The Trump administration’s unprecedented use of emergency grid authorities entered a second phase in August 2025, as the Department of Energy (DOE) extended three critical reliability orders. The measures signal that this year’s historic string of federal interventions—staked in Section 202(c) of the Federal Power Act—are likely to continue beyond the traditional summer peak and into the winter planning season.
The DOE this month has issued, in quick succession, a string of new directives. On Aug. 28, the agency directed PJM Interconnection to keep Constellation’s Eddystone Units 3 and 4—two dual‐fuel steam boiler-turbine units of 380 MW each (760 MW total)—in Pennsylvania available through Nov. 26, extending a previous May 30 emergency order. A week ago, on Aug. 21, it ordered the Midcontinent Independent System Operator (MISO) to delay the retirement of the 1,420 MW J.H. Campbell coal plant in Michigan until Nov. 19—well past Consumers Energy’s anticipated retirement date of May 31. And on Aug. 14, the DOE granted the Puerto Rico Electric Power Authority (PREPA) an additional 90-day extension (through Nov. 12) of its two May 16 emergency orders, authorizing PREPA to dispatch up to 800 MW of specified aging thermal generation and to accelerate vegetation clearing along critical 115 kV and 230 kV corridors.
The August directives follow five prior emergency orders issued since May. As POWER has reported, the string of reliability-driven orders began on May 16, when DOE issued two emergency directives to PREPA: one to dispatch over 50 generation units and another to accelerate vegetation clearing after multiple island-wide blackouts. On May 23, DOE ordered MISO and Consumers Energy to delay the closure of Michigan’s J.H. Campbell coal plant to preserve reserve margins during the summer peak. A week later, on May 30, the DOE directed PJM and Constellation Energy to keep the Eddystone units in Pennsylvania online past their retirement dates. On June 24, DOE authorized Duke Energy Carolinas to operate multiple generators at maximum output during an extreme heat wave (that order expired on June 25). And on July 28, DOE issued its fifth emergency order, directing PJM to override environmental limits and dispatch the Wagner 4 oil-fired unit in Maryland through Oct. 26.
While the August orders represent extensions rather than new declarations, they suggest the DOE appears to view underlying grid stressors as persistent rather than transient, requiring sustained federal oversight beyond the traditional summer peak period.
“The U.S. continues to face an energy emergency, with some regions experiencing more capacity constraints than others,” Energy Secretary Chris Wright said last week as he ordered the Campbell plant to remain online. “With electricity demand increasing, we must put an end to the dangerous energy subtraction policies embraced by politicians for too long,” he said. This week, in a statement that ordered Constellation to keep Eddystone 3 and 4 operational until November, Wright again claimed the nation a faces energy emergency, citing “unprecedented energy demand and resource retirements outpacing new generation additions.”
Extended Orders Reflect Persistent Grid Stress, DOE says
On Thursday, the DOE rationalized the extensions by pointing, as it has in nearly all its recent emergency orders, to its July-issued Grid Reliability Evaluation. Issued under the April 2025 Executive Order 14262 with technical analysis from PNNL and NREL, the report warns that “blackouts could increase by 100 times in 2030” if retirement trends persist without adequate firm replacement capacity. While it projects 104 GW of dispatchable generation could retire by 2030, only 22 GW of new firm baseload capacity is expected to replace it—prompting a shortfall that the DOE said would exacerbate supply-demand imbalances so severe that “even assuming no retirements, the model found increased risk of outages in 2030 by a factor of 34.”
However, the emergency order extensions have drawn sharply divided reactions from stakeholders. While grid operators have generally supported DOE’s interventions as necessary reliability measures, the orders have intensified legal challenges from environmental groups and state officials, who argue federal interventions exceed statutory authority and impose unnecessary costs on ratepayers.
