The Computational Load Entity Just Became Two
By KEIRSTEN BRAGER
NERC's August 19 posting replaced the Computational Load Entity with two separate registrations, Computational Load Owner and Computational Load Operator, raised the thresholds to 50 MW and 100 kV, and moved the test for who is in scope into a new Site definition. What changed between April and August, who should be running the applicability test, and the eight questions to answer before the window closes.
Overview
On August 19, the North American Electric Reliability Corporation (NERC) posted two packages for comment. The first is the revised Rules of Procedure (ROP) language, Appendices 2, 5A, and 5B, establishing registration for computational load. The second is the first tranche of Reliability Standards under Project 2026-02, CLO-001-1 through CLO-003-1 plus limited updates to FAC-001-5 and FAC-002-5, posted for comment and initial ballot.
This piece centers on the registration package, using the proposed standards to show why registration matters. Registration determines which organizations may enter the framework; the standards define what the registered functions may eventually be required to do.
The Window Is Thirty Days, and It Is the Best Chance to Shape the Initial Record
The ballot-pool join window closes September 3, 2026 at 8:00 p.m. Eastern. That is not the vote itself; it is the deadline to get into the pool that is allowed to vote. The initial ballots and non-binding poll then run September 9 through September 18, and comments on both the standards package and the ROP registry criteria close September 18.
The earlier date is the one organizations miss. An organization that lets September 3 pass has no seat in the ballot pool and therefore no vote when balloting opens September 9, no matter how strong its comments are, and it cannot join later in the same ballot window. Registered Ballot Body membership through a designated segment representative gates the pool, so confirm that first.
| Date | What closes or opens | What it means if you miss it |
|---|---|---|
| September 3, 8:00 p.m. Eastern | Ballot-pool join window closes | No seat in the pool, and therefore no vote. You cannot join later in the same ballot window. |
| September 9 to 18 | Initial ballots and non-binding poll | Open only to members of the ballot pool formed by September 3. |
| September 18, 8:00 p.m. Eastern | Comments close on both packages | Standards comments go through the Standards Balloting and Commenting System. Rules of Procedure comments go by email to ROPcomments@nerc.net. |
| December 31, 2026 | NERC files standards and registry criteria with FERC | Set by FERC order in Docket No. RD26-7-000. The compression above exists to preserve this date. |
| March 1, 2027 | Phase II workplan due | Sets the direction for the standards that follow the foundational tranche. |
The compression is deliberate. The Federal Energy Regulatory Commission (FERC) set the outer bounds. Its July 16 order, Docket No. RD26-7-000, 196 FERC ¶ 61,031, directs NERC to file both the standards and the registry criteria by December 31, 2026, and to follow with a Phase II workplan detailing the next steps in the standards development process by March 1, 2027. NERC is running the processes concurrently under a schedule designed to preserve those dates.
Jim Robb's August 13 letter to industry CEOs asks chief executives to direct their teams into the comment and balloting periods, to review their company's positions personally, and to underscore the urgency of first-ballot passage. The letter names the reason for the pace. It points to a customer-initiated load reduction and voltage excursion incident in PJM, more than 3 GW, the largest seen to date.
PJM's own review of the July 22 event puts the number higher than the letter does. Load fell from 99,984 MW to 96,205 MW, close to 3,800 MW, after a normally cleared fault on a 230 kV line in Dominion's zone. PJM recovered its Area Control Error limit in nine minutes against a NERC standard of thirty and reported no significant reliability impact. It also reported a large imbalance between generation and load and large swings in both voltage and frequency, and its Operating Committee chair said the facilities were too sensitive to voltage and are disconnecting too early. PJM is now weighing ride-through and other interconnection requirements of its own.
So the incident is not in dispute, and neither is the protection behavior behind it. What the compressed schedule assumes is that the answer can be drafted, balloted, and filed inside four months. A CEO letter is not a compliance obligation. It is a clear signal that NERC expects affected organizations to engage substantively and at the executive level during this compressed process.
