The Digital Chamber Comments on Project 2026-02 — Computational Loads

September 18, 2026

Project 2026-02 Computational Loads Drafting Team
North American Electric Reliability Corporation
1401 H Street NW, Suite 410
Washington, DC 20005
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Re: The Digital Chamber Comments on Project 2026-02 — Computational Loads

Dear Members of the Computational Loads Drafting Team:

The Digital Chamber (TDC) respectfully submits these comments on NERC Project 2026-02,Computational Loads. TDC advances policies that support the responsible development of energy andcomputational infrastructure, including Bitcoin mining, artificial intelligence, and high-performancecomputing. Our members include owners and operators of data centers and mining facilities, as well asparticipants in networks of independently owned computing resources. Their operations place them at theintersection of computational innovation and electric grid reliability, with a direct stake in developingstandards that are technically sound, proportionate to system risk, and practical to implement.

TDC supports NERC’s objective of ensuring that grid planners and operators have the information andoperational capabilities needed to reliably integrate computational loads. Clear interconnection,operational coordination, and disturbance monitoring requirements can strengthen reliability while givingdevelopers greater certainty about the obligations associated with building and operating computationalinfrastructure. These requirements should also account for differences in facility size, electrical behavior,operational control, and the ability to adjust demand in response to grid conditions.

Our comments focus on aligning reliability obligations with the electrical impacts an entity creates andthe functions it actually controls. The standards should clearly distinguish individual sites fromcomputing resources coordinated across separate locations, and distinguish control over electrical demandfrom ordinary participation in a compute market. They should also establish workable requirements formodeling, communications, and monitoring, with compliance costs and implementation periods thatreflect the circumstances of smaller facilities and entities entering NERC’s registration framework for thefirst time.

The choices made in this proceeding will influence how computational infrastructure is developed andintegrated into the grid. TDC encourages NERC to establish a framework that addresses demonstrablereliability risks while enabling flexible demand, distributed computing, and a range of facility sizes andoperating models. The recommendations below identify clarifications needed in the proposed standardsand issues warranting further development in Phase 2.

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Read the full comment letter here.

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About the Digital Power Network
‍The Digital Power Network is the largest coalition of Bitcoin miners and digital infrastructure providers in the United States, representing companies that make substantial, long-term investments in energy and computing infrastructure while supporting grid reliability and innovation.