Deadline to Act: August 3, 2026
By now, utilities and grid stakeholders are aware of NERC’s Level 3 Alert, issued on May 4, 2026. NERC uses a three-level alert system, with Level 3 designated as “Essential Actions.” This recent alert addresses the reliability risks posed by computational loads, such as data centers, on North America’s bulk power system (BPS). NERC identifies seven Essential Actions covering modeling, system studies, measurement devices, commissioning, operations, protection, and controls. The key decision is how to properly implement these Essential Actions through a coordinated, end-to-end plan. Such a plan requires alignment across these seven workstreams, supported by sound engineering judgment, validated technical inputs, and a clearly defined execution timeline.
EPE Helps Turn Essential Actions into Execution
We at EPE have technical expertise and proven tools to address each of the seven Essential Actions. Below is our preliminary guidance on how registered entities can develop a clear, coordinated response to each Essential Action, grounded in our experience assessing the impacts of over 125 GW of load interconnections.
Essential Action #1
Transmission Planners (TPs) and Planning Coordinators (PCs) should develop a detailed list of modeling data, settings, and parameters needed from computational loads and distribute this to Transmission Owners (TOs) in their footprint.
- EPE’s guidance: EPE has been at the forefront of establishing performance requirements for large loads including through industry-leading engagements with Energy Systems Integration Group (ESIG) and directly with our utility partners. The first step is establishing a standardized data collection framework for computational load facilities to ensure consistency across TPs, PCs, and TOs. This framework should define the minimum technical data and modeling requirements necessary to accurately represent computational load behavior in both steady-state and dynamic reliability assessments. We help clients with developing comprehensive data request templates that capture all essential modeling inputs, including electrical characteristics, load composition, dynamic behavior, protection and control settings, operating logic, and performance parameters. Our services also include model specification guidelines, data validation frameworks, and quality assurance processes to verify and resolve incomplete or inconsistent inputs before integration into planning models. This approach improves model fidelity, enhances the accuracy of interconnection and reliability assessments, reduces study risk, and supports compliance with evolving NERC guidance and industry best practices.
Essential Action #2
TPs and PCs should study their system with additional considerations for computational loads.
- EPE’s guidance: Planning studies should be expanded beyond the typical steady-state planning studied to address: 1) progressive growth of computational loads, 2) their dynamic behavior under normal operation and disturbance conditions, and 3) the system-wide impact of large load loss on voltage and frequency stability. This reinforces the need for detailed transient stability and electromagnetic transient (EMT) reliability studies. EPE supports clients in evaluating load growth, disturbance and fault response, dynamic behavior, and loss of load to ensure system studies reflect the realistic operation behavior of these facilities, rather than just relying on simplified assumptions. This includes assessing the impact of large load facilities on voltage control, voltage stability, rotor angle stability, and subsynchronous phenomena including torsional and controller interactions.
Essential Action #3
PCs should revise their definition of “qualified change” that triggers a review of local area protection, stability limits, and other reliability studies to account for computational load.
- EPE’s guidance: Change thresholds should be clearly defined for when modifications in computational load are significant enough to require further review. We help clients in establishing structured criteria based on load composition, control system modifications, operating profile variations, and facility repurposing, ensuring that review triggers are consistent, technically justified, and uniformly applicable across planning projects.
Essential Action #4
TOs should establish a commissioning process for computational loads.
- EPE’s guidance: The commissioning process should be established to verify that as-built computational load facility models align with the input data and planning assumptions used during the system studies. We support clients in establishing structured commissioning frameworks, including model validation procedures, coordination checklists between the TO and the computational load customer, and post-energization data verification to confirm consistency between as-built facility models and planning models. We bring proven expertise in Hardware-in-the-Loop (HIL) testing, offering deeper insights and greater assurance of facility performance. This enables a repeatable and controlled process for bringing new computational load facilities online with improved modeling accuracy and greater operational confidence.
Essential Action #5
TPs and PCs should study and implement corrective actions with TOs on the system side of the interconnection to ensure no non-consequential loss of firm load for computational load from normally cleared non-bus faults.
- EPE’s guidance: This requirement extends beyond identifying potential issues: it requires practical mitigation planning. We support clients in assessing fault response performance, identifying system-side vulnerabilities, and evaluating corrective actions that reduce the risk of unnecessary load loss while preserving overall system reliability and operational flexibility.
Essential Action #6
TOs should install and utilize dynamic fault recording devices to capture and share computational load facility electrical performance during system disturbances.
- EPE’s guidance: Measurement devices provide critical visibility into computational load and help monitor its characteristics and behavior during different system conditions. We support clients in 1) identifying appropriate measurement device technologies to install, 2) specifying the minimum recording rate (i.e., number of recorded samples per second) for adequate dynamic capture, 3) determining the data sharing requirements with the TO, and 4) identifying optimal installation locations to ensure accurate monitoring of the facility performance during disturbance.
Essential Action #7
Transmission Operators (TOPs), Reliability Coordinator (RCs), and Balancing Authorities (BAs) should establish Interpersonal Communication capabilities with computational loads to improve their situational awareness and joint operating procedures to ensure the reliable operation of the BPS during planned and emergency conditions.
- EPE’s guidance: Operational readiness relies on robust and pre-established reliable communication pathways that remain effective during both normal and abnormal system conditions. We support clients in defining communication architectures, coordination protocols, and cybersecurity requirements to ensure effective information exchange between grid operators and computational load facilities, enabling timely and coordinated response during planned outages, faults, and system disturbances.
Move from Requirement to Execution
Computational loads are changing how the industry plans, studies, commissions, and operates the grid. At EPE, it is our view that the current situation does not need to result in uncertainty or reactive decision-making.
With EPE's experienced engineering approach, registered entities can use NERC’s seven Essential Actions to strengthen modeling practices, improve planning and operational visibility, and build a more disciplined foundation for reliable large load integration. The organizations best positioned for this shift will be the ones that treat these actions not as isolated requirements, but as an opportunity to align planning, operations, protection, and controls around a more complete view of system performance.
Additional Reading
EPE has been extensively studying, evaluating, and making recommendations regarding large loads and data centers. Our most recent publications explain our thinking and approach:
EPE Expert Leads ESIG Report on Large Load Performance Requirements
How Grid Operators and Customers Are Working Together to Solve a New Era of Large Loads
The Growth and Risk of Large Load Interconnections
If your team is preparing its response to NERC’s Level 3 Alert, EPE can help you scope the work, align the right technical disciplines, and execute a plan that stands up to scrutiny.
Complete the contact form below.
.jpg&w=3840&q=75)