On July 25, Michigan Attorney General Dana Nessel’s filed a petition of review with the U.S. Court of Appeals, characterizing the DOE’s Campbell order as “arbitrary and illegal,” and outright calling it a “pretense of a fabricated energy emergency.” Meanwhile, a coalition of nine environmental groups led by the Sierra Club has mounted parallel legal challenges at the D.C. Circuit. “We are taking the Administration to court to stop its abuse of emergency powers and prevent further harm to our wallets and our health,” said Shannon Fisk, attorney and director of State Electric Sector Advocacy at nonprofit public interest environmental law organization Earthjustice. “While the Administration might not like that fact, a fabricated energy emergency does not give them the authority to saddle Michiganders with the costs and pollution of a coal plant that the utility has already replaced with other resources. The only energy emergency is the one being created by this unprecedented power grab by federal authorities.”
Campbell Builds on MISO’s 25-GW Fast Track Measure to Avert Capacity Gaps
When the DOE first issued its emergency order to MISO and Consumers Energy to keep the J.H. Campbell Units 3 and 4 coal units (a combined 1.4 GW) available beyond their scheduled retirement, it said the order was needed because “retirement of the J.H. Campbell facility at this time would create a reliability risk due to the potential for insufficient generation capacity to serve load in the event of higher than normal load, higher than anticipated forced outages, or underperformance of variable energy resources.”
The agency noted the Campbell units play a critical role in MISO’s Local Resource Zone 7, which covers much of Michigan’s Lower Peninsula. The units provide essential capacity during the summer peak, when the potential for grid stress was highest, it said, noting: “Consumers and MISO have identified that retiring these units could result in a loss of firm load under specific high-risk scenarios.”
In its Aug. 21 extension, the DOE said the emergency conditions that justified its May 23 order had not abated. It cited continued risks of power shortfalls in MISO’s Michigan zone due to “transmission constraints, generator maintenance outages, and increased likelihood of low wind conditions.” While the summer peak had passed, the DOE said reliability concerns would “remain during this fall period,” which justified the Campbell units’ availability through Nov. 19, 2025. The DOE, notably, also imposed specific emissions limits—6,900 tons of SO₂ and 2,350 tons of NOₓ over the emergency period—and said the extension was granted under Section 202(c) of the Federal Power Act because it was “necessary to best meet the emergency and serve the public interest.”
MISO has acknowledged resource challenges and moved quickly to address them. On Tuesday, notably, the grid operator signaled the scale of resource challenges driving federal emergency interventions when it announced that its Expedited Resource Addition Study (ERAS) attracted 47 projects across 12 states representing more than 26.5 GW of proposed new capacity—74% natural gas, 15% battery storage, 4% wind, 4% solar, and 3% nuclear.
The temporary fast-track process, designed to address “growing reliability challenges” and “accelerating demand growth,” will study up to 10 projects per quarter through August 2027, it said. “This broad mix underscores MISO’s evolving energy landscape and the urgent need to bring new resources online to address growing reliability challenges,” said Aubrey Johnson, MISO’s vice president of system planning on Tuesday.
Federal Extension Aligns with PJM’s Fast-Track Efforts to Address Resource Adequacy
Likewise, the agency initially issued its May 30 order to PJM to prevent a potential energy emergency stemming from the planned June 1 retirement of Constellation’s Eddystone Units 3 and 4, two legacy 380-MW oil-fired combustion turbines located at the Eddystone Generating Station in Delaware County, Pennsylvania. As POWER reported, PJM warned that retiring the peaking units, which are used primarily during capacity shortfalls and periods of high demand, could create reliability violations and lead to cascading outages, given shifting regional load and generation dynamics.
In its Aug. 28 extension, the DOE reaffirmed that the underlying emergency “has not abated,” citing “persistent unavailability of transmission projects originally intended to address the reliability concerns” and the “ongoing need for available capacity through the fall and into the winter planning season.” The DOE said that despite efforts to expedite system reinforcements, the absence of these peakers would still pose “an imminent threat of widespread or severe outages” in southeastern Pennsylvania and neighboring load pockets. The agency authorized continued operation through Nov. 26 under tight environmental controls and minimum run-hour use, while allowing Constellation to recover costs under FERC jurisdiction.
PJM, for its part, has also launched an aggressive multi-pronged response to the supply-demand imbalances driving federal emergency interventions. On Aug. 12, the PJM Board of Managers invoked the Critical Issue Fast Path (CIFP) process to fast-track solutions for reliably serving data centers and other large loads, recognizing that the resource adequacy issue should be one of PJM’s “highest priorities,” as David Mills, chair of PJM board of managers member, wrote. The expedited stakeholder process aims to develop “reliability-focused solutions to ensure large loads can continue to be integrated rapidly and reliably, without causing resource inadequacy” in time for the 2028/2029 capacity auction scheduled for June 2026.
