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The Cost

Retiring coal plants forced open

DOE emergency orders kept retiring fossil plants running, with the costs passed to ratepayers.

StatusIn effectImpactSevere · 4/5Sources6CorrectedSep 29, 2026

Key facts

  • $3-6B/yr projected cost
  • Multiple states
  • Section 202(c) orders

Summary

Under Trump's grid executive order, DOE issued repeated emergency orders forcing fossil plants slated for retirement to keep operating, which an analysis commissioned by environmental groups projected could cost ratepayers $3 billion to nearly $6 billion per year if extended to plants slated to retire through 2028.

What happened

Beginning May 23, 2025, under Trump's grid executive order, DOE issued repeated Section 202(c) 'emergency' orders compelling fossil plants slated for retirement to keep operating, including the J.H. Campbell coal plant in Michigan, coal plants in Indiana, Washington state and Colorado, an oil-fired plant in Pennsylvania, and a coal plant in Florida. A Grid Strategies analysis commissioned by Earthjustice, EDF, NRDC and Sierra Club projected that keeping large fossil plants scheduled to retire through 2028 running could cost ratepayers over $3.1 billion per year, and nearly $6 billion if orders extended to more older plants.

Impact on the United States

Shifts the cost of keeping retiring plants open onto ratepayers - Consumers Energy reported $80 million to keep the Campbell plant open from late May to late September 2025, and an analysis commissioned by environmental groups projected $3 billion to nearly $6 billion a year if such orders spread - while prolonging soot, smog and CO2 emissions near the plants.

Documented effects

  1. Section 202(c) emergency orders kept multiple retiring coal and fossil plants running across six-plus states[1]
  2. Grid Strategies analysis commissioned by environmental groups projected $3.1 billion to nearly $6 billion per year in added ratepayer costs if such orders covered plants slated to retire through 2028[3]
  3. Emergency order kept a Florida coal plant operating[2][4]
  4. The D.C. Circuit vacated DOE's first Campbell order on September 11, 2026, holding that Section 202(c) applies only where DOE identifies a risk of substantial harm from inadequate electricity supply calling for immediate federal action, and that the circumstances DOE cited did not qualify[6]

Why this is rated severe

Keeps retiring fossil plants running at ratepayers' expense ($80 million for one plant over four months, per Consumers Energy; an analysis for environmental groups projected $3-6 billion a year if extended) and prolongs their emissions; the D.C. Circuit vacated the first order in September 2026.

on September 11, 2026 the D.C. Circuit vacated DOE's first J.H. Campbell order, holding it exceeded DOE's Section 202(c) emergency authority

Corrections & updates [6]

Every change to a fact on this page after publication is logged here, newest first.

  1. CorrectedSource

    The EDF release on the Grid Strategies cost report is dated August 14, 2025, not December 1, 2025.[3]

  2. ClarifiedFigure

    The $3-6 billion figure is a projection by Grid Strategies, commissioned by Earthjustice, EDF, NRDC and Sierra Club: over $3.1 billion a year if large fossil plants scheduled to retire through 2028 were kept running, and nearly $6 billion if orders extended to more older plants. It is not a measured cost of the orders issued so far.[3]

  3. ClarifiedSource

    Added DOE's own Florida order (Order No. 202-26-26, Stanton Energy Center Unit 1, Orlando Utilities Commission), which cites Executive Order 14262 on grid reliability as part of its basis.[4]

  4. CorrectedSummary

    Corrected: the plants named as Eddystone and Centralia are not named in the cited sources. CNN reports orders for two coal plants in Indiana, one in Michigan, one in Washington state, one in Colorado and an oil-fired plant in Pennsylvania; the first order (J.H. Campbell, Michigan) was issued May 23, 2025, per the Department of Energy. Projected costs are now attributed to the environmental groups' analysis rather than stated as realized.[1][5][3]

  5. UpdatedStatus

    Updated: on September 11, 2026 the U.S. Court of Appeals for the D.C. Circuit vacated DOE's first order for the J.H. Campbell plant, holding that it exceeded DOE's emergency authority under Section 202(c) of the Federal Power Act (Michigan v. Department of Energy, No. 25-1159). The court noted the order had already expired.[6]

    Previously
    in-effect
    Now
    in-effect (on September 11, 2026 the D.C. Circuit vacated DOE's first J.H. Campbell order, holding it exceeded DOE's Section 202(c) emergency authority)
  6. ClarifiedSeverity rationale

    Clarified that the $3-6 billion figure is a projection if the orders were extended, and added the D.C. Circuit ruling. Severity unchanged.

    + Show previous and current text
    Previously
    Subsidizes high-emission plants at a projected $3-6 billion a year in ratepayer cost (per an analysis for environmental groups) and added pollution.
    Now
    Keeps retiring fossil plants running at ratepayers' expense ($80 million for one plant over four months, per Consumers Energy; an analysis for environmental groups projected $3-6 billion a year if extended) and prolongs their emissions; the D.C. Circuit vacated the first order in September 2026.

Sources [6]

Image: Boyd Norton, Public domain (Wikimedia Commons)

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