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Last updated: Tuesday, September 22, 2026
September emergency DR, a 2030 standard that breaks, and a toll gate that just got cheaper
PJM activated Pre-Emergency and Emergency Demand Response on the afternoon of Sept. 17 with load forecast near 132,000 MW and roughly 36,000 MW of generation already in outage, and DOE backed it with an emergency order through Sept. 18. That is September, with fall outage season barely started. A Pennsylvania PUC study puts the same system's 2030 loss-of-load expectation at 0.59 in the base case and 13.20 in the high-load, low-supply case against a 0.1 criterion. Only the no-new-data-centers run clears, and nobody is forecasting that.
The policy response is splitting, and the split is what matters to your forward curve. ISO-NE is going to a bring-your-own-new-capacity obligation for anything 50 MW and up, which keeps new load from bidding against your book in the capacity auction. Texas went the other way: the PUCT threw out the non-refundable $50,000 per MW study fee it floated in March, replaced it with one flat $100,000 regardless of size, and stretched the missed-milestone window from six months to 24. That was the one real toll gate on a 474 GW queue. The House passed the Ratepayer Protection Act 417-3, but ClearView reads it as behind the curve. Price scarcity harder where load is cheap to queue.
Storage is tightening and the curve refuses to pay for it
The fundamentals and the curve are telling two different stories, and that gap is the trade. EIA put the week-ended Sept. 11 injection at 44 Bcf against a 74 Bcf five-year average and an 87 Bcf build a year ago. Working gas sits at 3,298 Bcf, now 122 Bcf below last year and only 118 Bcf over the five-year average, with South Central actually pulling 5 Bcf out and salt down 24% on the year.
The curve does not care. March 2027 printed a fresh low at $2.772 and the March over April 2027 spread collapsed to roughly 11 cents, a record. That spread is the market saying it does not expect to run short this winter, and supply is why: Lower 48 output at 113.8 Bcf a day, gas rigs at 134, end-October inventories still projected near 3,985 Bcf. The demand support is real but conditional. Corpus Christi took its seventh train Aug. 28 and now runs 3.1 Bcf/d nominal, second only to Sabine Pass, and Europe is 69% full against an 85% norm. For a marketer the read is that winter optionality is being sold cheap. Storage is lean enough that one sustained cold pattern re-prices the front.
The flexibility build is shaving the evening peak faster than the forwards re-price
ERCOT's installed battery fleet hit roughly 15 GW and 24.6 GWh in early 2026, up from 7.8 GW a year earlier, and the capital behind the next wave is already committed. Jupiter Power closed $1.4 billion across four transactions funding ten projects totaling 1,500 MW and 3,600 MWh in Texas and Michigan. Underneath that the cost floor is dropping: B2U's 28-MWh Bexar Martinez site runs entirely on more than 700 repurposed car batteries at as much as 40% below a conventional build, with another 50 MWh landing in six months. Both Texas sites are merchant, so they show up wherever the spread is.
Supply is arriving from the demand side and the solar side at once. Apex and Meta took their joint portfolio to 1.2 GW with a 144-MW Starling PPA in Gonzales County, and every block of that competes into the same afternoon. School districts are enrolling electric buses in utility grid programs and clawing back thousands per bus, flexibility parked on a predictable schedule right on the congested distribution circuits. A judge also vacated EPA's termination of the $7 billion Solar for All program. The evening scarcity hours you are underwriting are being shaved by megawatts that were not in last year's model.