By Earl Shockley, President and CEO, INPOWERD LLC
Trust • Accountability • Service
The North American electric grid is embarking on an intriguing yet pivotal new phase, characterized not by gradual demand growth, but by sudden and substantial large loads that surpass our transmission planners’ ability to accurately model the system. Throughout my extensive 40 plus years of observing the evolution of the Bulk Power System, I have never witnessed a convergence of risk, complexity, and urgency of this magnitude.
Large loads are no longer rare occurrences; they have become the new norm. The shift is rewriting the rules of reliability. In this blog, I will detail the key challenges that the electric industry and transmission planners are currently facing.
Grid Transformation: The Target That Keeps Moving
NERC’s 2026 ERO Enterprise CMEP Implementation Plan makes one reality unmistakably clear: grid transformation risk is now a top-tier priority. The Plan emphasizes the rapid expansion of substantial loads originating from data centers, industrial electrification, artificial intelligence (AI), clusters, and cryptocurrency, which significantly impact transmission planning, modeling, and long-term adequacy.
Transmission Planners have always lived with moving targets. But today the target isn’t just moving; it’s accelerating, multiplying, and shapeshifting.
Traditional long-range forecasts assumed load patterns that evolved slowly over decades. Those days are gone. Modern large loads:
- Arrive at unprecedented scale and speed
- Demand high energy availability 24/7/365
- Cluster in geographic pockets with limited existing infrastructure
- Require dense, high-capacity transmission backbones not designed for modern digital industries
NERC’s recent assessments and reports echo this challenge:
- The 2024-2025 Long-Term Reliability Assessment (LTRA) highlighted unprecedented load growth from data centers, electrification, and industrial transformation, with some regions expecting multi-gigawatt increases within 3-5 years.
- The 2023 and 2024 State of Reliability Reports (SORA) documented a rising frequency of areas approaching transmission and resource adequacy limits well before large loads reached full scale.
- The RISC Reliability Priorities Reports (2023-2025) flagged load growth as a strategic industry risk, noting that traditional planning assumptions no longer reflect the realities of high-density, high-consumption digital loads.
- NERC’s Special Assessments on Grid Transformation and Energy Adequacy - stressed that future events would occur outside historical patterns, requiring a broader range of probabilistic and scenario-based planning approaches.
Put simply: Transmission planners are now trying to forecast the future at a time when the future refuses to behave like in the past.
The Weight on the Planner’s Shoulders
Transmission planners bear the first, and often heaviest, burden of large load growth. The 2026 CMEP Plan explicitly maps load-growth concerns to key NERC Reliability Standards requiring heightened scrutiny, taken together, these standards paint a picture:
- TPL-001-5.1 - Transmission system planning for steady state and stability
- MOD-025, MOD-026, MOD-027 - Accurate modeling of equipment and dynamic performance
- MOD-031 & MOD-032 - Load forecasting and data reporting
- FAC-001 & FAC-002 - Interconnection studies for new facilities
Earlier NERC assessments and reports reinforce these concerns:
- The LTRA warns that load uncertainty is now the leading driver of planning risk across multiple regions.
- The SORA notes that inaccurate load models have already contributed to operational constraints, voltage instability risks, and elevated emergency alerts.
- NERC’s Inverter-Based Resource and Modeling Special Assessments highlight the cascading risks created when new large loads interact with IBR-heavy systems.
The following trends converge to create a planning landscape unlike anything the industry has experienced historically.
- Uncertainty in Forecasting - the NERC LTRA shows that large-load forecasts now swing by gigawatts within a single planning cycle. Industries such as AI computing and hydrogen processing often double their projected demand with little warning. Many new loads are speculative until the moment construction begins. Businesses can shift, cancel, or double capacity without warning. Planners must prepare multiple scenarios simultaneously, each requiring different transmission expansions.
- Compressed Timelines - the RISC report notes that commercial development timelines now grow faster than transmission facilities can be planned or built. This mismatch is becoming a structural reliability risk. Data centers and industrial loads may demand energization in 18-36 months. Historically, major transmission projects require 7-10 years. This mismatch places planners in an impossible vise: build quickly enough to meet commercial demand, but thoroughly enough to maintain reliability.
- Localized Impacts - NERC’s special assessments show that large loads tend to cluster where infrastructure is weakest, creating voltage depressions, thermal overloads, and insufficient reactive support. Large loads don’t spread evenly. They cluster, creating hot spots where existing infrastructure is overwhelmed. These load pockets can erode voltage stability, reduce reactive margins, and trigger cascading thermal overloads if not modeled and mitigated properly.
- Modeling Gaps - the SORA repeatedly identifies inaccurate or incomplete models as a pervasive industry issue, one amplified when load curves change rapidly. Interconnection studies require accurate models, from Generator Owners to Balancing Authorities, and NERC repeatedly highlights inconsistencies and gaps in interconnection modeling. Planners must reconcile data that often arrive incomplete, outdated, or overly optimistic.
This results in transmission planners being asked to chart a map while the terrain shifts beneath them. Planners must now model the future with precision while the future refuses to stand still.
