Modules · Compliance studies · Module 085
CLO-001-1 Computational Load Interconnection, Studies, & Modeling Data
Interconnection studies, modeling data and Model Verification for data-center sites under NERC's proposed CLO-001-1, including the duties of a Generator Owner whose plant connects one.
About this module
What this module covers.
The new CLO-001-1 standard (Computational Load Interconnection, Studies, & Modeling Data) applies to Computational Load Sites with a total connected Load of 50 MW or more supplied through electrical equipment connected at 100 kV or above from one or more points of connection. A Computational Load Site is one or more buildings, structures, or installations at a single location that primarily contains information technology infrastructure used for creating, executing, and delivering software applications and services, artificial intelligence training, deployment, and delivery, cryptocurrency mining, or other computational activities at a data center, and that is supplied through electrical equipment connected to the Bulk-Power System. The Computational Load Owner (CLO) must coordinate and cooperate with the Transmission Owner, Generator Owner, Distribution Provider, and Transmission Planner or Planning Coordinator on interconnection studies for new sites and for existing sites seeking a qualified change as defined by the Planning Coordinator, including providing study data (R5). The CLO must provide steady-state, dynamics, and short-circuit modeling data to its Transmission Planner and Planning Coordinator according to their data requirements and reporting procedures, with a written confirmation sufficing for unchanged data (R9); respond to written technical concerns about that data within 90 calendar days, or a longer period the notifying Planning Coordinator or Transmission Planner agrees to, with updated data or a technical explanation (R10); and provide Model Verification documentation showing that the configurable, site-specific model parameters represent the design and settings of the in-service equipment, initially within 365 calendar days after the in-service date, within 180 calendar days after a hardware, software, firmware, or setting change that alters the dynamic response, and subsequently within 10 calendar years of the most recent transmittal (R11). A Generator Owner that fully executes an Agreement to study interconnecting a Computational Load Site to its existing Facility used to interconnect to the Transmission system must document Computational Load Site interconnection requirements, including procedures for coordinating with the applicable Transmission Owner and Distribution Provider, and make them available on request within 45 calendar days of full execution of a study Agreement (R3), and must coordinate and cooperate with its Transmission Planner or Planning Coordinator on studies of those interconnections, including providing data (R6).
CLO-001-1 is pending FERC approval; FERC has directed NERC to file computational load Reliability Standards by December 31, 2026. If FERC approves it, the standard becomes effective in the United States on the first day of the first calendar quarter after the effective date of FERC's approval order, or as FERC otherwise provides. The implementation plan phases compliance: the Planning Coordinator and Transmission Planner requirements (R7, R8) at 3 months, the Transmission Owner, Distribution Provider, and Generator Owner interconnection requirements (R1-R3) at 6 months, and the study, modeling data, technical-concern, and Model Verification requirements (R4-R6, R9-R11) at 9 months after the effective date.
This module covers digitizing the preparation of compliance procedures, study and modeling data submissions, and Model Verification documentation to support compliance preparedness for NERC CLO-001-1.
Module: 085
Kind: Compliance studies
Governing body: NERC
Applies to: New and in-service sites
Typical time: Follows the standard's clocks
Dashboard capabilities
- Automated Compliance Workflow for CLO-001-1
- Plant File Manager (intake of interconnection requirements, study data requests, modeling data, and equipment design and settings documentation)
- Dashboard (per-site tracking of the modeling data submission schedule, the 90-day technical-concern response window, and Model Verification due dates)
Support services
What GridStrong does inside this module.
Task 1: Develop Compliance Procedure
- Create an audit-ready compliance procedure for meeting the CLO-001-1 requirements, working collaboratively across engineering, development, and compliance departments. This includes:
- Identifying applicable Computational Load Sites against the 50 MW and 100 kV applicability criteria, along with functions, SMEs, roles, responsibilities, and ownership
- Determining specific actions and evidence to demonstrate compliance with specific requirements and measures
- Conducting a gap analysis comparing current practices versus the new requirements, identifying missing processes, incomplete documentation, any staff training needed, etc.
- Developing clear step-by-step procedures for CLO-001-1 that align with internal controls, documentation policies, and the data requirements and reporting procedures of each applicable Planning Coordinator and Transmission Planner
- Establishing compliance timelines that align with the implementation plan (R3 at 6 months; R5, R6, and R9-R11 at 9 months after the effective date)
- Defining and determining specific compliance evidence per site, including retention of R1-R7 evidence for three years and R8-R11 evidence since the last audit
Task 2: Document Interconnection Requirements (Generator Owner customers)
- Document Computational Load Site interconnection requirements for each existing Facility used to interconnect a Computational Load Site to the Transmission system, and make them available on request within 45 calendar days of full execution of the study Agreement (R3).
- Include procedures for coordinating the interconnection requirements with the applicable Transmission Owner and Distribution Provider (Part 3.1).
Task 3: Coordinate Interconnection Studies and Provide Data
- For each planned change at an existing Computational Load Site, compare it against the Planning Coordinator's publicly available definition of qualified change (R7) to determine whether R5 applies.
- Review the applicable Transmission Owner, Distribution Provider, or Generator Owner Computational Load Site interconnection requirements and map them to the site design.
- Coordinate and cooperate with the Transmission Owner, Generator Owner, Distribution Provider, and Transmission Planner or Planning Coordinator on interconnection studies (R5), or, if you are a Generator Owner, with the Transmission Planner or Planning Coordinator (R6).
