Duke Forecasts 22,295 MW in the Carolinas, and DOE Clears Data Center Backup Generators to Run Before Load Shedding
- FERC & Federal Policy & Markets
Marin Holt
- 0
- 8 minutes read
- Peak Demand Forecast: 22,295 MW
- DOE Order: No. 202-26-43
- Order Window: September 3 through September 8
- Heat Index Forecast: 100 to 105 degrees
The U.S. Department of Energy directed Duke Energy Carolinas to run emergency generation on September 3. The order also lets the utility call on backup generators at Carolinas data centers. These generators must operate before any firm load shedding. Duke told DOE it expected peak demand of about 22,295 MW. Forecast temperatures reached 97 degrees, with afternoon heat index values of 100 to 105. DOE Order No. 202-26-43 took effect September 3 and runs through September 8.
The order gives Duke two separate powers. First, DOE directs Duke to dispatch a list of Specified Resources. Exhibit A of the utility application names these resources. Duke runs them only as needed to maintain reliability. Second, DOE lets Duke direct backup generation at large load sites. This serves as a last resort call, made just before Duke declares an Energy Emergency Alert 3, or during one. At EEA 3, a balancing authority starts to interrupt firm load.
DOE wrote the backup generation clause broadly. It covers auxiliary, standby, directly connected, and battery storage resources. These resources qualify whether or not they synchronize to the bulk power system. The Duke application names data centers, including hyperscaler facilities. It also names other large industrial and commercial customer sites. Duke holds authority to call on its Transmission Owners to carry out the order.
One carve-out limits the order’s reach. It does not apply to backup generation that serves a critical reliability or backup need. DOE names defense and homeland security sites, first responders, air traffic control, hospitals, and 911 call centers. The list also covers water and wastewater plants, along with natural gas pipeline and gathering facilities.
Duke expects the order to push units past permit restrictions on nitrogen oxides, carbon monoxide, and volatile organic compounds. DOE addressed that cost directly. Emissions, hours of operation, and fuel burned under the order do not count toward rolling average limits. DOE set that position in its February 4, 2026, order granting rehearing. Duke must send DOE a daily notice naming each resource that used the allowance.
Why It Matters
Backup generators at data centers have moved from private insurance to a grid resource. A utility now directs them under federal order. Duke holds that authority through the hottest week of the year. Large load customers in the Carolinas should read Exhibit A and the carve-out list closely. Those two documents decide which sites Duke calls and which it passes over. The emissions allowance matters just as much. A site that runs its backup generation under this order does not spend the permit headroom it needs for the rest of the year. That removes the main reason a plant manager would refuse the call.
This is the seventh 202(c) order document to name Duke Energy Carolinas or Duke Energy Progress in 2026. DOE issued Orders 202-26-05 and 202-26-07 in late January during Winter Storm Fern. It extended both to February 3. Order 202-26-27 covered roughly 30 hours on June 11 and 12. Order 202-26-34 ran from July 2 through July 6.
The structure changed this time. January split the dispatch power and the backup generation power across two documents. The June and July orders carried the dispatch power alone. Order 202-26-43 combines both in one document.
Critical Perspective
The order authorizes Duke. It does not compel any specific unit to run. Duke picks which Specified Resources it dispatches. Paragraph G lets Duke add units mid-order with only written notice to DOE afterward. DOE holds a veto it exercises after the fact. So, the public record of what actually ran arrives late.
The rolling average exemption deserves more scrutiny than the five-day window does. Emissions, run hours, and fuel burned under this order do not count toward rolling limits. Those limits exist to cap cumulative output, not single bad days. Duke has now drawn seven such order documents in 2026. A carve-out repeated that often starts to work as a standing amendment to an annual permit. No permit proceeding ever opened.
Then there is the word emergency. DOE described the September heat days in advance. Duke filed on the same day the order issued. A 22,295 MW September peak in the Carolinas is a forecastable condition, not a surprise. Using an emergency instrument on a foreseeable summer peak treats a resource adequacy question as an operational one. The resource adequacy question never reaches a commission.
Sources
- U.S. Department of Energy, “Energy Secretary Secures Carolinas’ Grid Ahead of Holiday Weekend,” September 3, 2026
- DOE Order No. 202-26-43, full order text, September 3, 2026
- DOE CESER, “Federal Power Act Section 202(c): Duke Energy Carolinas, LLC (Duke) Order No. 202-26-43”
- DOE CESER, “2026 DOE 202(c) Orders”
