Although Texas' ERCOT is not subject to FERC regulations, there are apparently emergency DOE orders that apply to some Texas generating facilities nonetheless:

Under FPA section 202(c) during the continuance of a war in which the United States is engaged or 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, or of the fuel or water for generating facilities, or other causes, the Secretary of Energy may require by order temporary connections of facilities, and generation, delivery, interchange, or transmission of electricity as the Secretary determines will best meet the emergency and serve the public interest. 16 U.S.C. § 824a(c). [...]

On February 14, 2021, a 202(c) emergency order was issued to the Electric Reliability Council of Texas (ERCOT) authorizing specific electric generating units (resource list) located within the ERCOT area to operate at their maximum generation output levels due to ongoing extreme weather conditions and to preserve the reliability of bulk electric power system.

Which facilities are on that "resource list" and how much of Texas power do they (normally) supply?

I found the full text of the order, but the list of units is apparently a separate document. (One intersting bit from the text though is that ERCOT itself requested the DOE to issue the federal order.)

  • Definitely of interest because it shows capacity limits, which could be equivalent to normal supply. americanexperiment.org/2021/02/… but it's by power type, not facility – user9790 Feb 20 at 20:53
  • Asking for a specific list of what facilities were involved does not appear to be on-topic for this site. (Note: I am not one of those who voted to close.) A better question that is related to politics is why is the federal government involved at all? ERCOT has largely avoided federal regulation by keeping the electrical power that generated in the parts of Texas that ERCOT does cover within those bounds. – David Hammen Feb 21 at 6:56
  • 2
    Also note that the title of the question is incorrect. The DOE did not order those generating units to operate at full power. It instead authorized those units to operate at full power. The Politics.SE question should have been "why" rather than "which facilities". I answered the question that should have been asked. – David Hammen Feb 21 at 6:59
  • @DavidHammen: fair point. I got misled by the first para in the DOE summary which speaks of orders rather than authorizations.... The title of the DOE authorization itself is "Order No. 202-21-1" but I guess that's customary, even if it's an authorization and not an order. – Fizz Feb 21 at 7:36
  • Regarding the first sentence... FERC's jurisdiction is over inter-state energy market operations, and thus doesn't have jurisdiction over any power plant, anywhere (except for a weird carve-out for some hydro plants). The DOE has jurisdiction over every power plant in the U.S. – LShaver Feb 22 at 16:16

ERCOT has the list, but it's in the most data-processing unfriendly format possible (a PDF table). I've only converted it as much as I needed to sum its data columns. I get a total of 32,196.93 MW max winter rating and 8,716.21 MW min winter rating from the (two) relevant order columns.

Given that Texas has about 125,117 MW in total generating power according to Wikipedia, what's on that emergency order list only about 25% (using the max winter rating) of the total.

Some interesting things that are not in the emergency order list are e.g. the nuclear plants, although these are only 4,700 MW, so they don't cover the difference by themselves. The units on the emergency order list are all gas and coal powered, i.e. none of them are "green power" ones. I guess this is because (as the order itself says) they needed the DOE to issue the emergency order so that the power plants would no longer be subject to pollution emission limits.


This is the text of the request that ERCOT sent to DOE:


This is the DOE order:


The DOE order basically copies the request that ERCOT sent - it fully grants it.

The list of the generating units was prepared by ERCOT and is available here


  • Please edit your answer and include essential parts here. – user35692 Feb 22 at 5:30
  • I don't think you understand what this actually means: This Order does not provide relief from an entity’s obligations to purchase allowances for emissions that occur during the emergency condition or to use other geographic or temporal flexibilities available to generators. – user9790 Feb 22 at 22:24
  • I do understand what it means. Emission allowances are a normal part of operating power plants. Using other resources is also quite normal. – Daniel Martinez Feb 23 at 15:49
  • You should quote the relevant parts of those documents in your answer. Links are great, but answers should also be able to stand alone in case the links break in the future. It also makes the answer stronger if the relevant parts are right there, instead of within a large document – divibisan Feb 24 at 16:55

The original title of the question ("Which generating units did the DOE order to operate at maximum capacity in Texas?") is incorrect. The Department of Energy (DOE) did not order those generating units to operate at full capacity. It instead authorized those plants to operate at full capacity, despite the fact that doing so would most likely violate federal air and / or water pollution regulations.

The request from Electrical Reliability Council of Texas (ERCOT) to the DOE is in a letter dated 14 February 2021. The list of generators at the end of the letter appears to be identical to the list later provided by the DOE. The letter spells out why ERCOT made that request:

ERCOT has been notified by three major generation owners that their generating units will, or are likely to, encounter operating restrictions during the next several days due to various emissions and other limits established in federal permits. These units are described in Exhibit A to this letter. These units are subject to a number of environmental limitations that may restrict output. ERCOT has been informed that the operation of gas-fired generators during the next few days could be impacted by permit restrictions on nitrogen oxide and carbon monoxide emissions, that coal-fired generators would be impacted by permit restrictions on emissions of sulfur dioxide, nitrogen oxide, mercury, and carbon monoxide, and that generation fueled by distillate fuel oil would be subject to various restrictions on operating duration and/or emissions. ERCOT has also been informed that generators of various fuel types may be subject to wastewater release limits. ERCOT is also aware that many other generators not included on this list are subject to similar federal permit limits.

ERCOT has avoided federal electrical power regulations by keeping the electricity generated in Texas in Texas. It cannot avoid federal pollution regulations; courts have long upheld the federal governments authority over air and water quality on the grounds that pollutants do not obey state boundaries.


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