PJM has repeatedly noted that its 2025 Long-Term Load Forecast projects peak load growth of 32 GW from 2024 to 2030, stressing about 30 GW coming from data centers alone. “The onrush of demand has created significant upward pricing pressure and has raised future resource adequacy concerns,” the Board’s letter reads.
PJM President and CEO Manu Asthana, too, has underscored the urgency of addressing resource adequacy. “The economic growth that we are seeing in our footprint is exciting, and at the same time we need to make sure that we can preserve system reliability for the average consumer as this demand is added to the system,” he said in a statement earlier this month.
Meanwhile, PJM announced Friday that the application deadline for its reformed interconnection process will be April 27, 2026, as the grid operator works to clear its remaining 63 GW transition queue by 2026 while processing 46 GW of projects that have signed interconnection agreements but face permitting and supply chain delays. The grid operator also launched a Sub-Annual Capacity Market Senior Task Force on Aug. 25 to explore seasonal capacity procurement. In a statement, PJM Executive Vice President Stu Bresler noted that “risks to grid reliability in winter are different than summer, and it makes sense to explore how to procure needed capacity in ways that better reflect these realities.”
Puerto Rico’s Grid Crisis Deepens Amid Persistent Emergency and Underfunding
Earlier this month, on Aug. 14, the DOE extended two May 16 emergency orders that had allowed PREPA to dispatch over 50 aging thermal generating units and to conduct urgent vegetation clearing along critical transmission corridors. As in its other orders, the agency said the underlying threats to reliability “have not been resolved,” citing ongoing risks from forced outages, persistent drought-related fuel limitations, and unmet timelines for 800 MW of temporary generation. It also referenced a July 9 blackout that left 120,000 customers without power. While it noted that “critical repairs, infrastructure improvements, and additional generation procurement remain underway,” a failure to extend the orders could expose Puerto Rico to further loss-of-load events, it said.
For its part, Puerto Rico has launched an unprecedented $21 billion grid modernization initiative while simultaneously addressing immediate reliability vulnerabilities that triggered federal emergency intervention. LUMA Energy, the island’s transmission and distribution operator, says it has committed over $620 million to modernizing more than 23 substations across the island, replacing transformers some up to 80 years old and installing advanced digital relays capable of isolating faults in hundredths of a second. Governor Jenniffer González-Colón issued an executive order in April significantly expanding the island’s energy emergency declaration, waiving local permitting requirements for generation projects while announcing a $767 million Tesla contract for 430 MW of battery storage systems. Earlier this year, meanwhile, the Puerto Rico Energy Bureau has authorized dual generation procurement processes, approving emergency acquisition of 700-850 MW of temporary capacity while initiating competitive procurement for 2,500-3,000 MW of new baseload generation.
Still, experts note factors that led to the island’s grid inadequacy remain—mainly that the system remains fragile and underfunded. LUMA on Aug. 20 acknowledged it lacks sufficient funds to manage increased demand during hurricane season as Puerto Rico enters what forecasters predict will be an active storm period. The island endured its first test last week as Hurricane Erin’s outerbands prompted widespread service interruptions.
“LUMA stresses with utmost urgency that Puerto Rico’s emergency response accounts are severely underfunded,” the company stressed. “Today, this account is underfunded by more than $220 million. As established under LUMA’s Operation and Maintenance Agreement, this account should always maintain a minimum of $30 million to ensure a rapid emergency response. Furthermore, any use of these funds must be replenished within 10 days. Neither of these requirements is currently being met. This critical underfunding is a direct and ongoing risk to Puerto Rico’s ability to prepare for, respond to, and recover from major weather events that impact the electric grid. Without proper funding, response and restoration efforts will face delays and Puerto Rico’s communities will remain vulnerable when they most need protection,” it said.
—Sonal Patel is a POWER senior editor (@sonalcpatel, @POWERmagazine).
