On May 23, 2025, the U.S. Department of Energy (DOE) issued a rare emergency order under Section 202(c) of the Federal Power Act to extend operations of the J.H. Campbell power plant in Michigan through August 21, 2025. The DOE directive required Consumers Energy and MISO to ensure the plant’s availability and to economically dispatch it when doing so would reduce costs to ratepayers.

Since then, much of the public conversation has focused on Consumers Energy’s estimate in its Q2 2025 SEC filing that compliance with the DOE order carried a $29 million financial impact. This figure has been widely interpreted as a burden for Michigan customers.

But our analysis tells a different story.

A Closer Look at Campbell’s Operations

The J.H. Campbell power plant consists of three generating units totaling about 1,400 MW. Historically, Campbell has been one of the most efficient coal plants in the country, operating at an average utilization rate above 60% since 2018, compared to less than 47% for the national coal fleet.

Between May 23 and June 30, 2025, Campbell generated approximately 780,000 MWh of electricity. Hourly market data from MISO shows that power prices at the Campbell hub averaged about $41/MWh over that period, with highs exceeding $300/MWh during peak hours.

Applying these prices to Campbell’s output, we estimate the plant’s generation provided about $31.4 million in value to the grid.

Costs vs. Benefits

Consumers’ reported $29 million cost impact likely reflects operating expenses without accounting for energy revenues that are normally earned in competitive markets. Based on historical data filed with FERC, Campbell’s production costs average around $37/MWh—consistent with our estimate for this period.

When we compare those costs to market revenues, the plant’s operations produced a net benefit of at least $2 million for Michigan and MISO ratepayers during June alone.

Why It Matters

The Campbell case highlights the complex financial mechanics of emergency DOE orders. While headline figures may suggest high costs, the economic reality is more nuanced. In this instance, keeping Campbell online likely saved consumers money during a time of high demand and volatile market prices.

For a detailed breakdown of the data, methodology, and financial estimates behind this conclusion, read our full memo here: Download the full Campbell analysis memo HERE.