Here’s some unwelcome deja vu. According to the organization that oversees the reliability of America’s power grid, much of the country could face blackouts again this winter.

Warnings of winter blackouts are becoming a seasonal fixture. Texas experienced a devastating power outage in February 2021. And a bitter cold snap last Christmas forced utilities to implement rolling blackouts across multiple states.

Now, the North American Electric Reliability Corporation (NERC) fears that a prolonged cold snap could threaten the nation’s natural gas infrastructure and the power plants that rely on it. In short, many of the power plants needed to keep America’s homes and businesses warm could be left without fuel.

NERC explains that “in recent winter reliability events, over 20 percent of generating capacity has been forced off-line when freezing temperatures extend over parts of North America.” That’s because utilities experience sharp increases in electricity demand at precisely the moment that frigid conditions constrict their fuel supplies.

America is relying more heavily than ever on natural gas to generate electricity. And doing so has made the nation’s energy supply more vulnerable. Although we’re counting on natural gas to shoulder more of our energy needs, the infrastructure required to move it hasn’t kept up. And that’s a problem because, even though power plants have mandatory standards to prepare for freezing events, the natural gas system itself does not. And so, when wellheads or pipelines freeze, power plants even hundreds of miles away are left without fuel. The nation’s top energy regulator calls this a “reliability gap.”

Last Christmas, the operators of the PJM electricity grid–which serves 65 million Americans from Chicago to Virginia–were forced to beg customers to conserve power when the system lost 32 gigawatts of power capacity, enough to power 20 million homes. An incredible 70 percent of PJM’s outages were natural gas plants.

While no power source is immune to the ravages of bitter cold, the natural gas system is proving particularly vulnerable. And yet, at the very moment that America’s power grid is being pushed closer to the breaking point, the U.S. Environmental Protection Agency (EPA) has launched a blitz of rules to accelerate the closure of essential power plants. While the rules immediately target the nation’s remaining coal fleet, they will eventually focus on natural gas plants as well. Together, coal and natural gas currently provide 60 percent of America’s power.

The EPA’s regulatory onslaught is dangerous because coal is still providing an essential grid reliability backstop during peak winter months. Coal plants are winterized, and can store months of fuel on site. When natural gas supplies are diverted for home heating, or pipelines freeze, or solar power is unavailable during storms and long winter nights, coal plants come to the rescue–ramping up generation to fill gaps and keep the system running.

Until we have a reliable replacement for this essential capacity, accelerating their retirement will simply lead to more trouble. And yet the EPA is still charging ahead.

When blackouts come this winter–or the next–the underlying cause won’t be weather or aging infrastructure. It will be a colossal policy failure. Unless we rapidly strengthen the reliability of our power supply now, we could see a bad situation grow far worse.

Terry Jarrett is an energy attorney and consultant who has served on both the board of the National Association of Regulatory Utility Commissioners and the Missouri Public Service Commission.