Modules · Compliance studies · Module 086
CLO-002-1 Computational Load Operational Data and Communications
Operational data specifications, Operating Instructions and Interpersonal Communication for data-center owners and operators under NERC's proposed CLO-002-1.
About this module
What this module covers.
The new CLO-002-1 standard (Computational Load Operational Data and Communications) 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, and gives Transmission Operators, Balancing Authorities, and Reliability Coordinators the site data they need, and gives Transmission Operators and Balancing Authorities Interpersonal Communication capability with each site's Computational Load Operator. Each Transmission Operator, Balancing Authority, and Reliability Coordinator must maintain and distribute a documented data and information specification for Computational Load Sites (R1-R6), and each Computational Load Owner (CLO) and Computational Load Operator (CLOP) that receives one must satisfy it (R7), including its deadlines or periodicity, availability and accuracy criteria, model submissions consistent with the model submitted for planning purposes, subject to modifications for operations purposes, as applicable, update and correction provisions, format, and secure transfer method. The CLOP must comply with each Operating Instruction issued by its Transmission Operator, Balancing Authority, or Reliability Coordinator unless the action cannot be physically implemented or would violate safety, equipment, regulatory, or statutory requirements (R8), and must inform the issuer when it cannot comply (R9); the proposed modified Glossary definition of Operating Instruction would cover commands to a Computational Load Site. The CLOP must have Interpersonal Communication capability with its Balancing Authority and Transmission Operator (R11) and, on detecting a failure of that capability, consult each affected entity to determine a mutually agreeable restoration action (R13). The CLOP must train each operator who can receive an oral two-party, person-to-person Operating Instruction in three-part communication (repeat the instruction and receive confirmation, or request that it be reissued) before that operator receives one (R14), and must use that protocol for each such instruction received during an Emergency (R15).
CLO-002-1 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 Transmission Operator, Balancing Authority, and Reliability Coordinator specification requirements (R1-R6) at 6 months, and R7-R15, which include every CLO and CLOP requirement plus the Transmission Operator and Balancing Authority communication requirements (R10, R12), at 12 months after the effective date. The Computational Load Site and Computational Load Owner definitions must be approved before CLO-002-1 becomes effective. An entity with a Computational Load Site in service no later than 12 months after the effective date may request an extension of the R8-R15 compliance dates from its Compliance Enforcement Authority if circumstances beyond its control, such as supply chain delays in the procurement, engineering, installation, or commissioning of Interpersonal Communication equipment, prevent it from establishing Interpersonal Communication capability and associated protocols; the request is due no later than 3 months before the compliance date.
This module covers digitizing the preparation of compliance procedures, operating procedures, training materials, and evidence records to support compliance preparedness for NERC CLO-002-1.
Module: 086
Kind: Compliance studies
Governing body: NERC
Applies to: In-service sites
Typical time: Follows the standard's clocks
Dashboard capabilities
- Automated Compliance Workflow for CLO-002-1
- Plant File Manager (intake of Transmission Operator, Balancing Authority, and Reliability Coordinator specifications, communication equipment documentation, and training records)
- Dashboard (per-site tracking of the 12-month compliance dates and extension request deadlines)
Support services
What GridStrong does inside this module.
Task 1: Develop Compliance Procedure
- Create an audit-ready compliance procedure for meeting the CLO-002-1 requirements, working collaboratively across operations, engineering, and compliance departments. This includes:
- Identifying applicable Computational Load Sites, the registered CLO and CLOP for each, and the Transmission Operator, Balancing Authority, and Reliability Coordinator responsible for each site, along with 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-002-1 that align with internal controls and documentation policies
- Establishing compliance timelines that align with the implementation plan (R7-R15 at 12 months after the effective date)
- Defining and determining specific compliance evidence per site, including retention of R7 evidence for the most recent 90 calendar days, R8-R13 voice recordings for 90 calendar days and documentation for 12 calendar months, and R14-R15 voice recordings for 90 calendar days and documentation for two calendar years
Task 2: Meet Data and Information Specifications
- Collect each data and information specification the Transmission Operator, Balancing Authority, and Reliability Coordinator distribute to you (R4-R6).
- Map each specification item to its site data source and owner, deadline or periodicity, availability and accuracy criteria, format, and secure transfer method (R7).
- Where a specification requires model submissions, align them with the model submitted for planning purposes (for a Computational Load Site, typically the CLO-001-1 R9 data), subject to modifications for operations purposes, as the specification provides.