One Function Became Two
The April posting proposed a single functional registration, Computational Load Entity, defined as the end-user or the entity that hosts end-users that receives electric power for Computational Load. NERC received 32 sets of comments from 44 commenters, spanning the trades, the regional transmission organizations and independent system operators, and the data center community.
The August revision replaced that single function with two. Computational Load Owner (CLO) and Computational Load Operator (CLOP) now stand as separate registrations, and NERC removed the "end-user or entity that hosts end-users" construction from the functional registrations entirely. NERC defines the Owner as the entity that owns and maintains a Computational Load Site and the Operator as the entity that operates it.
NERC's stated reason is that two functions address differing organizational arrangements more clearly, which is the measured version of what commenters raised about colocation, multitenant sites, and third-party operations.
An organization that knew which box it fell into last month now has to work out which of two boxes it occupies, or whether its arrangement produces both. The owner of a site and the party with day-to-day operating authority over that site's electrical equipment are frequently different companies, and the documents dividing their responsibilities were drafted against a commercial relationship rather than a functional registration.
The Site Definition Moved Part of the Filtering Work
Commenters asked for a facility-level definition so the criteria would attach to something identifiable. NERC proposed Computational Load Site instead, keeping the numerical thresholds out of the definition and in the registry criteria alone. The definition carries the word "primarily," and that one word replaced the 1 MW de minimis floor. Size and voltage still filter separately. What "primarily" now decides is composition, which is the question the megawatt figure used to answer.
NERC paired that change with a clarification that large industrial and commercial loads, manufacturing facilities and large hospitals among them, are not captured. A site that has computational load without being primarily computational does not meet the criteria. That is a cleaner test than a de minimis megawatt figure. It is also a more interpretive one, and interpretive tests get argued at the margin.
The Thresholds Moved Up
Every element of the April proposal changed.
| Element | April 1 proposal | August 19 revision |
|---|---|---|
| Size threshold | 20 MW | 50 MW |
| Voltage threshold | 60 kV | 100 kV |
| Computational load minimum | 1 MW de minimis | Removed, replaced by "primarily" in the Site definition |
| Connection | Single point of interconnection | One or more points of connection |
| Measurement basis | "Aggregate connected Load capability" | "Connected Load," meaning all electrical equipment at the site |
| Functional registration | Computational Load Entity | Computational Load Owner and Computational Load Operator |
NERC's justification is the reasoning a future registration dispute will cite. Expanded analysis, extended to sites planned to be operational by the end of 2027, let NERC conclude the threshold could rise to 50 MW while still addressing the aggregate risk from data center sites and clusters.
The connection change compounds the threshold change. Moving from a single point of interconnection to one or more points of connection widens what aggregates into the 50 MW figure at the same time the figure itself rises. A campus that would have missed the old test on configuration can meet the new one on aggregation.
Voltage Is Measured Where You Might Not Expect
This is the one most likely to produce a wrong answer inside an organization that thinks it has run the test.
NERC clarified that the criteria reference the Bulk Power System connection of the electrical equipment serving the site, adding language for load "supplied through electrical equipment" connected at 100 kV or above, and stated this applies irrespective of the site's own service or interconnection agreement voltage. A site served at distribution voltage through a stepdown from a 100 kV or higher connection is therefore not automatically outside the criteria.
The number on your service agreement is not the number the criteria ask about. Confirm the precise wording against the posted Appendix 5B redline before relying on it for a specific site.
Who Should Evaluate Applicability
Utilities serving or courting computational load. You are already the registered entity on your side of the interface. The registry criteria decide which of your customers may become co-registered, and the FAC-001-5 and FAC-002-5 updates reach your interconnection requirements directly. A territory with no computational load today is not outside this. The Level 3 Alert, distributed to planners, owners, and operators on the utility side, already reaches entities that could feasibly receive an interconnection request within two years. Absence is a clock rather than an exemption.
Computational load owners. If your organization owns and maintains a Computational Load Site, or holds the lease that governs the site and its electrical equipment, the Owner registration is aimed at you. The registration test turns on ownership and maintenance of the Site, not on the lease itself; the lease is where the question of who performs, who reports, and who pays gets worked out commercially. The 50 MW figure is connected Load across all electrical equipment at the site, not IT nameplate, and not contracted capacity.
