Power Grid Emergency 13 States: The Count Is PJM's Footprint, Not the Strain

On October 12, 2026, Energy Secretary Chris Wright signed DOE Order No. 202-26-50, a Federal Power Act Section 202(c) emergency order for PJM Interconnection, the grid operator whose region the order describes as all or parts of 13 states and the District of Columbia. From October 13 through October 16, it let PJM dispatch listed power plants that might exceed their environmental permit limits, and call on backup generators as a last resort before, or during, an Energy Emergency Alert 3. For a reader in one of those 13 states, the count is a map of where PJM operates, not of where the grid was short: PJM's own filing found the most acute strain in three zones, and the order ties the 61,591 MW of anticipated generation outages to planned outages in the autumn outage season.

What the Count of 13 States Measures

The count comes from footnote 3 of the order, not from its findings. The footnote's sentence reads: “The PJM Region includes all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and the District of Columbia.” Counting the names gives 13 states plus the District. The words that carry the meaning are “all or parts.” The sentence lists the states alphabetically and marks none of them as whole or partial, so a resident cannot tell from the order alone whether a given address sits inside PJM.

Other federal descriptions drop the qualifier. The U.S. Energy Information Administration, in its EIA Today in Energy note on the June 2025 Eastern heat wave, writes: “PJM's footprint includes 13 states and the District of Columbia.” The subtitle of DOE's August 19, 2026 DOE press release on Order No. 202-26-25 reads: “Emergency order strengthens grid reliability and minimizes the risk of energy shortfalls in 13 states and the District of Columbia.” Neither sentence repeats all or parts, and headlines carry the shorter version.

The same release adds a population: “Energy shortfalls for 65 million Americans are simply unacceptable,” said Secretary Wright. The release does not say how the 65 million was counted, and none of the five documents read for this post splits it by state or sets it against the population of 13 whole states.

One Label for One Unit and for a Whole Region

The August release shows how freely the label travels. Order No. 202-26-25, also a Section 202(c) order for PJM, concerns one generator. In DOE's words, “The emergency order permits PJM Interconnection, L.L.C. (PJM), in coordination with the Talen Energy Corporation, to run Unit 4 at the Wagner Generating Station in Anne Arundel County, Maryland, to meet anticipated electricity demand.” The release adds that “PJM requested the order to continue operating Wagner Unit 4 beyond its current operating limit.” One unit in one Maryland county, and the subtitle still frames the risk as 13 states and the District.

The October order works at a different scale: paragraph A covers the Specified Resources listed in Exhibit A to PJM's application, and paragraph B reaches backup generators across the region. Same statute, same operator, same count. The August order runs from August 20, 2026, through November 17, 2026, so as of October 18 the one-unit order is still in force by its stated dates, while the regional one reached the end of its stated term on October 16.

Where It Was Most Acute: Three Zones

The order's findings locate the problem far more narrowly than its footnote. The key sentence reads: “PJM forecasts demand ‘at or around 111,500 MW (or higher)’ on October 13, 2026, and reports that ‘PJM is forecasted to be within 900 MW of its reserve margin on October 14, 2026’ with anticipated generation outages to reach 61,591 MW across PJM, with the most acute issues in the BGE, PEPCO, and Dominion zones.”

The PJM 202(c) application of October 11, 2026 explains the zonal part: “In addition, generation outages (anticipated to reach around 61,591 MW) across the RTO are reducing operating flexibility and increased reliance on all available resources, and such issues are being experienced most acutely in BGE, PEPCO, and Dominion zones, to maintain transmission flows within established limits.” The closing clause ties the acute problem to transmission limits: a shortage that binds where power flows into a few zones, not 13 states running short together.

The order names three drivers: “Further, PJM reports system conditions are being driven by elevated demand, a high generation outage rate due to planned outages during the autumn outage season, and numerous planned transmission outages.” The application names four: “At the time of this request, PJM has issued a Capacity Advisory for October 12–14, 2026 due to the combined impacts of elevated electric demand, generation outages, planned transmission outages, and significant firm export obligations.” The fourth, firm export obligations, is absent from the order's driver sentence, yet power PJM had already committed outside its region was part of the squeeze.

