The health harms of keeping fossil fuel plants from retiring
Co-authored by EDF analysts Rishab Jagetia and Grace Hauser

The Trump administration has spent over 500 days flouting environmental rules to prop up dying coal plants — and everyday Americans are paying for it with their health
For over a year, the Trump administration has invoked Section 202(c) of the Federal Power Act, typically reserved for emergencies, to force units at six aging coal plants and one natural gas plant across the country to keep running after their long-planned retirement dates.
A federal appellate court’s decision on Friday, September 11, that the initial order requiring a Michigan coal plant was unlawful — and that the Department of Energy’s justifications for these orders do not meet legal requirements — may be the first step in ending these orders and allowing the plants to retire. But these plants have already added hundreds of millions of dollars to families’ electric bills and emitted thousands of tons of harmful air and water pollution, affecting the health of people living nearby and damaging the environment. To understand the full scope of the damage, we compiled data across all the affected plants subject to wrongful 202(c) orders. The picture that emerges is striking.
What is a 202(c) order?
In true instances of reliability crises, such as winter storms or grid-reliability risks, the Department of Energy (DOE) uses 202(c) orders to grant select power plants a few hours or days of extended operation. Section 202(c) is supposed to be a last resort — invoked only to address imminent, unexpected grid shortfalls, and limited to the minimum operation necessary. The Trump administration is illegally abusing this power.
There is no energy emergency
The seven plants that the Trump administration has ordered to continue running have been slated for retirement through years of careful planning by utilities, state regulators, and grid operators. The administration overrode all of it. None of the utilities asked DOE to extend their plants’ lifespans; in fact, a few utilities are actively fighting the orders so that they do not pass costs onto ratepayers.
The data shows the extent of the administration’s fabrication of a reliability crisis: many of these plants ran for only a fraction of the time that they were ordered to remain available (Figure 2). For example, as of the end of June, R. M. Schahfer unit 18 hadn’t even produced power since the Trump administration mandated it to run. A plant that produces no power while operating under an emergency declaration isn’t evidence of a grid crisis. It’s evidence of a manufactured one.

Americans are paying with their health
These plants’ operation during their 202(c) orders has led to the emission of thousands of tons of nitrogen oxides (NOx) and sulfur dioxide (SO2), and hundreds of pounds of fine particulate matter. SO2 and NOx have well-documented effects on respiratory health, such as exacerbated asthma symptoms and increased vulnerability to respiratory infections. Particulate matter is especially harmful to human health as it can penetrate deeper into the lungs and cause heart attacks, strokes, heart issues, lung disease, and cancer.
The J. H. Campbell plant in Michigan has emitted the most NOx, SO2, and particulate matter by far—directly related to its length of operation. By June 30, 2026, J. H. Campbell unit 1 alone generated well over 1,000 US tons of NOx and over 2,000 tons of SO2. During this period, the J. H. Campbell plant as a whole emitted almost 140 tons of particulate matter.
These emissions have dire consequences for local residents. Over 160,000 people live within three miles of these facilities, including more than 8,700 children under the age of five (Figure 3). The most densely populated site is around the Eddystone plant in Pennsylvania where over 94,000 residents live, among them more than 5,000 young children.

Communities near these plants face elevated exposure to toxic pollution from units that their utilities, state regulators, and grid operators had already determined were no longer needed for grid reliability. Compared to if these plants had retired on their original retirement dates, these emissions have caused between 33 to 59 premature deaths, 46 emergency room visits for respiratory distress, 132 new cases of asthma, 7,548 missed school days, and 2,697 missed workdays together totaling between $530 to $901 million in 2023 USD (Figure 4).

This has to stop – and we’re fighting to make it happen
The Trump administration’s Section 202(c) orders aren’t emergency measures. They are a systematic effort to prop up an uneconomical industry at the public’s expense; in dollars, in health, and in lives. Every day these orders remain in effect, communities near these plants breathe dirtier air and families pay higher electricity bills.
EDF and our partners are challenging these orders in court. The legal case is strong: plants that sit idle for hundreds of days under “emergency” mandates, while the Trump administration rolls back emission limits for power plants and grants them passes to pollute, expose the hollow justification behind these orders. Courts have tools to stop this — and we are using them.
You can read our full report here, look into the dataset yourself here, and read our methodology here.


