The U.S. District of Columbia Court of Appeals ruled that the Department of Energy has no authority under federal law to use emergency powers to prevent the shutdown of the J.H. Campbell coal-fired power plant in Michigan. The court upheld the claims of Michigan, Minnesota, Illinois, and public interest groups, and found that the Department of Energy misunderstood the meaning of “emergency intervention” in the law. According to the judgment, there is currently no short-term crisis that can take precedence over the state government's power grid management authority, and the “increased risk” of energy supply due to surging demand is not equivalent to a state of emergency.

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