NO OUTAGESMontana Backup Power

Regulatory brief

What DOE Order 202-26-37 says and what it does not

On July 26, 2026 the U.S. Department of Energy issued an order under Federal Power Act § 202(c) authorizing Southwest Power Pool to direct backup generation resources as a last resort. This page summarizes that order, the SPP West expansion behind it, and the Montana rules that stack on top.

Storm front moving over Montana transmission lines in winter

The federal layer

The order, in its own terms

Order number
DOE Order No. 202-26-37
Issued
July 26, 2026
Legal authority
Federal Power Act § 202(c)
Effective through
August 3, 2026
Requested by
Southwest Power Pool, after consecutive energy emergency alerts in the SPP West Balancing Authority Area
Core provision
SPP may direct backup generation resources to operate as a last resort before declaring an Energy Emergency Alert Level 3, or during an EEA 3
Resources covered
Auxiliary, standby, directly connected, and battery backup generation resources

Directs the Southwest Power Pool to dispatch specified generation units and explicitly authorizes SPP to direct backup generation resources to operate as a last resort before declaring an Energy Emergency Alert Level 3, or during an EEA 3. Issued at SPP's own request after consecutive energy emergency alerts in the SPP West Balancing Authority Area.

The regional layer

Why Montana is inside a Southwest Power Pool order

Southwest Power Pool completed its expansion into the Western Interconnection, becoming the first RTO to span both the Eastern and Western grids across 17 states. Montana sits inside the SPP West Balancing Authority Area, which has already issued multiple Energy Emergency Alerts in July 2026.

The states now inside the SPP West Balancing Authority Area are Arizona, Colorado, Montana, Nebraska, New Mexico, Utah, Wyoming. Regional membership brought market benefits; it also means regional emergency procedures now reach Montana facilities directly.

SPP West Balancing Authority Area

Live since April 1, 2026. SPP is now the first RTO operating across both the Eastern and Western Interconnections, spanning 17 states in total.

The local layer

Three separate exposures, one result

01

Montana HB 490

Requires electric providers to include de-energizing strategies in their wildfire mitigation plans. This is the legal basis for planned, proactive power shutoffs during extreme wildfire conditions.
02

Utility practice on the ground

NorthWestern Energy maintains an active Public Safety Power Shutoff plan, and Bonneville Power Administration has already shut transmission-level power to Flathead Electric members in Libby under wildfire risk.
03

Winter, independent of all of it

Winter storm and cold-weather outages remain an independent, year-round exposure across Western Montana, unrelated to wildfire shutoffs or federal emergency orders.

In plain terms: the utility or grid operator can now turn your power off on purpose, or call private generators online, when conditions demand it. Winter storm risk remains an additional, independent threat across Western Montana.

What it means

Practical implications by risk

Outage length becomes weather-driven
When a line is de-energized preventively, restoration waits for the weather window to close and for patrol crews to inspect the circuit, not for a repair crew. Plan for days, not hours.
Notice may be short or nonexistent
Proactive shutoffs are triggered by forecast conditions that change quickly. A backup plan that depends on advance warning is not a plan.
Rural feeders are first candidates
Long radial lines through timber and grass carry the highest ignition and failure risk, and that is exactly where the fewest alternatives exist.
Having capacity makes you visible
The DOE order covers backup generation resources broadly. Owning a well-documented, properly interconnected system is how you stay the operator of it.
Commercial obligations do not pause
Refrigerated inventory, life-safety systems, patient care, and contractual uptime commitments continue to apply during a shutoff you did not cause.
Documentation is the deliverable
Insurers, lenders, and regulators ask for records, not intentions. A load study, a code-compliant install, and a maintenance log are the evidence.

What we are not saying

An honest reading of the limits

01

This is not a mandate to buy

The order directs grid operations. It does not require any private party to install backup generation. We think owning your own power is the right call; the federal government has not said so.
02

Obligations are fact-specific

Whether and how any directive reaches a particular facility depends on interconnection status, size, and instructions from the relevant reliability coordinator or balancing authority.
03

Orders have end dates

This order was issued effective through August 3, 2026. The authority it exercises, and the conditions that prompted it, both outlast the document.

Disclaimer

This page summarizes publicly available information regarding DOE Order No. 202-26-37 and SPP operations. It does not constitute legal, regulatory, or engineering advice. Actual obligations under any emergency order depend on specific facts, facility interconnection status, and directions issued by the relevant reliability coordinator or balancing authority. Consult your legal counsel and utility for facility-specific guidance.

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