The following was written by Todd Staples, President, and Dean Foreman, Ph.D., Chief Economist, at the Texas Oil & Gas Association (TXOGA):

The April 17 joint staff report by the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) on the January 2025 winter storms presents itself as a comprehensive review of system performance, yet sprinkles in offhanded critique about ERCOT gas-electric coordination. But a clear-eyed assessment of Texas’ electric grid this winter would highlight reliability, resilience, and measurable progress rooted in operational improvements. FERC and NERC, however, fail to acknowledge these facts and instead fall back on familiar, unproductive mantras.

To be clear, this year’s Arctic storms were serious. Temperatures dropped into single digits across the Gulf Coast, with significant snowfall reported in Houston and much of Texas. On January 22, U.S. electricity demand peaked at 683 gigawatts, while natural gas demand hit an all-time high of 150 billion cubic feet per day. Yet in ERCOT, there were no controlled power cuts to homes and businesses—a striking contrast with Winter Storms Uri (2021) and Elliott (2022), which caused widespread outages across multiple U.S. regions, including Texas.

The FERC/NERC report acknowledges improvements only in passing—citing better generator availability, improved preparedness, and stronger forecasting. Still, when discussing ERCOT, the report reverts to a boilerplate and misinformed critique: that limited communication with intrastate pipelines indicates a systemic gap. There is no gap. FERC/NERC want to regulate Texas pure and simple.

Despite a longer overall sequence of winter storms nationally this year, ERCOT experienced fewer unplanned outages than during Uri—a storm that brought deeper and more widespread freezing conditions specifically across Texas. Generator outages in the Texas Interconnection peaked at just under 14,000 megawatts—less than half the 34,000 megawatts lost in 2021. Thermal and dispatchable resources performed when it mattered most, supplying up to 97.8% of the grid’s electricity—including 69.8% from natural gas—on the morning of January 28. Generators self-scheduled and secured fuel in advance, while ERCOT relied on four independent weather models and refined load forecasts to improve preparedness for peak demand.

These are real, measurable gains—and they weren’t mandated by federal directive. They resulted from leadership and reforms directed by Governor Greg Abbott and Texas legislative leaders—including but not limited to Lt. Governor Dan Patrick, former Speaker Dade Phelan, Senator Charles Schwertner, and Representative Todd Hunter—deftly implemented by the Public Utility Commission, Railroad Commission, ERCOT planners, and private-sector operators who applied lessons from past failures and acted decisively. Texas implemented its own weatherization standards, invested in better data and tools, strengthened coordination through state-led efforts like the Texas Energy Reliability Council (TERC), and private operators expanded natural gas storage. In contrast, the FERC/NERC report offers little more than retrospective self-approval and fails to explain why other regions under federal oversight still suffered high generator outage rates. To be sure, coordination amongst all participants in the electric market must evolve. But we should question whether FERC and NERC’s approach—favoring uniform, federally driven mandates over regionally tailored solutions—actually strengthens grid reliability. Texas’ experience shows that flexibility, not one-size-fits-all regulation, can better meet the unique needs of different markets. The Texas model may not align with federal regulatory norms, but it continues to deliver, serving record and growing demand.

Rather than fault ERCOT for structural differences, regulators should recognize that innovation, decentralization, and market-based adaptation—not top-down mandates—are proving to be the most effective drivers of resilience. That’s the real lesson from Texas. And it’s one worth learning before the next storm arrives.