Winter is here. The first snow of the season is expected across parts of the Midwest, Northeast, Great Lakes and even into the Southeast later this week. At elevation, a foot or more of snow could be coming. In the Northwest, a “bomb cyclone” storm is forming offshore with the potential to have the intensity of a hurricane.

The arrival of nasty winter weather comes as the North American Electric Reliability Corp. (NERC) released its annual Winter Reliability Assessment. While NERC doesn’t foresee issues during normal winter weather conditions, extreme winter weather — read: the kind we’re already seeing well in advance of the first day of winter — could cause energy shortfalls across much of the country. Defining “extreme” is a question of semantics. But what is clear, should we see the biting cold, ice storms and blizzards that come every year, grids across the nation will be pushed to the limit.

The loss of so much fuel-secure, dispatchable coal generation over the past decade is colliding with soaring power demand, leaving grid operators under a constant threat of crisis.

The Gas Vulnerability

What has NERC most concerned is the potential for freezing temperatures to impact delivery of natural gas to power plants. This is a reoccurring and devastating problem.

It was precisely this problem that was the leading cause of the blackouts that crippled Texas in 2021 when winter storm Uri claimed the lives of 246 people. While Texas has taken some steps to weatherize its grid and its natural gas system, national efforts to do so are glaringly absent.

NERC has found that outside of Texas, there is “little to no information to indicate that upstream gas producers, gatherers, and processors have improved winterization of their operations.”

That’s deeply concerning because the gas delivery vulnerability is hardly confined to Texas. Two years ago, Winter Storm Elliott forced the largest recorded electricity load shed in the history of the Eastern interconnection – the grid system covering two thirds of the U.S. – largely because of inadequate gas supplies. A stunning 90.5 gigawatts (GW), or 13% of the generating capacity in the Eastern Interconnection, failed to run or operated at reduced capacity during the storm. Gas-fired capacity accounted for 63% of the outages. On the PJM grid, the nation’s largest regional grid serving 65 million Americans, gas capacity accounted for 70% — or 32 GW – of outages.

Not only does the gas system remain a frightening vulnerability, but there is also little to no regulatory oversight of the system despite its critical importance to energy delivery.

“I think the concern is that, while we have standards in place for reliability of electric generation units, we don’t know as much about an assured supply of gas,” said Mark Olson, NERC’s manager of reliability assessments.

In the wake of Elliot, Willie Phillips, the chair of the Federal Energy Regulatory Commission, implored Congress to direct an agency to oversee reliability for the natural gas system. That still hasn’t happened.

Urgent Need for a Policy Pivot

Unfortunately, we now enter this winter with glaring vulnerabilities in the power system and have a new, alarming challenge to navigate—soaring power demand. Electrification of the economy, rapid addition of EVs, new manufacturing plants and the explosive growth of data centers is sending peak winter power demand skyward while grid operators must manage a system with ever-shrinking reserve margins and less and less fuel-secure coal capacity.

The challenges facing the PJM grid are indicative of the national reliability crisis. Facing the existing regulatory burden, PJM projects that it will lose 40 gigawatts of generating capacity by 2030 – 21% of the market’s existing capacity – with only 31 GW of additions in the same period. PJM also projects peak winter demand – when coal capacity is needed most – to climb to almost 165 GW in the next decade from 135 GW last winter. By 2040, PJM expects power demand in its service territory to have doubled.

More than ever, we need a return to sane policymaking that reflects the on-the-ground reality of soaring power demand, inadequate reserve margins and glaring resource vulnerabilities. Responsible policymaking should underpin grid reliability instead of undermining it. It is far past time to recognize and embrace the importance of dispatchable fuel diversity and the fuel security provided by the coal fleet.