Is the grid serving Virginia in a recurring crunch?
RICHMOND, Va. - When the Department of Energy declared a grid emergency across the PJM region on Sept. 17, it was not the first time this year. It may not be the last.
Order No. 202-26-45, signed by Energy Secretary Chris Wright, carries a number in DOE's 2026 series of emergency orders under Section 202(c) of the Federal Power Act. PJM Interconnection's application for it cites seven earlier 2026 orders as precedent for letting grid operators dispatch backup generation: Amended Order No. 202-26-01A of Jan. 25, Orders 202-26-06 and 202-26-07 of Jan. 26, Order 202-26-23 of May 18, Orders 202-26-33 and 202-26-33A of June 30 and July 2, Order 202-26-35 of July 14 and Order 202-26-41 of Sept. 1.
The order also cites DOE's Feb. 4, 2026, order granting rehearing in a set of orders tied to Winter Storm Fern, and a Jan. 22, 2026, letter from Wright urging grid operators to plan for using backup generation during emergencies.
A September emergency
What set the September order apart was its timing. It did not come during a midsummer heat wave or a winter storm. It came at the start of what PJM calls outage season.
"PJM is currently in outage season," the grid operator wrote in a Sept. 17 update. "Typically, both transmission and generation facilities perform maintenance and construction from mid-September through December so they are fully available to service peak loads during extreme weather." PJM said it had recalled or canceled outages where possible, but about 36,000 megawatts of outages remained.
PJM's Sept. 16 application to DOE cited "a high generation outage rate due to planned outages during the autumn outage season," numerous planned transmission outages, elevated demand and "significant firm export obligations." It forecast demand near 133,285 megawatts and a shortfall of about 700 megawatts below its reserve margin on Sept. 17. PJM's update said hotter weather to the south and west was increasing the need for exports from PJM.
Where Virginia fits
The application said the strain was "experienced most acutely in BGE, PEPCO, and Dominion zones," with north-to-south flows limited by loading on the Conastone-Peach Bottom 500-kilovolt line. On the morning of Sept. 17, PJM told DOE that "a critical generation facility that supports the affected Zones" had unexpectedly gone offline. PJM called emergency demand response that afternoon in the BGE, Pepco and Dominion zones.
The order's list of covered resources included Virginia combustion turbines in Louisa, Fauquier and Hanover counties and emergency diesel units in Ashburn and Gainesville. PJM's Sept. 17 compliance report shows six Ashburn diesel units ran 8 to 10 hours in reliance on the order.
How the tool works
Section 202(c) lets the energy secretary order generation or transmission when an emergency exists "by reason of a sudden increase in the demand for electric energy, or a shortage of electric energy or of facilities for the generation or transmission of electric energy." When an order may conflict with environmental law, the statute requires that it be limited to the "hours necessary to meet the emergency and serve the public interest" and that it minimize environmental harm to the extent practicable.
Orders of that kind can last up to 90 days and can be renewed. Order 202-26-45 lasted two days, Sept. 17 and 18, and required PJM to request any renewal before it expired.
Recent orders have also changed how emissions are counted. Under 202-26-45, emissions, hours and fuel burned while the order is in effect "will not be counted toward applicable rolling-average-based limitations." PJM had asked for that treatment of 12-month and 30-day rolling limits.
The open questions
The documents do not say how often PJM came close to an Energy Emergency Alert Level 3 during the two days, which is the stage at which rolling blackouts become possible. They do not quantify the cost of the emergency, though the order says rate recovery "is available" through federal tariff filings. And they do not address whether future outage seasons will need to be scheduled differently as demand grows.
The Virginia State Corporation Commission, which regulates Dominion Energy Virginia and Appalachian Power, was copied on the order. No public SCC response to it was found.
Future orders, if any, will be posted on DOE's 2026 Section 202(c) page.
Documents
The order, PJM's application, its supplemental letter and Exhibit A are posted on the Department of Energy's 202(c) page for Order No. 202-26-45 at energy.gov. PJM's daily compliance report for Sept. 17 is posted at pjm.com.
DOE Order 202-26-45 emergency orders Federal Power Act 202(c) outage season PJM reliability Virginia