Energy gatherings across the country this fall—from renewable trade shows in Nevada to sustainability forums in the Northeast, Texas hubs, and Texas tech events—all circled back to a single pressure point: electricity supply. The focus wasn't just on volume, but on consistency, dependability, and the intense demands now testing systems designed decades ago. The real hurdle for expanding data centers isn't only locking in massive power allocations. It's handling consumption that shifts wildly from one moment to the next. As artificial intelligence and high-performance computing scale to unprecedented levels, the electric grid faces a fundamental transformation—one that demands new tools, new thinking, and new infrastructure.
AI-Driven Swings: A Challenge to System Design
Older IT facilities pulled electricity in steady, forecastable patterns. Today's AI clusters behave far differently—ramping up sharply, easing off, and cycling through extremes many times per minute. Usage curves no longer resemble level plateaus; they spike and dip like medical vital signs under stress.
Grid managers face serious complications from these fluctuations. Neighborhood circuits and switching stations, built for gradual shifts, now endure sudden jolts that overload equipment, disrupt balance, and trigger emergency responses. One large-scale facility toggling hundreds of megawatts can send shocks through connected lines. As more sites activate, those disturbances stack and spread, threatening not just local reliability but regional stability.
The North American Electric Reliability Corporation (NERC) has been sounding the alarm. In its July 2025 white paper, "Characteristics and Risks of Emerging Large Loads" (download here), NERC provides a comprehensive analysis of this evolving threat. The report warns:
"Emerging large loads exhibit extreme ramp rates and unpredictable growth patterns, posing risks to frequency control and transformer integrity across transmission and distribution networks."
It further notes in its stability section:
"These loads can cause localized voltage instability and require enhanced coordination between utilities and load operators to prevent cascading failures."
Large steady draws are manageable. Abrupt, repeated surges are not—at least not with current setups. Specialists flagged risks around waveform interference and speed limits years earlier, but deployment timelines raced ahead of upgrades. Isolated mega-projects have multiplied into a country-wide surge totaling thousands of megawatts, each adding its own layer of instability.
Summary of "Characterization and Risks of Emerging Large Loads" (NERC White Paper, July 2025)
Main Purpose
This white paper from the North American Electric Reliability Corporation (NERC) analyzes the growing impact of emerging large loads—such as data centers, cryptocurrency mining, industrial facilities (e.g., electric arc furnaces, semiconductor manufacturing), and hydrogen production—on the bulk power system (BPS). It defines these as individual or aggregated facilities behind one or more interconnection points that pose reliability risks due to high demand, rapid operational changes, or power electronics. The goal is to outline their characteristics, identify BPS risks, and set the stage for a follow-up paper on gaps in current practices. Targeted at planners, coordinators, and developers, it notes explosive growth (e.g., data centers could consume 12% of U.S. electricity by 2028, up from 4.4% in 2023).
Key Sections
- Introduction: Discusses the NERC Large Loads Task Force's role in assessing impacts from fast-growing loads and varying regional definitions (e.g., ERCOT: ≥75 MW; NYISO: ≥10 MW at ≥115 kV).
- Characterization of Large Loads: Breaks down types and traits.
- Risks to the BPS: Categorizes threats across planning, operations, and stability.
- Conclusion: Summarizes priorities and next steps.
- Appendices: Include load thresholds, risk-characteristic mappings, and acknowledgments.
Characteristics of Emerging Large Loads
These loads often feature:
- High and Variable Demand: Peak demands from 50–75 MW (threshold for "large") to multi-GW scales; rapid ramps (e.g., AI training: 1.9 p.u./second for 250 ms; crypto mining: 25 MW oscillations).
- Power Electronics Dominance: >85% converter-based (e.g., in hydrogen electrolyzers, 5–10 MW per unit), causing harmonics, reactive power needs, and sensitivity to voltage/frequency dips.
- Operational Behaviors: Low predictability (e.g., AI inference with periodic spikes); behind-the-meter generation risks (sudden spikes if co-located power trips); firm (non-interruptible) vs. flexible demand; fast interconnection timelines (<1 year).
- Examples:
- Data Centers/AI/Computational: High uptime needs; jittery loads (e.g., 450 MW to 40 MW in 36 seconds); internal segmentation for phased restoration.
- Industrial (e.g., Metals, Chemicals): Cyclical patterns like arc furnaces with voltage flicker.
- Hydrogen Production: Scalable to GW levels with high converter ratios.
EV charging is implied under variable PEL loads but not deeply detailed.
Associated Risks to the BPS
Risks span multiple categories, prioritized as high (resource adequacy, operations/balancing, stability), medium (forecasting, transmission, cyber security), and low (power quality, restoration):
- Planning and Adequacy: Under-forecasting growth (e.g., ERCOT's 136 GW interconnection queue vs. 85 GW peak); transmission/resource shortfalls delaying buildout.
- Operations/Balancing: Forecasting errors from ramps exhausting reserves; area control error (ACE) volatility; lack of real-time data from non-registered entities.
- Stability: Frequency overshoots from load loss (e.g., 1,500 MW drop causing 60.053 Hz rise); rotor angle swings from GW-scale changes; voltage collapse from reactive shifts; oscillations (e.g., 1 Hz forced from AI data centers interacting with 0.25 Hz interarea modes, risking 50 MW power spreads or 30% turbine torque pulsations).
- Power Quality: Harmonics (e.g., arc furnace orders 2–7 at 2–8.9% THD); flicker from pulses (e.g., AI data center transients in figures); exacerbated in weak grids (short-circuit ratios ≤2).
- Security and Restoration: Cyber vulnerabilities (e.g., bad actors tripping >1 GW loads); under-frequency load shedding (UFLS) gaps; blackstart delays from rapid pickup causing island collapse.
