By: Jean-Phillippe Beaudet
Our Response to NERC
On September 18, The Digital Chamber filed comments on NERC Project 2026-02, the first reliability standards written for computational loads: AI data centers, high-performance computing, and Bitcoin mining. The three standards cover interconnection, real-time operations, and disturbance monitoring. They apply to sites of 50 MW or more connected at 100 kV or above.
TDC supports the goal. Grid planners need to know how these loads behave, and developers need to know what the grid expects of them. But campuses with multiple connections, operating out of one site, need additional clarity to ensure that reporting obligations aren’t inappropriately levied on smaller partners at a site – a key point of our response. Additionally, TDC introduced the concept of decentralized distributed computational loads, and offered recommendations for new classifications in preparation for future mesh network buildouts.
Rules That Work for Every Operator
Compute is among the fastest-growing sources of demand on the grid, and projects need clear, workable rules. We see two areas where added clarity would help NERC reach its reliability goals:
- Right-size costs across facility sizes. Modeling, monitoring, communications, and training cost about the same at a 50 MW site as at a 500 MW site, or roughly ten times more per megawatt. Costs that scale with system impact would keep small and mid-size facilities in the market.
- Give distributed compute a clear home. Independently owned installations increasingly sell capacity into shared networks. Clarifying whether joining one makes a 2 MW owner a NERC-registered entity, and who is responsible when coordinated load moves across regions, would give owners and planners the same certainty.
NERC is finalizing Phase 1 while its roadmap sets Phase 2 priorities through 2027. TDC will stay engaged so NERC has the best information on current and future deployments.
TDC’s view
Reliability obligations should attach to the controller of electrical demand. Our comments ask NERC to:
- Treat location as decisive. Common ownership, a shared scheduler, or a shared workload arrangement should not merge separate installations into one regulated site.
- Define the aggregator by what it does. We proposed three new terms – Distributed Compute Resource, Dispatch Coordination, and DCR Aggregator – that place obligations on the entity coordinating load, modeled on FERC Order No. 2222 for distributed energy.
- Separate control from commerce. Selling capacity a site can decline is not a change in grid behavior and shouldn’t trigger a restudy. Transfer of control, however, should.
- Protect exit rights. Small operators must be able to leave an arrangement freely. Otherwise, the registered entity gains commercial control over its participants’ access to the grid.
- Keep compliance proportionate. That means 18 to 24 months for first-time registrants, a materiality test for model re-verification, triggered data retention, and data limits tied to electrical behavior.
We also encouraged NERC to approach fast workload transfers between regions as a capability planners can see and coordinate, rather than only a risk to manage.
Getting these details right will help smaller operators, who carry the heaviest per-megawatt burden, build and compete alongside the largest campuses.
What’s next
NERC’s drafting team will review comments before revising the standards, and we look forward to working with the team and other stakeholders through that process. TDC has also recommended a dedicated Phase 2 workstream on coordinated distributed compute through the Large Loads Working Group. Our filing includes a supporting annex, “Distributed Compute Resources and the Aggregation Gap,” which details that framework.
TDC shares NERC’s objective: computational growth that proceeds alongside a reliable and resilient electric grid. Members running or planning computational load should contact the TDC policy team to share how these standards affect them.
Reach out to Policy@digitalchamber.org with any questions or comments.