- Compile and provide the data the Transmission Owner, Generator Owner, Distribution Provider, and Transmission Planner or Planning Coordinator request to support the studies described in R4 Parts 4.1-4.4 (affected-system impact; adherence to NERC Reliability Standards, regional and Transmission Owner planning criteria, and the interconnection requirements; steady-state, short-circuit, and dynamics studies under normal and contingency conditions; study assumptions, system performance, alternatives considered, and coordinated recommendations).
- Keep a dated record of each data request and response as evidence (M5, M6).
Task 4: Submit Modeling Data
- Obtain the steady-state, dynamics, and short-circuit modeling data requirements and reporting procedures developed by each applicable Planning Coordinator and Transmission Planner (R8).
- Compile the required modeling data in the specified data format and level of detail, including parameters, settings, and capabilities related to cessation, tripping, Ride-through, and post-Disturbance recovery; the amount or percentage of information technology infrastructure; and its expected uses or behaviors.
- Provide dynamic models accepted by the Transmission Planner, or as otherwise agreed, where such models are available (Part 9.1).
- Prepare submissions on the schedule in the Planning Coordinator and Transmission Planner data requirements (R8 Part 8.2.3 requires that schedule to call for data at least once every 13 calendar months), incremental submissions for the post-commissioning as-built site and for qualified changes, or a written confirmation that the data has not changed (R9).
- Keep dated transmittal records showing recipient and date (M9).
Task 5: Respond to Technical Concerns
- Review each written notification from the Planning Coordinator or Transmission Planner of technical concerns with the submitted data, including its technical basis.
- Prepare either updated data or an explanation with a technical basis for keeping the current data that responds to the concern (Part 10.1).
- Track the 90-calendar-day response deadline, or the longer period agreed with the notifying entity (Part 10.2), and keep dated response records or a statement that no notification was received (M10).
Task 6: Prepare Model Verification Documentation
- Compare the configurable, site-specific parameters of the submitted model(s) against the design and settings of the in-service equipment at each Computational Load Site (R11).
- Identify any parameters that cannot be verified and prepare the written statement of those parameters and the reasons they cannot be verified (Part 11.1).
- Prepare Model Verification documentation for the Transmission Planner within 365 calendar days after the in-service date, within 180 calendar days after a hardware, software, firmware, or setting change that alters the dynamic response, and within 10 calendar years of the most recent transmittal (Part 11.2).
- Keep dated transmittal evidence for each site (M11).
Final deliverables
- Task 1: Compliance procedure for NERC CLO-001-1.
- Task 2: Dated Computational Load Site interconnection requirements document per Generator Owner Facility.
- Task 3: Study data package and coordination record per Computational Load Site study.
- Task 4: Modeling data submission package per site, or a written confirmation that the data has not changed.
- Task 5: Response package per technical-concern notification, with updated data or a technical-basis explanation.
- Task 6: Model Verification documentation per site, including the written statement of any unverifiable parameters.
What we need from you
- Site one-line diagram, total connected Load, and the voltage level at which the electrical equipment supplying the site is connected to the Bulk-Power System, for each point of connection for each Computational Load Site.
- Executed study Agreement and the applicable Transmission Owner, Distribution Provider, or Generator Owner Computational Load Site interconnection requirements.
- Study data requests from the Transmission Owner, Generator Owner, Distribution Provider, Transmission Planner, or Planning Coordinator.
- Each applicable Planning Coordinator's definition of qualified change, and the Planning Coordinator and Transmission Planner modeling data requirements and reporting procedures.
- Equipment design data and settings related to cessation, tripping, Ride-through, and post-Disturbance recovery.
- Amount or percentage of information technology infrastructure and its expected uses or behaviors.
- Available dynamic models accepted by the Transmission Planner, and documentation of the design and settings of the in-service equipment.
- In-service date and records of hardware, software, firmware, or setting changes at each site.
- Prior modeling data submissions, transmittal records, and any written technical-concern notifications.
Assumptions and considerations
How the scope is bounded.
- CLO-001-1 is pending FERC approval; it has no effective date until FERC approves it, and compliance then phases in under the implementation plan. We align the compliance procedure with the version FERC approves.
- Applicability depends on registration as a Computational Load Owner under the Rules of Procedure registry criteria the NERC Board approved on October 8, 2026 (a Computational Load Site with a total connected Load of 50 MW or more supplied through electrical equipment connected at 100 kV or above); those criteria have not yet been filed with FERC, and NERC expects Computational Load Owners to be registered beginning in 2027.
- If you are a Generator Owner, the Generator Owner requirements (R3 and R6) apply through your existing Generator Owner registration, not Computational Load Owner registration.
- Requirements on Planning Coordinators, Transmission Planners, Transmission Owners, and Distribution Providers (R1, R2, R4, R7, R8, and R6 as it applies to Transmission Owners and Distribution Providers) are outside the scope of this Module, except where you must respond to them.
- Each Planning Coordinator sets its own definition of qualified change, and each Planning Coordinator and Transmission Planner sets its own modeling data requirements, data format, and submission schedule; these may differ between planning areas.
- You inform us promptly when a study Agreement is fully executed or a technical-concern notification is received, since the 45-day (R3) and 90-day (R10) clocks start on those dates.
- You, as the registered entity, transmit each submission and response; we prepare them ready to send.
- You supply all required documentation and access to engineering, development, and operations SMEs.
- We will use engineering judgment and best practices to support compliance preparedness.
- We do not assume liability for inaccurate or incorrect data or information you supply.
Other modules
Every module runs on the same record.
Run this module on one site.
Tell us the plant and the deadline. An engineer confirms the inputs, the schedule and what the Dashboard needs from you.