Computational load operators. If your organization operates a site day to day without owning it, the second registration is aimed at you, and it may reach you where the owner registration lands on a different company.
Hosts, colocation providers, and their tenants. Removing the "hosts end-users" language does not resolve a multitenant arrangement. It relocates the operational and commercial questions into your contracts, where nobody has drafted for them. Performance, data access, cost allocation, and indemnity all land there. Registration itself still turns on the approved criteria applied to the specific arrangement, not on what a commercial agreement says.
Five Questions Every Organization Should Ask
Applicability
Does any site we own or operate meet the revised test, and can we show our work?
Run every candidate site against three elements together. Those are 50 MW of connected Load, a Bulk Power System connection at 100 kV or above through the serving electrical equipment, and a site that is primarily computational. Aggregate across one or more points of connection rather than looking for a single interconnection point.
Then run it again against your 2027 and 2028 build plan, since NERC's own analysis extended to sites planned to be operational by the end of 2027. A planned expansion that would take a site above 50 MW may not create a present registration obligation, but it creates a readiness question today. Organizations should know when the threshold will be crossed, which configuration will cross it, and which entity will own and operate the qualifying site.
Operating authority
Who is the Owner, who is the Operator, and are they the same company?
Name the entity that owns and maintains the site and its electrical equipment. Name the entity with operating authority over that equipment day to day. If those are different companies, the arrangement could produce two registrations, divided obligations, and a coordination problem inside contracts that predate either function. Registration still requires applying the approved criteria to the specific arrangement.
Data
Can we produce what the standards will ask for, on their timelines?
Interconnection and modeling data. Operational data and communications. Protection coordination and disturbance monitoring. For each, ask who holds the data, what system it lives in, and how long it takes to assemble. Dynamic fault recorders and access to them, telemetry paths, and model validation records are the recurring gaps.
Contracts
What do our existing agreements say about who performs, who reports, and who pays?
Pull the interconnection agreements, colocation leases, and operations and maintenance contracts. Find the provisions assigning responsibility for grid-facing performance, data provision, ride-through, and curtailment.
Then ask the question those documents were never written to answer. If a Reliability Standard applies to the owner or the operator directly, does this contract help or does it conflict? The contract does not decide registration. The approved criteria and registration process do. Contracts can allocate performance, access, cost, indemnity, and coordination responsibilities, but they cannot transfer the registered entity's regulatory accountability.
Compliance evidence
If a Regional Entity asked today, what would we hand over, and who signs it?
Once the applicable standards become effective, registration brings the entity into the Electric Reliability Organization (ERO) compliance and enforcement apparatus, including evidence obligations, self-reporting, mitigation, and potential financial penalties.
Ask whether your organization has anything resembling an evidence file for grid-facing performance, and who the accountable executive is. NERC declined to create a computational-load-specific exception process, so materiality arguments run through the existing Registration Review Panel, which will want documentation.
Three More Questions, by Role
These three belong to specific people, and each is currently unowned in most organizations I talk to.
Critical Infrastructure Protection (CIP) Senior Managers and delegates
Where does the computational load interface touch our CIP-002 categorization, and can we defend that categorization today?
Nothing in this tranche extends CIP to computational load, and this question is not a prediction that it will. It is about the interface obligations already accruing on your side.
The telemetry points, the fault recorder access, the shared protection and control data, and any Remedial Action Scheme participation at a computational load interconnection may touch systems you have already categorized or create new interfaces that must be evaluated against the existing categorization. Map those and document where the categorization gets hard to defend. Name the delegate who owns this boundary, since planning departments have been carrying it by default and a delegation that exists only by default is not evidence.
Governance, risk, and compliance teams
Which of our registers, control libraries, and calendars carry a line for this, and who owns each one?
A new functional registration changes the regulatory profile of the entity. It is not a project in the compliance department. Check whether your risk register carries a computational load line with a named owner. Check whether your internal controls library tests grid-facing performance, data provision, or interface coordination.