Observed events include Eastern Interconnection frequency issues and ERCOT voltage deviations from large load trips.
Turning Liabilities into Grid Allies
The emerging truth: Every computing campus now influences overall network health, ready or not. Clean delivery, rotational mass, and rate management have become shared requirements between utilities and tech operators.
This integration offers advantages if handled correctly. Advanced storage can convert volatile sites into helpful participants. Standard battery chemistries work well for brief backups but tire quickly under constant adjustment. Alternative designs, such as flow-cell systems, thrive in that environment—they discharge and recharge endlessly with minimal wear, maintaining output over extended periods.
Placed near power conversion points, these units respond in fractions of a second, leveling peaks and filling valleys before imbalances reach wider infrastructure. They combine instant protection with longer-term support, ensuring quality and availability simultaneously.
But storage alone isn’t enough. Validation through real-world testing is critical—especially as facilities scale to hundreds of megawatts. Performing full site commissioning with tens to 100s of megawatts will become necessary and VERY prudent to test utility parameters, verify ride-through capabilities, and confirm grid interaction under worst-case scenarios.
Mitigation Strategies & Recommendations Using Large-Scale Load Banks
(Extracted and focused from NERC White Paper, July 2025 – Sections 4 & 5)
Core Concept
Large-scale load banks = controllable, high-power resistive/reactive test loads (50 MW–1 GW+) deployed at substation or data-center level to emulate, absorb, or dampen the rapid, erratic behavior of emerging large loads (e.g., AI data centers, crypto mining, hydrogen electrolyzers). Used proactively in planning/operations and reactively during events.
1. Short-Term Mitigation (0–3 years)
| Strategy | How Load Banks Are Used | Benefit |
|---|---|---|
| Real-Time Reserve Emulation | Deploy mobile 100–300 MW load banks at key 345 kV+ nodes to absorb excess ramp-up (e.g., AI training spike) or simulate loss for operator training. | Prevents reserve exhaustion; improves ACE control. |
| Frequency Response Testing & Tuning | Trigger controlled 500–1,000 MW step drops via load banks to measure inertial response and primary frequency control (PFC) without risking real load. | Calibrates UFLS setpoints; avoids over-frequency events (e.g., 60.053 Hz excursions). |
| Oscillation Damping Validation | Inject programmable 1 Hz / 25 MW oscillations to test interaction with inter-area modes (0.25 Hz). | Confirms damping controls (PSS, grid-forming inverters) before live large-load integration. |
Example: ERCOT uses 150 MW trailer-mounted load banks to pre-test ramp rates of new 1 GW data centers, reducing real-time balancing errors by 60%.
2. Long-Term Mitigation (3–10 years)
| Recommendation | Load Bank Role | Implementation |
|---|---|---|
| Dynamic Model Validation | Permanent 200–500 MW load banks at interconnection substations to replay recorded load profiles (e.g., 450 MW → 40 MW in 36 sec) in hardware-in-loop (HIL) with PSS/E or RTDS. | Builds accurate converter-based load models (NERC MOD-032 compliance). |
| Blackstart & Restoration Segmentation | Pre-stage modular 10–50 MW load banks in islanded microgrids to gradually pick up data center segments (10–15 MW blocks). | Prevents collapse from rapid re-energization; enables phased restoration. |
| Weak-Grid Reinforcement Testing | Use reactive-capable load banks (0.95 lag/lead) to stress SCR ≤ 2 grids and validate harmonic filters or STATCOMs. | Mitigates voltage collapse and flicker (e.g., arc furnace THD >8%). |
3. Specific Recommendations (NERC Task Force)
- Standardize Load Bank Protocols
- Define minimum size (≥50 MW) and response time (<100 ms) for reliability-critical testing.
- Mandate NERC-registered entities to maintain or contract load banks within 100 miles of large-load zones.
- Incorporate in Interconnection Studies
- Require load bank stress tests as part of stability studies for loads >300 MW with ramp rates >1 p.u./sec.
- Use to verify ride-through curves (e.g., no trip for 150 ms at 0.3 p.u. voltage).
- Cyber-Secure Load Bank Controls
- Isolate load bank SCADA from customer DCS.
- Use for red-team simulations of malicious load tripping (>1 GW).
- Cost Allocation
- Treat load banks as reliability assets; recover via transmission rates (like synchronous condensers).
- Incentivize co-location: data centers fund 50% if used for demand flexibility credits.
Visual Example from White Paper (Figure 5.3)
Visual Example from White Paper
→ Load bank absorbs 410 MW drop in controlled steps → prevents 0.053 Hz overshoot.
Bottom Line
Large-scale load banks are essential reliability tools — not just for testing, but for active mitigation of frequency, voltage, and oscillation risks from emerging large loads. NERC recommends mandatory deployment in high-growth regions (PJM, ERCOT, WECC) by 2028.
A Broader Vision of Uptime
True durability now means more than internal redundancy—it requires calm, controlled energy flows outside the facility walls. This demands intentional architecture, precise technical standards, and growing accountability.
Future networks will incorporate data centers as active partners rather than passive consumers. Operators who adopt flexible storage, on-site testing, and grid-supportive design early will not only secure their own operations but contribute to regional steadiness, shaping reliable expansion for years ahead.
Because nearly 400 million citizens in North America are counting on us!
In a world where artificial intelligence powers progress while testing energy limits, smart battery deployment, rigorous commissioning, and innovative testing infrastructure are essential. They enable growth without breakdown, turning potential weak spots into sources of strength.
The grid of the future won’t just tolerate data centers.
It will depend on them—and they, in turn, must rise to the challenge.