- Identify items the site cannot meet and raise them through each specification's conflict-resolution process.
- Set up records of data transmittals or receiving-entity attestations as evidence (M7).
Task 3: Develop Operating Instruction Procedures
- Develop procedures for receiving, logging, and carrying out Operating Instructions from the Transmission Operator, Balancing Authority, and Reliability Coordinator (R8).
- Define the conditions under which an Operating Instruction cannot be carried out (it cannot be physically implemented, or it would violate safety, equipment, regulatory, or statutory requirements), and compile copies of the governing requirements as evidence (M8).
- Develop the process for informing the issuer of an inability to comply (R9), with operator log entries and an attestation template for periods when no such situation occurs.
Task 4: Establish Interpersonal Communication Capability and Failure Response
- Document Interpersonal Communication capability with the Balancing Authority and Transmission Operator for each site (R11), using equipment specifications, installation documentation, and test records.
- Develop the failure-response procedure: on detecting a failure, consult each affected entity to determine a mutually agreeable restoration action, and log the consultation (R13).
Task 5: Develop Operator Training and Emergency Communications
- Develop initial three-part communication training for each operator who can receive an oral two-party, person-to-person Operating Instruction: repeat the instruction, not necessarily verbatim, and receive confirmation from the issuer, or request that the issuer reissue it (R14).
- Set up a roster check so no operator receives an oral two-party, person-to-person Operating Instruction before completing initial training, with training records (attendance logs, agendas, learning objectives, course materials) as evidence (M14).
- Develop the Emergency procedure for repeating back, or requesting reissue of, oral two-party, person-to-person Operating Instructions, excluding single-party to multiple-party burst instructions, with evidence such as time-stamped voice recordings, operator logs, or issuer attestations (R15).
Task 6: Prepare Extension Requests (where applicable)
- For sites in service no later than 12 months after the effective date where circumstances beyond your control prevent establishing Interpersonal Communication capability and associated protocols, prepare the extension request to the Compliance Enforcement Authority, including site identification, a plan and timetable for completion, a description of the circumstances and why they are beyond your control, and any other relevant information.
- Track the filing deadline of 3 months before the compliance date, and prepare an updated request if more time is required.
Final deliverables
- Task 1: Compliance procedure for NERC CLO-002-1.
- Task 2: Data specification compliance matrix per site, mapping each specification item to its source, owner, schedule, format, and transfer method, with open gaps.
- Task 3: Operating Instruction procedure, including the inability-to-comply notification process, log templates, and attestation template.
- Task 4: Interpersonal Communication capability evidence package per site and communication-failure response procedure.
- Task 5: Initial three-part communication training materials, training-record templates, and Emergency communication procedure.
- Task 6: Extension request per affected site, ready for your submission to the Compliance Enforcement Authority.
What we need from you
- Registration status of the CLO and CLOP for each Computational Load Site.
- Each data and information specification received from the Transmission Operator, Balancing Authority, and Reliability Coordinator.
- Site one-line diagram and an inventory of available site data and information points.
- Model submitted for planning purposes (for example, CLO-001-1 R9 modeling data), where a specification requires model submissions.
- Existing operating procedures, operator logs, and voice recording practices.
- Roster of operating personnel who can receive oral two-party, person-to-person Operating Instructions, and existing training records.
- Interpersonal Communication equipment specifications, installation documentation, and test records.
- Contact points for the Transmission Operator, Balancing Authority, and Reliability Coordinator.
- For extension requests: procurement, engineering, installation, and commissioning schedules for Interpersonal Communication equipment.
Assumptions and considerations
How the scope is bounded.
- CLO-002-1 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 or Computational Load Operator 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.
- You identify the registered CLO and CLOP for each site; one entity may register for both functions.
- Requirements on Transmission Operators, Balancing Authorities, and Reliability Coordinators (R1-R6, R10, R12) are outside the scope of this Module, except where you must respond to their specifications, Operating Instructions, and notifications.
- We do not operate the Computational Load Site, receive or carry out Operating Instructions, or procure or install Interpersonal Communication equipment; your operating personnel perform these.
- You keep voice recordings and operator logs for the retention periods the standard sets.
- The Compliance Enforcement Authority decides each extension request; preparing a request does not guarantee it is granted.
- You, as the registered entity, transmit each submission and request; we prepare them ready to send.
- You supply all required documentation and access to operations, engineering, and compliance SMEs.
- 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.