Commissioner-led Reliability Technical Conference

NERC Presentation on the State of Reliability 

• Jim​ Robb​, President and Chief Executive Officer​, North American Electric Reliability Corporation

Panel 1: Leadership Perspectives on the State of the Bulk-Power System and Priorities

As the electric industry navigates an evolving resource mix and increasing demand, ensuring grid reliability remains the defining regulatory priority.  The exponential growth of data centers and the increasing frequency of extreme weather events add complexity to this challenge.  Industry leaders will explore the risks, trends, and key priorities shaping the future of grid reliability and resilience and discuss potential actions and strategies to address these challenges.

This panel may include a discussion of the following topics and questions:  

1. What are your top reliability concerns over the next three years?  What trends and risks identified in NERC’s 2025 State of Reliability Report and the 2025 ERO Reliability Risk Priorities Report should the Commission prioritize and how should the Commission endeavor to address these risks?  What actions should the Commission take to address those identified reliability priorities?
2. NERC’s 2024 Long-Term Reliability Assessment identifies the need for generation and transmission additions to replace retiring generation.  What progress has been made and what refinements are needed to ensure reliability, especially during the most critical hours of extreme weather events?  What additional steps can the Commission take to address this concern?
3. We have seen significant improvements in the grid’s performance during recent extreme weather events, in part due to industry’s efforts to improve generator performance following the recommendations from the joint FERC-NERC inquiries of previous extreme cold weather events as well as the implementation of Reliability Standard EOP-012 (Extreme Cold Weather Preparedness and Operations).  What additional measures should we take to sustain this improved grid performance during extreme weather? 
4. The U.S. electric grid continually faces evolving cyber and physical security threats.  Ensuring the security of the electric grid is critical for its reliability and resilience.  Are the current Critical Infrastructure Protection (CIP) Reliability Standards sufficient for the current threat landscape that includes advanced persistent threats (in which an intruder remains undetected in a network to steal sensitive data over a long-time frame) to ensure the security of the U.S. electric grid?  What physical security and cybersecurity issues are not addressed by the current CIP Reliability Standards?  Do the CIP Reliability Standards do enough to protect the U.S. electric grid from sophisticated nation-state sponsored threat actors?  What additional actions should the Commission and NERC take to further fortify the grid from physical or cyber attacks? 
5. In Order No. 901, the Commission approved a three-year plan for NERC to develop Reliability Standards to address the challenges and reliability risks posed by the increasing penetration of inverter-based resources (IBRs), including solar, wind, and battery storage technologies, on the grid.  These include accurate data sharing, model validation and the establishment of performance standards for IBRs to ensure they can maintain operation during grid disturbances.  How will NERC and industry assess whether the new IBR Reliability Standards meet this goal?  Should Battery Energy Storage Systems (BESS) play a larger role in supporting reliability and, if so, how?

Confirmed Speakers:

• Jim Robb, President and Chief Executive Officer, North American Electric Reliability Corporation
• J. Arnold Quinn, Sr. Vice President, Regulatory Policy, Vistra Corp.
• Tricia Pridemore, Commissioner, Georgia Public Service Commission and President, National Association of Regulatory Utility Commissioners
• Matthew G. Holtz, Vice President, Transmission Operations, Invenergy
• Carlos Casablanca, Managing Director, Distribution Planning and Analysis, American Electric Power   
• Gil Quiniones, President and Chief Executive Officer, ComEd
• Kodwo Ghartey-Tagoe, Executive Vice President and Chief Executive Officer, Duke Energy Carolinas

Panel 2: Ensuring Reliability with Large Loads

The North American power system faces a significant challenge:  emerging large loads, primarily data centers, are seeking to connect to the Bulk-Power System at an unprecedented pace and scale.  These large loads have the potential to impact reliability, as demonstrated by events involving voltage-sensitive load reduction observed in both the Eastern Interconnection and the Electric Reliability Council of Texas (ERCOT).  NERC’s Large Load Task Force (LLTF) recently published a white paper, Characteristics and Risks of Emerging Large Loads[1] analyzing the risks that large loads pose to Bulk-Power System reliability.  Among other things, the white paper recommends that NERC assess gaps in existing practices and identify potential mitigations to these emerging risks.

 This panel may include a discussion of the following topics and questions:   

1. What is the status of NERC’s efforts to address this matter?  Discuss the reliability risks posed by large loads, especially when the large load rapidly fluctuates or is suddenly taken off-line.  Please describe the potential need to update protection system requirements in Reliability Standards due to these large load fluctuations.
2. Do system planners have the necessary tools and data such as dynamic models to properly simulate and address the risks associated with large load behavior on the Bulk-Power System?  What strategies can help utilities better understand and manage the increased demand from the integration of concentrated data centers and other similar types of large loads into the grid? 
3. How can utilities and grid planners minimize and manage the uncertainty associated with the anticipated timing and location of large loads (e.g., due to “location shopping” or project cancellations) in demand forecasts for resource adequacy and transmission planning?
4. Forecasting models have historically leaned on predictable past behavior.  How can the unfamiliar load profile of emerging large loads, such as artificial intelligence (AI) data centers with their rapid on-off cycles and fluctuating consumption patterns, be accurately modeled for the operations time frame?  How should short-term forecasting models incorporate the behavior of these large loads?
5.  There has been discussion in industry on whether thresholds for what is considered a “large” load may be helpful in the development of Reliability Standards.  Should there be a universal size threshold for a load to be considered “large”?  What factors would go into determining whether such a load would require different reliability considerations in operations and planning?  Are there unintended consequences of setting a threshold, and how should entities account for the relative size of the load to the local system and Interconnection?
6. What rules or approaches, including new or modified Reliability Standards (for the transmission operators, balancing authorities, and planners), are needed to address the reliability risks posed by large loads? 
   1. How can improved operational visibility, monitoring, and coordination be established for large loads to prevent unexpected demand swings and ensure reliable grid operations?
   2. What technical solutions or contractual/regulatory mechanisms can address the risks posed by large load ramp rates (e.g., cycling consumption on and off in less than a minute, ramping from zero to hundreds of MWs in short timeframes)?  Can solutions other than generation, such as BESS, address these swings?
   3. How can the voltage and frequency “ride-through” behavior of large loads during disturbances be improved?  Should the Commission and/or NERC establish ride-through requirements for large loads so that they do not unexpectedly trip off-line?  Should some type of requirement be placed on large loads to limit changes in demand and prevent widespread disconnections particularly in light of the unexpected scale of recent load loss events?

Confirmed Speakers:

• Mark Lauby, Sr. Vice President and Chief Engineer, North American Electric Reliability Corporation
• Jennifer Curran, Sr. Vice President, Planning & Operations, Midcontinent Independent System Operator
• Jason Connell, Vice President, System Planning, PJM Interconnection
• Matt Gardner, Sr. Vice President, Dominion Power
• Travis Wright, Vice President, Energy and Sustainability, QTS Data Centers
• Chris Matos, Strategic Negotiator, Energy Markets, Google, LLC