An Emergency at 111,500 MW

The demand number is the surprise. The application compares the October forecast with a day less than four weeks earlier: “This condition is similar to September 17 where the peak load was 127,729 MWs and 33,899 MWs of generation outages.” October's forecast of 111,500 MW sits 16,229 MW below that September peak. The outages run the other way: 61,591 MW against 33,899 MW, a gap of 27,692 MW, or about 1.8 times as much generation out of service.

As a share of load, outages were about 27 percent on September 17 and about 55 percent for October 13. Adding load and outages gives 173,091 MW in October against 161,628 MW in September, 11,463 MW more despite lower demand. That sum is arithmetic on PJM's figures, not a PJM measure, and leaves out imports, exports and transmission limits.

EIA reports that PJM load peaked at 160,560 MW on June 23, 2025, between 5:00 p.m. and 6:00 p.m., and adds: “The load on the grid surpassed PJM's seasonal peak load forecast of 154,000 MW but remained below the record load of 165,563 MW in 2006 (PJM has expanded numerous times, and this data point is based on PJM's current footprint).” The October forecast is 49,060 MW below that June peak, about 69 percent of it. Even the 2006 record is restated on today's larger region, so the footprint behind the count of 13 has itself moved.

The gap is on the supply side, and the order names it: planned outages during the autumn outage season. Winter brings heating load instead, a different stress covered in faultlinesweekly's reading of the EIA Winter Fuels Outlook 2026-27 electric figure.

The reserve figure needs the same care. Being within 900 MW of the reserve margin on October 14 is a distance from a reserve level, not the size of the reserve, and it equals under 1 percent of the 111,500 MW forecast. Weather was a second channel: the application warned that units could face permit limits “due to continuing hot temperatures and the need for generation” and asked for an order effective through October 16, “which is the date temperatures in the PJM Region are forecasted to decrease.”

What Paragraph B Allows, and When

Paragraph B, the backup generator clause, reads: “From October 13, 2026, PJM is authorized to direct backup generation resources (whether auxiliary, standby, directly-connected, battery storage, or other, and whether synchronized or not to the bulk power system) to operate as a last resort before declaring an EEA 3 (i.e., before firm load interruption) or during an EEA 3.” That is five resource types, synchronized to the bulk power system or not, and two timing branches: as a last resort before an EEA 3 is declared, and during one. Its second sentence lets PJM call on its Transmission Owners and Electric Distribution Companies to carry the order out.

Data centers enter through the order's background section, which describes PJM's aim to deploy backup generation “at data centers (including, but not limited to, hyperscaler facilities) and at other large load industrial and commercial customer sites as another tool to mitigate any undue risk to the bulk-power system.” Paragraph C requires those resources to operate and allows an orderly ramp down after the EEA conditions end.

Paragraph D carves out ten categories: “This Order is not applicable to any backup generation resource serving a critical reliability or backup need, including those at defense, homeland security, first responder, air traffic control, hospital facilities, 911 call centers, water treatment or wastewater facilities, natural gas pipeline facilities, natural gas gathering facilities, or other similar facilities.” Nine are named and the tenth is open-ended. Paragraph K keeps the emergency out of PJM's capacity accounting: “Because this Order is predicated on the shortage of facilities for generation of electric energy and other causes, any backup generation resource subject to this Order shall not be considered a capacity resource.”

The rest sets limits and paperwork. Paragraph A directs PJM to dispatch Exhibit A plants it finds necessary, only as needed to maintain reliability. Paragraph E confines operation to PJM's reliability parameters and, as far as practicable, to environmental law, and requires a daily notification to DOE. Paragraph F keeps environmental monitoring, reporting and recordkeeping in force as far as practicable. Paragraph G lets PJM add plants by written notice, but an added plant drops out once DOE notifies PJM of its disapproval. Paragraph H covers environmental information on DOE's request, the next paragraph directs any needed tariff filings or waivers to the Federal Energy Regulatory Commission, and paragraph J keeps other law in force after expiry.

Paragraph L sets the calendar: “This Order shall be effective October 13 through October 16, 2026, with the exception of the reporting requirements in paragraph E and applicable compliance obligations in paragraph F.” Those two carve-outs mean the reporting and compliance duties outlive the four-day term. It closes: “Renewal of this Order, should it be needed, must be requested before this Order expires.”