Large Loads and the Reliability Paradox
This new class of electric grid customers reinforces a paradox I’ve written about for years:
The electric grid has become essential to safety, security, and quality of life and at the same time it is becoming more uncertain. Large loads increase economic vitality, innovation, and electrification progress, but they also heighten operational fragility when not matched with proportional transmission development.
In response to this increasing risk, NERC issued in September 2025, a Level 2 Alert on Large Loads, the Alert requires registered entities to formally assess their readiness to manage the reliability risks posed by emerging large loads and to submit a documented response to NERC explaining their findings. Entities must evaluate whether their interconnection, planning, modeling, commissioning, and operational practices adequately address large-load behavior, including voltage sensitivity, tripping characteristics, and data accuracy, and must define and implement corrective actions where gaps are identified.
The Alert also requires review of operational coordination, monitoring, and event analysis involving large loads. Industry responses are due January 28, 2026, after which NERC will analyze the submissions and report results to FERC, making the Alert a substantive accountability exercise rather than an informational notice.
In short: the Alert makes clear that emerging large loads are no longer a passive demand; they introduce dynamic, system-level risks that must be explicitly studied, modeled, coordinated, and monitored to preserve Bulk Power System reliability.
NERC’s risk assessments also underscore that inadequate modeling and slow expansion of transmission infrastructure could lead to:
- Greater potential for IROL exceedances: SORA: operators are increasingly encountering narrower operating margins.
- Sudden, Simultaneous Load Loss: NERC Alert: Large loads, particularly data centers, AI facilities, and crypto mining operations can rapidly reduce or trip load in response to voltage or frequency disturbances. When multiple large loads respond similarly, the resulting simultaneous load loss can destabilize the system, worsen disturbances, and complicate operator response.
- Voltage Sensitivity and Dynamic Behavior: Special Assessments: increasing sensitivity of IBR-heavy systems to sudden large-load behavior. Many large loads are highly voltage-sensitive and exhibit fast, non-linear behavior that is not well understood or consistently modeled. This creates risk during contingencies, where actual system response may differ significantly from planning assumptions.
- Energy insufficiency during extreme weather: LTRA: seasonal assessments show growing year-round risk windows.
- Reduced situational awareness: RISC/NERC Alert: Planners and System Operators face unprecedented uncertainty in forecasting and real-time operations. In some cases, system operators lack real-time visibility, clear communication protocols, or defined operating expectations for large loads, increasing the risk of delayed or ineffective response during system events.
The bottom line: The load is rising faster than our legacy planning frameworks can evolve. Large loads don’t just stress energy supply; they reshape the entire reliability landscape.
Why Transmission Planners Need More Than Reliability Standards - They Need Support
Compliance is necessary, but not sufficient. Compliance requirements alone cannot solve the scale of this problem. NERC’s RISC and SORA reports repeatedly state that the risk landscape has outgrown traditional deterministic planning. Transmission planners now need:
- Better Data Inputs - the LTRA and modeling assessments emphasize that load-serving entities often lack detailed operational characteristics for new loads until late in the process.
- Earlier Engagement with Load Developers - special assessments recommend structured early identification programs; some regions have already begun implementing load interconnection triage teams.
- Cross-Discipline Coordination - the RISC report warns that siloed planning, protection, and operations functions create blind spots that are now reliability risks.
- Workforce Expansion and Skill Development - every recent NERC report, from SORA to the RISC report, notes a growing workforce shortage in planning, modeling, protection engineering, and cybersecurity.
- Internal Controls That Keep Models Accurate Over Time - the SORA has found that entities often fail not at initial modeling, but at sustaining accurate models as systems evolve. Strong internal controls can prevent “modeling debt”, a silent reliability risk that compounds over time.
A New Planning Mindset for a New Grid Reality
As a former regulator and long-time advisor to utilities and grid operators, I believe the industry must embrace a new mindset:
- Treat Large Loads as System-Defining Events - special assessments show they reshape interconnection topology and system strength in ways like major new generation facilities. They must be studied with equal rigor.
- Plan for Maximum Reasonable Load Scenarios - the LTRA warns that underestimating large-load growth is now one of the fastest-growing contributors to resource adequacy risk. Conservative planning today avoids emergency triage tomorrow.
- Challenge Historical Assumptions - the SORA has documented that historical patterns no longer represent future risk conditions. Yesterday’s “extreme conditions” are becoming today’s baseline.
- Build Flexibility into Every Study - NERC’s grid transformation assessment urges planners to incorporate adaptive, scenario driven methods, not static, point-in-time studies. No single solution will remain optimal across a decade of rapid technological change.
Large loads are not going away. In fact, they are accelerating. The question is whether we allow them to become unmanageable burdens or use them as catalysts to modernize our planning frameworks. This is a critical moment for the industry, and the choices we make now will shape grid resilience for decades to come.
The INPOWERD Perspective: Turning Burden into Blueprint
At INPOWERD, we help entities navigate this new era by:
- Addressing NERC Alert obligations
- Strengthening internal controls for modeling, forecasting, and planning
- Supporting risk-informed interconnection processes
- Developing defensible planning documentation aligned with CMEP risk elements
- Training planners and executives on emerging load and modeling challenges
- Applying insights from SORA, LTRA, RISC, and NERC special assessments to real-world decision making
