What has actually been done to the U.S. energy system since January 2025 — and where each piece stands today.
Most of this has not happened through legislation. There is one major statute. Everything else runs through emergency powers, lease settlements, rule rescissions, permitting procedure, and agency orders — each technical enough on its own to be covered as an isolated story and then dropped.
This page collects them and sorts them by the mechanism used, because the mechanism is what determines how durable each change is. An emergency order can be vacated in a year. A repealed tax credit takes an act of Congress to restore. A signed lease buyout is close to permanent.
Record current through September 13, 2026
How to read this. Every entry states what an agency or court did, on what date, and its status now. Where an official gave a stated rationale, it is reported as a stated rationale. Where the action is being challenged, the challenge is noted. Nothing here argues that any of it is good or bad policy — that judgment is yours to make, which is easier with the record in one place.
Emergency powers used to keep plants running
Section 202(c) of the Federal Power Act lets the Energy Secretary order a generator to run during an emergency. It was written for hurricanes and sudden grid failures. Since May 2025 it has been used to stop scheduled retirements — coal units mostly — and it is the single most-litigated tool on this list.
DOE ordered the 1,560 MW coal plant to stay online past its scheduled May 31, 2025 retirement. The order was extended three times, running through May 18, 2026. Michigan, Illinois and Minnesota petitioned the D.C. Circuit; opening briefs were filed December 19, 2025.
760 MW of oil and gas capacity held open, extended three times through May 24, 2026. Officials from Illinois, Maryland and New Jersey, plus environmental groups, petitioned the D.C. Circuit in September 2025.
Centralia Unit 2 in Washington (~730 MW, Dec 16), Schahfer Units 17 & 18 in Indiana (~847 MW, Dec 23), F.B. Culley Unit 2 in Indiana (~103 MW, Dec 23), and Craig Station Unit 1 in Colorado (~446 MW, Dec 30).
Washington's Attorney General petitioned the Ninth Circuit on March 2, 2026. In Colorado, the plant's own owners — Tri-State G&T and Platte River Power Authority — filed for rehearing on January 29, 2026, joined by the state a day earlier.
By April 2, 2026 the department had issued 43 separate 202(c) orders and extensions covering six generating stations. Cost estimates for the power bought under these orders range from $235 million across the first 13 orders to more than $300 million, depending on who is counting and how.
Worth noting: reporting has found the plants held open under these orders generated substantially less power than before the orders were issued.
The D.C. Circuit vacated the J.H. Campbell order, holding that DOE lacked authority under Section 202(c). The court found "emergency" must mean a grid crisis requiring immediate action, not a medium- or long-term supply concern, and that the department's justification rested on fragmentary documents rather than a demonstrated emergency. It rejected what it called the agency's sweeping conception of its emergency powers.
The ruling does not automatically void the other active orders, but it substantially weakens their footing. DOE may seek Supreme Court review.
One day after the D.C. Circuit ruling, the Energy Secretary issued a further order keeping a Northwest coal generating plant online, citing grid reliability. Whether the new order is written to survive the reasoning in the Campbell decision is the open question.
Offshore wind: halted, then bought out
This one moved in two distinct phases. Through 2025 the approach was administrative — withdrawals, stop-work orders, suspensions — and courts reversed nearly all of it. In 2026 the approach changed to paying leaseholders to walk away, which courts cannot easily undo.
A presidential memorandum halted future lease sales, paused permitting, and ordered a review of federal wind leasing practices. The same day, Interior's acting secretary issued Order 3415 suspending the department's authority to issue renewable energy authorizations.
BOEM issued a stop-work order against the New York project on April 16. It was lifted on May 19 after negotiations with state and local officials.
Secretary's Order 3437 (July 29) directed a department-wide review of wind policies. Order 3438 (August 1) required "capacity density" to be weighed in environmental reviews — a criterion that disadvantages wind and solar relative to denser generation. On August 5, BOEM rescinded the wind leasing schedule and 3.5 million acres of designated wind energy areas.