In a corporate family where the owner and operator functions could land on different legal entities, ask which entity's program would carry which obligation, and whether those programs talk to each other.
Capital allocators
Does the FY2027 plan carry the interface spend, and is there a reserve for what the criteria have not yet decided?
For affected sites, the most likely spending categories sit at the interface. Telemetry and supervisory control and data acquisition (SCADA) buildout, dynamic fault recorders and access to them, protection and control upgrades, and systems for collecting and exchanging modeling data.
Some organizations may previously have treated those as deferrable planning improvements. The proposed standards move them closer to regulatory expectations, strengthening the case for evaluating them during the current planning cycle. The contingent spend depends on where registration lands and what the standards ultimately require, so name a reserve line rather than a number you cannot yet defend.
What to File, and by When
By September 3, 8:00 p.m. Eastern. Join the ballot pool so you can vote when balloting opens. Confirm your Registered Ballot Body credentials and your entity's segment and designated voter first; large end-use load participants should specifically check Segment 7 (Large Electricity End Users), while utilities and other registered entities will sit in their own segments.
September 9 through 18. The initial ballots and non-binding poll are open to members of the ballot pool.
By September 18, 8:00 p.m. Eastern. File comments on both packages, through two different channels. Standards comments go through the Standards Balloting and Commenting System. Rules of Procedure comments go by email to ROPcomments@nerc.net. Address the thresholds if a site of yours sits near 50 MW or 100 kV. Address the owner and operator split if your arrangement does not divide cleanly. Address the site definition if "primarily" is ambiguous for your configuration.
Generic support is a wasted filing. NERC revised the criteria substantially in response to specific, configuration-level comments, which is evidence that specificity works on this record.
The Bottom Line
NERC did not just propose standards on August 19. It proposed the population those standards will govern, and changed the shape of that population from April. One entity became two. The thresholds rose while the aggregation rules widened. A single word, "primarily," replaced a megawatt floor. Voltage is measured at a connection your service agreement may not name.
Each of those is a registration question, and registration determines which downstream obligations may become yours and which organization will be expected to perform them. September 18 is when the most influential public-comment window closes. The August 27 NERC webinar should add detail on the standards themselves. I will take up the requirement language in CLO-001 through CLO-003, what the record now says about workload composition, and where the AI Reliability Boundary sits after the webinar.
Join Us September 3
On an upcoming webinar, NERC O&P expert Earl Shockley and I will walk these questions through the configurations that make them hard for utilities, computational load owners, operators, and hosts. The session runs the same day the ballot-pool join window closes.
Sources and Further Reading
NERC Rules of Procedure: Appendix 2, 5A, and 5B revisions, Consideration of Comments
Project 2026-02 Computational Loads: posted drafts, comment form, ballot pool
FERC order, Docket No. RD26-7-000, 196 FERC ¶ 61,031, July 16, 2026
August 13, 2026 industry CEO letter from Jim Robb
PJM July 22 load-transfer event, Operating Committee presentation, August 6, 2026, and PJM's summary of the Operating Committee review
Large Loads Action Plan: August 13, 2026 industry CEO letter, Level 3 Alert materials'
Large Loads FAQs and Checklist for Computational Load Entities: dates, standard numbers, ballot enrollment
NERC Standards, Compliance, and Enforcement Bulletin, August 24, 2026: Project 2026-02 ballot-pool join window (August 19 to September 3), initial ballot and non-binding poll window (September 9 to 18), and ROP registry-criteria comment deadline (September 18)
NERC Rules of Procedure, Appendix 3D: Registered Ballot Body Segment definitions, including Segment 7 (Large Electricity End Users)
Read the Rest of This Series
NERC Computational Load Standards: FERC Sets December 2026 Deadlines
NERC Computational Load Alert: August 3 Deadline for Utilities 2026
This article analyzes proposed language that remains subject to comment, balloting, NERC Board approval, and FERC review, and it may change before anything becomes enforceable. It is provided for general information and does not constitute legal advice. Registration determinations, applicability, and compliance obligations depend on the specific facts of an organization's configuration and arrangements. Consult qualified counsel and your Regional Entity.
