On December 30, 2025, the U.S. Department of Energy (DOE) issued Order No. 202-25-14 (DOE Order). The Order prevents the planned retirement of Craig Station Unit 1 on grounds of “a shortage of electric energy, a shortage of facilities for the generation of electric energy, and other causes” in the Western Electricity Coordinating Council (WECC) Northwest assessment area. According to DOE, “the emergency conditions resulting from increasing demand and shortage from accelerated retirement of generation facilities will continue in the near term and are also likely to continue in subsequent years.”
The DOE Order contains only one definition of the WECC Northwest assessment area, stating that it “includes Colorado, Idaho, Montana, Nevada, Oregon, Utah, Washington, and Wyoming.” DOE’s definition may derive from the 2024 Long-Term Reliability Assessment (LTRA) of the North American Electric Reliability Corporation (NERC). Figure 1 shows the NERC-defined area.
Figure 1: NERC-Define WECC Northwest Assessment Area
In support of its determination, DOE relies on a few sources: (1) NERC’s 2024 LTRA, (2) WECC’s 2024 Western Assessment of Resource Adequacy (WARA), (3) DOE’s own resource adequacy study, and (4) information published by the Energy Information Administration.
This report evaluates whether the sources on which DOE relies support a finding of the current existence of a resource adequacy crisis for the short-term future (i.e., in 2026) or for the medium-term future (i.e., in 2027–2031) in the WECC Northwest assessment area. CEG did not conduct a new or independent resource adequacy model; rather, this report analyzes how, if at all, the methodology, assumptions, and conclusions in DOE’s cited sources speak to the existence of any such crisis in the area. This report also explains the fundamentals of resource adequacy planning and assessments. Additionally, because the Pacific Northwest is within the area in which the Order asserts the existence of emergency conditions, our recent report on “Resource Adequacy in the Pacific Northwest” informs our opinion here and is part of this report in Appendix A.
We conclude that DOE’s sources do not support the existence of a resource adequacy crisis in the WECC Northwest assessment area. The 2024 Long Term Reliability Assessment finds no elevated reliability risk across the broader WECC regions, assigning the region its lowest possible risk rating. The 2024 Western Assessment of Resource Adequacy finds no demand-at-risk hours in 2026 and almost none in 2027 in the three subregions that roughly correspond to the WECC Northwest assessment area. DOE’s July 2025 study focuses on long-term scenarios and, even under highly conservative assumptions, does not find evidence of a near-term resource adequacy crisis in Colorado or the broader region. Finally, the Energy Information Administration’s data on planned power plant retirements and additions show substantial net generation additions in Colorado beyond the retirements cited in DOE’s Order and do not support the finding of a near-term or medium-term resource adequacy shortfall. Moreover, the retirement of Craig Station Unit 1 represents a long-planned transition that is reflected in regional planning analyses and is not identified as a driver of either near-term or medium-term reliability risk.
The potential for load-growth driven resource shortfalls identified by the studies in 2030 reflects the normal and intended function of resource adequacy planning: to identify risks with sufficient lead time for state, regional, and utility processes to respond through deliberate, coordinated action, as they have done for decades.
Authors:
Brad Cebulko, Erik Olson, Ed Burgess
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