Separately, DOT recommended a 1.2-mile setback for turbines near highways and railroads (July 29), and on August 29 withdrew $679 million in port infrastructure funding across six states, of which $22.4 million had already been spent.
Stop-work order issued August 22 against the Rhode Island and Connecticut project. A court granted a preliminary injunction on September 22, allowing construction to resume.
A federal district court in Massachusetts vacated Interior Order 3415 as arbitrary and capricious, finding the agencies had paused wind authorizations without the reasoned decision-making the Administrative Procedure Act requires.
BOEM suspended leases for all five large offshore projects then under construction: Coastal Virginia (2.6 GW), Empire Wind (2 GW), Sunrise Wind (924 MW), Vineyard Wind 1 (800 MW), and Revolution Wind (700 MW). Interior cited national security risks identified in recently completed classified reports, with the Secretary describing radar interference from turbine blades and towers.
Dominion Energy responded that Coastal Virginia supports military installations and that Virginia's demand growth is driven by bases, shipbuilding and data centers.
Courts enjoined all five suspensions within six weeks: Revolution Wind (Jan 12), Empire Wind (Jan 15), Coastal Virginia (Jan 16), Vineyard Wind (Jan 27, the court calling the suspension "irrational"), and Sunrise Wind (Feb 2).
Having lost repeatedly in court, the administration began settling. Five agreements were reached with TotalEnergies, Duke Energy, Ocean Winds, Invenergy and RWE, together exceeding $3.9 billion. Leaseholders relinquish federal offshore acreage; several commit to fossil investment instead.
The largest, announced August 6–7, 2026, pays RWE $1.22 billion to give up three leases — New York Bight, Canopy off California, and Lake Charles off Louisiana. RWE's side includes a $900 million stake in a Louisiana LNG project, a $300 million turbine reservation, a pipeline of 15 gas peaking projects, and $19.6 billion of planned U.S. investment over six years.
New York, Massachusetts and California are suing to stop the deals.
Removing the legal foundation for climate rules
Rather than repeal individual regulations one at a time, EPA moved against the finding that authorizes them. The 2009 endangerment finding — the determination that greenhouse gases endanger public health and welfare — is the legal hook nearly every federal climate rule hangs from.
EPA issued a final rule rescinding the greenhouse gas endangerment finding along with motor vehicle greenhouse gas standards. Health and environmental organizations petitioned for reconsideration and filed suit. The litigation is live and its outcome determines how much of the rest of federal climate regulation survives.
EPA proposed rescinding greenhouse gas standards for fossil-fired power plants under Clean Air Act section 111, on the reasoning that these plants do not contribute significantly to dangerous air pollution.
The final repeal was sent to the Office of Management and Budget on May 14, 2026 and had not taken effect as of late August 2026. The D.C. Circuit case over the original standards, West Virginia v. EPA, has been held in abeyance since April 2025 while the rewrite proceeds.
Tax credits ended by statute
The one piece that went through Congress, and therefore the one piece courts cannot touch. Restoring any of it requires new legislation.
Wind and solar (45Y, 48E): terminated for facilities placed in service after December 31, 2027 — with an exception for projects that began construction by July 4, 2026. That exception created a hard deadline that shaped development schedules through the following year. Other technologies phase out from 2034.
Vehicles: the clean vehicle credit (30D) and commercial clean vehicle credit (45W) both ended September 30, 2025.
Households: the residential clean energy credit (25D) and the energy efficient home improvement credit (25C) both end after 2026.
Supply chain: from 2026, foreign entity of concern rules bar credits where a prohibited foreign entity is involved, with escalating cost-ratio thresholds of 40 to 60 percent depending on technology and year. These reach 45Y, 48E, 45X, 45Q, 45U and 45Z.
Environmental review rewritten
Permitting changed through an unusual combination: a Supreme Court decision narrowing what agencies must study, an executive order, and then the wholesale removal of the government-wide rules that had governed environmental review since the 1970s.
