation (NERC) issued a Level 2 Alert regarding “Large Load Interconnection, Study, Commissioning, and Operations”. The Alert was sent to Distribution Providers (DP), Resource Planners (RP), Transmission Owners (TO), Transmission Operators (TOP), Transmission Planners (TP), Balancing Authorities (BA), Planning Coordinators (PC), and Reliability Coordinators (RC). The Level 2 Alert was issued in response to a series of disturbances where unexpected large load output reduction occurred between 2024-2025, because rapid, major changes in the electric load can impact the Bulk Power System’s (BPS) ability to maintain a stable state.
The Alert defines a Large Load as “Any commercial or industrial individual load facility or aggregation of load facilities at a single site behind one or more point(s) of interconnection that can pose reliability risks to the BPS due to its demand, operational characteristics, or other factors. Examples include, but are not limited to, data centers, cryptocurrency mining facilities, hydrogen electrolyzers, manufacturing facilities, and arc furnaces.”
High Level Summary of Alert Recommendations
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Recommendation 1: TOs, and when relevant DPs, should establish clear facility design and performance criteria in their interconnection requirements for Large Loads to mitigate the reliability risk posed by their expected behavior during normal operations and in response to System Disturbances;
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Recommendation 2: TPs and PCs should establish a comprehensive interconnection and system-wide study process using steady state, dynamic, and short-circuit models to assess reliability impacts of Large Loads;
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Recommendation 3: TOs should enhance their load commissioning activities to establish a comprehensive commissioning process that ensures operational readiness for Large Loads;
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Recommendation 4: TOs should establish operating protocols and the necessary communication infrastructure to support reliable ongoing operations after Large Load facilities enter into commercial operations; and
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Recommendation 5: TPs, RPs, and PCs should, in consultation with their appropriate regulatory bodies, identify and implement a process to include Large Loads into their Long-Term Transmission Planning Horizon Demand forecasts as well as their Near-Term Transmission Planning Horizon Demand forecasts.
Questions regarding the potential effects of large loads on interconnected electric systems, as well as questions regarding how to ensure consistent, reliable service to the large loads themselves have received industry-wide attention recently. NERC indicates that the responses to its Alert will “subsequently inform the additional actions necessary to mitigate observed reliability risks. The results of this assessment will be issued in a forthcoming report on the Alert data.”
Registered entities are required to submit an acknowledgement to NERC by Midnight Eastern Time on September 16, 2025 and reporting to NERC by recipients of the Alert is required by Midnight Eastern Time on January 28, 2026. For more information and assistance in developing a response please contact Lisa Gast or Sean Neal.