RTO Reliability Reforms: Disguised Attacks on Renewable Energy Under the Guise of Grid Security
Project 2025's proposals for FERC and RTOs frame renewable integration as a reliability threat, urging pricing reforms, reserve-margin changes, expanded gas infrastructure, and reliability pricing for dispatchable generation. While some FERC orders have begun altering market rules, the core restructuring—weakening renewables' market access and mandating dispatchable generation—remains on paper. The proposals risk locking in fossil dependency by distorting market signals away from clean resources.
Project 2025's FERC/RTO proposals, detailed in Chapter 13, weaponize the language of 'reliability' and 'market economics' to justify a fundamental restructuring of electric grids. They call for limiting the impact of subsidized renewables on price formation, updating reserve margins to exclude non-dispatchable resources, expanding natural-gas infrastructure, and requiring RTOs to create reliability pricing for dispatchable generation. The subtext is clear: wind and solar are cast as unreliable interlopers, while coal, gas, and nuclear are positioned as the only trustworthy backbone. But the math does not support this narrative. Intermittent resources are already being paired with storage, demand response, and grid-enhancing technologies to provide firm, clean power. Studies from RMI and LBNL show that integrating high penetrations of renewables (up to 80%+) is feasible without sacrificing reliability—if markets value flexibility and energy storage. The real reliability threat is climate change itself: more frequent extreme weather events (heat domes, polar vortices, wildfires) stress a grid still dependent on precisely the fossil plants the proposals prioritize. These FERC proposals, if fully enacted, would lock in fossil dependency for decades by distorting market signals away from clean resources and toward dispatchable but carbon-intensive generation. They would also accelerate natural-gas infrastructure buildout, locking in methane leaks and carbon emissions at precisely the moment the IPCC says we must rapidly decline. The alternative is a grid built on distributed clean energy, storage, and energy efficiency—paired with FERC-reformed markets that value reliability from diverse, flexible resources. Environmental justice demands that the transition not replicate the pollution burdens already borne by frontline communities near coal and gas plants.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Rescind EPA's 2026 final rule rescinding the Endangerment Finding The next EPA administrator must initiate a new rulemaking under Clean Air Act Section 202(a) to reinstate the 2009 Endangerment Finding, based on the extensive scientific record already in place, and defend it through public comment and potential litigation.
- Re-establish the Office of Environmental Justice and External Civil Rights The EPA administrator should issue an internal reorganization directive to re-establish the office, restore its staff and budget, and reissue guidance for environmental justice considerations in all EPA actions; Congress can support this through appropriations language.
- Restore EPA's greenhouse gas emission standards for vehicles and other sectors Once the Endangerment Finding is reinstated, the EPA must reissue or strengthen sector-specific rules for vehicles, power plants, methane, and other sources—each via notice-and-comment rulemaking—to fulfill the Clean Air Act's mandate.
Reversing it is step one. The forward agenda — what we build so it can’t recur — is in Answers to this entry →
Grounded in
- EPA Launches Biggest Deregulatory Action in U.S. History
- Regulatory Tracker - Environmental and Energy Law Program
- Trump's Climate and Clean Energy Rollback Tracker
- 2025 EPA Rollbacks & Environmental Policy Changes - Interactive Timeline
- Final Rule: Rescission of the Greenhouse Gas Endangerment Finding
- Greenhouse Gas Endangerment Finding - Environmental and Energy Law Program
- Twelve Policy Priorities to Secure Bulk Electric Reliability
- New Energy Market Regulations and Trends in 2025
Original source — excerpted
project2025 Project 2025 ch. 13: EPA (pp 434-436)"— 401 — Department of Energy and Related Commissions nation in the summer110 and winter.111 Cyber and physical attacks also threaten the grid. Specific areas for reform include the following: l Limit the impact of subsidized renewables on price formation. Subsidized renewable resources are undermining electric reliability in RTOs. The increase in subsidized, intermittent resources is undermining the ability of RTOs’ pricing models to support the reliable dispatchable generation that is needed to serve the grid at all times.112 l Reform the application of reserve margins. Reserve margins have become largely meaningless. Traditionally, the electric industry has used “reserve margins” to ensure that the grid has enough power plants to guarantee reliability. Generally, reserve margins represent the amount of generation available (power plants) to meet peak electric demand (the time of day and year when people are using the most electricity) plus a percentage of additional generation for backup.113 However, given the increasing number of intermittent resources (like solar, which may be available during the heat of the day but disappears as the sun sets), other dispatch…"