The Court limited the scope of effects agencies must analyze under the National Environmental Policy Act, reducing the reach of environmental review and the grounds on which approvals can be challenged.
Responding to Executive Order 14154 and the Seven County decision, federal agencies replaced the common framework with individual procedures. Reviews are now governed agency by agency rather than by one shared rule.
The Council on Environmental Quality published a final rule removing its NEPA implementing regulations from the Code of Federal Regulations. The statute remains law; the uniform rules interpreting it are gone. Practical effect cuts both ways — faster reviews in some cases, less settled precedent and more litigation risk in others.
Federal acreage and export approvals reopened
The most conventional items on the list, and the ones that behave most like past changes of administration: leasing restarted, export licensing resumed.
Executive Order 14156 declared a national energy emergency; the "Unleashing American Energy" order directed agencies to remove barriers to development. Interior moved to restore leasing in the Arctic National Wildlife Refuge and the National Petroleum Reserve–Alaska, and to remove obstacles to Arctic leasing generally.
The pause on non-FTA LNG export authorizations was lifted and approvals resumed. Alaska LNG completed its federal permitting ahead of schedule.
Nuclear licensing overhauled
The least contested item here. Nuclear expansion has support in both parties, and these orders have drawn comparatively little litigation.
The orders direct reform of the Nuclear Regulatory Commission, faster reactor licensing, fuel supply chain development, and reactor deployment on federal and military sites. The stated target is roughly 400 GW of capacity by 2050, about quadruple current levels.
Critical minerals treated as trade security
Minerals were moved out of environmental and land-use policy and into national security and trade law, which carries different authorities and far fewer procedural constraints.
An executive order directed a Section 232 national security investigation into processed critical minerals, rare earth elements and derivative products. Results were announced in January 2026, with officials directed to open trade negotiations. Section 232 authority permits tariffs and import restrictions on national security grounds.
The demand problem nobody planned for
Everything above concerns supply. The pressure that now shapes all of it is demand — data centers — and the electricity bills that have followed. This is where energy policy stopped being a trade-press subject.
Analysts have attributed the increase to data center demand growth colliding with constrained generation and transmission, alongside other drivers including transmission investment and fuel costs. Utility rate increase requests reached record levels. How much of the rise is attributable to data centers specifically remains genuinely disputed.
Seven technology companies — Amazon, Google, Meta, Microsoft, OpenAI, Oracle and xAI — signed a voluntary pledge to keep data center costs off household bills. Signatories commit to build, bring or buy their own new generation, cover the delivery infrastructure their facilities require, negotiate separate rate structures with utilities and states, pay agreed rates regardless of usage, and make backup generation available to grid operators.
The pledge is voluntary and carries no enforcement mechanism. Whether it holds is a question for state utility commissions, not federal agencies.
Data centers and utility bills have become a significant issue in the 2026 midterms — the point at which the technical record above starts driving votes rather than just dockets.
Sources
- Harvard Environmental & Energy Law Program — Federal Offshore Wind Deployment tracker
- Harvard EELP — Power Plant Greenhouse Gas Regulation tracker
- Georgetown Climate Center — Federal Actions on Wind Development
- POWER Magazine — Log of DOE Section 202(c) emergency orders
- U.S. Department of Energy — 202(c) orders, primary source
- Utility Dive — D.C. Circuit vacates the Campbell emergency order
- Utility Dive — Interior suspends the five offshore projects under construction
- Maritime Executive — The offshore wind lease settlements
- U.S. EPA — Final rule rescinding the endangerment finding, primary source
- Sidley Austin — One Big Beautiful Bill Act energy tax provisions
- Federal Register — Removal of NEPA implementing regulations, primary source
- The White House — Ratepayer Protection Pledge, primary source
- Holland & Knight — The four nuclear executive orders
- Covington — Section 232 critical minerals investigation results
- Brookings — Data centers as a 2026 midterm issue
MWS Energy Desk · My Wire Service
Corrections welcome. This record is only useful if it is right.