What an EEA 3 Counts

Paragraph B's trigger is an alert level, and the alert level has its own counting rule. The order's parenthetical pairs the moment before an EEA 3 with the moment before firm load interruption. NERC's metric document for these alerts, NERC PAS Metric M-11, Energy Emergency Alerts, revised March 13, 2025, defines what it tracks: “These metrics track EEA 3 declarations for BAs when actual capacity and/or energy deficiencies occur as defined by EOP-011-4.” Its first formula line reads: “EEA 3 alerts issued in a count by region (including events with and without firm load interruption)”.

In NERC's own count, then, an EEA 3 can occur with or without customers losing firm service, and the revision history notes that the word firm was added to make that explicit. The metric gives the purpose plainly: “The purpose of an EEA is to provide real-time indication of potential and actual energy emergencies within an Interconnection.”

Footnote 32 of the order quotes NERC Reliability Standard EOP-011-4: “The Reliability Coordinators and the energy deficient Balancing Authority shall continue to take all actions initiated during EEA 2.” An EEA 3 is a rung that keeps the earlier rungs running. So power grid emergency can mean three things in this episode: DOE's Section 202(c) order, which PJM sought by asking the Secretary to find that an imminent reliability emergency would exist; PJM's Capacity Advisory for October 12–14; or a NERC alert level. Backup generators running under paragraph B would not by themselves show that firm load was cut.

Concrete Framework

Five questions read any grid emergency headline that leads with a count of states.

1. Footprint or affected area? Look for the words all or parts. Here they sit in footnote 3 and describe where PJM operates; the findings put outages across PJM and the most acute issues in the BGE, PEPCO and Dominion zones.

2. Which zone is yours? Inside PJM but outside those zones means within the order's reach but outside its most acute area. Inside one of the 13 states but outside PJM means outside the area the order addresses, since its findings and paragraph A speak of the PJM Region and PJM's service territory.

3. Demand or supply? Divide outages by load: about 27 percent on September 17, about 55 percent for October 13. A ratio that doubles while load falls marks a supply-side event, and the order attributes the outages to the autumn outage season.

4. Which emergency? A Section 202(c) order, a PJM Capacity Advisory and a NERC Energy Emergency Alert are different instruments, and NERC counts EEA 3 events with and without firm load interruption.

5. Which calendar? Order No. 202-26-50 ran October 13 through October 16, its reporting and compliance duties continue past that date, and renewal had to be requested before expiry. The one-unit Wagner order runs through November 17 under the same count. New plants shift this picture slowly, as faultlinesweekly's note on monthly power construction put in place shows from the spending side.

What Would Invalidate This

Whether PJM sought renewal before October 16, or DOE issued a follow-on order, is open: when the DOE page for Order No. 202-26-50 was read on October 18, its newest listed document was PJM's updated Exhibit A dated October 14.

Actual PJM load on October 13 and October 14 was not read, and the forecast said 111,500 MW or higher. Whether PJM declared any Energy Emergency Alert, or any backup generator ran under paragraph B, was not confirmed; the daily notifications under paragraph E were not among the public documents read. Generators running during an EEA 3 with firm load cut would change the answer to question 4 for this episode.

Exhibit A was not opened, so the number and location of the listed plants are unknown. The documents read here do not place the three zones in particular states, and the Census Bureau's state population file could not be retrieved, so no estimate is made of how many residents of the 13 states live outside PJM. EOP-011-4 was read only through the clause quoted in footnote 32, and the September 17 figures come from PJM's application alone.

What to Watch Next Week

First, the DOE 202(c) page for Order No. 202-26-50. A renewal request or a new PJM order would show the autumn outage season still binding after October 16; compare any new outage figure with the 61,591 MW of October 13 and the 33,899 MW of September 17, and check whether the same three zones are named.

Second, actual load. EIA's Hourly Electric Grid Monitor, the data source behind the June 2025 peak of 160,560 MW, reports PJM demand by hour and is where the 111,500 MW forecast can be checked against what happened.

Third, the Wagner order, effective through November 17, 2026: DOE still describes it with 13 states, yet it covers one unit in Anne Arundel County. Finally, filings at the Federal Energy Regulatory Commission under the order's tariff paragraph would show whether any party needed waivers for the four days from October 13 to October 16.