Section 202(c) Plant Orders: Dates, Dispatch and Procurement Evidence

Correction, October 18, 2026: this article previously presented old expiration dates as a forward calendar, treated order serial numbers as an issuance count, and inferred automatic renewals and urgent equipment purchases. It also overstated the absence of revenue offsets and the uniformity of order terms. Those conclusions are withdrawn. The dated documents below distinguish an availability obligation from a procurement commitment.

A Section 202(c) plant order can matter to maintenance planning. It identifies a facility and an operating obligation worth investigating. To forecast an equipment purchase, however, a buyer still needs the plant’s actual work scope, authorization and schedule. Neither an order’s expiration date nor a low generation total supplies that evidence.

Replace the old calendar with dated documents

These are the periods stated on the individual DOE pages checked on September 26. They replace the article’s August and early-September dates. They are examples from the DOE index, not an exhaustive legal-status inventory or a prediction of further renewals. Craig’s listed period begins the following day. Campbell also requires the litigation distinction discussed below.

Facility	DOE document	Stated operating period
J.H. Campbell	202-26-39	August 17–November 14, 2026
Eddystone Units 3–4	202-26-40	August 23–November 20, 2026
Stanton Unit 1	202-26-42	September 2–November 30, 2026
Centralia Unit 2	202-26-44	September 13–December 11, 2026
R.M. Schahfer Units 17–18	202-26-46	September 20–December 18, 2026
F.B. Culley Unit 2	202-26-47	September 20–December 18, 2026
Craig Unit 1	202-26-49	September 27–December 25, 2026

An expiration date is a point to check for a new instrument, an amendment or a court development. It is not a purchase deadline. The index includes amendments and orders retaining earlier-year identifiers, including PREPA entries. A suffix such as 38 or 49 therefore does not establish the total number of orders issued in 2026.

Read the dispatch and reporting clauses

Campbell Order 202-26-39 illustrates why the operative text matters. Paragraph A directs MISO and Consumers Energy to keep the plant available and directs MISO to use economic dispatch to minimize ratepayer costs. Paragraph B limits operation to MISO’s specified times and parameters and requires daily reporting. The order concerns availability and dispatch; the old claim that it is purely an availability purchase was too strong. (Order, page 11)

Paragraph D required MISO to report by August 31 on measures taken and planned for operational availability. That is a reporting obligation addressed to MISO. It does not identify a new breaker, relay or transformer purchase, prove that the owner’s capital budget had been zeroed, or set a universal two-week procurement deadline for every plant order.

Paragraphs E and G address a recovery route through FERC and exclude capacity-resource status under this order. They do not say there are no revenues of any kind, establish the amount ultimately recoverable, or prove a particular maintenance package has approval. Applicable environmental obligations also remain under paragraph C. (Order, paragraphs C–G)

Separate compliance costs, revenues and supplier awards

Consumers’ Q2 filing provides a concrete counterexample to the former no-offset claim. Through June 30, 2026, it reported a $259 million net financial impact from complying with the emergency orders after applying $239 million in MISO revenues. The filing described recovery proceedings as pending and the ultimate financial impact as subject to their outcome. Those are dated issuer disclosures, not a current recovery determination. (CMS Energy / Consumers Energy Form 10-Q, pages 35–36)

That net figure is not an equipment order book. A useful supplier forecast would separate operating, staffing, maintenance and capital costs, then identify the purchasable scope. Likewise, lower generation alone does not prove that every dollar of a plant’s cost is availability spending or that a specific spares purchase will follow.

Read the Campbell court decision at its actual scope

In its September 11 opinion, the D.C. Circuit vacated the original Campbell order, 202-25-3, after concluding DOE exceeded its statutory authority. The opinion says it was reviewing the initial order; petitions involving four extensions had been held in abeyance. Its remedy discussion notes that the order under review had already expired. (Opinion, page 25; pages 39–40)

That opinion does not by itself establish that all later Campbell orders or orders for other plants ended. DOE’s separately numbered August order states an August 17–November 14 period. A purchase decision needs the relevant order and subsequent case status checked together. The old assumption of an uninterrupted, guaranteed renewal cycle is not a sound basis for a commitment, and neither is an assumption that this one opinion closed every affected plant.

Evidence that makes a plant order actionable for buyers

Use a named order as the start of a project review:

• Confirm the applicable instrument, operating period and subsequent legal or regulatory changes.
• Obtain the plant’s approved maintenance or modification scope, including which equipment needs work and why.
• Identify the purchasing entity, budget authorization, outage window and any recovery dependencies.
• Seek dated solicitations, quotations or awards before assigning supplier demand or a purchasing deadline.

These are procurement checks, not additional DOE requirements. A later order is evidence of another dated obligation. Evidence of an equipment opportunity comes from the work and purchasing documents that follow.

For related context, see the grid modernization procurement guide and the dated May PJM backup-generation order analysis.

For a weekly review of utility procurement developments, read The Feeder.