Coal Plant Emergency Orders: How the Trump Administration Is Rewriting Energy Policy [2025]

Something weird is happening in America's power grid. And I don't mean the occasional blackout during a heat wave.

The Trump Administration just ordered a Colorado coal plant to stay open even though it was scheduled to close. Nothing unusual about that on the surface, right? Power plants open and close all the time. Except this isn't the first time. Or the second. Or the tenth.

In the past year alone, the federal government has declared 16 energy emergencies to keep coal plants running. That's more declarations in 12 months than were issued during the entire 16-year span from 2008 to 2024. We're talking about a fundamental shift in how emergency powers are being wielded, and it's raising serious questions about legality, environmental policy, and the future of American energy infrastructure.

Here's what's really going on.

TL; DR

• Emergency declarations exploding: The Trump Administration issued 16 emergency orders in one year, compared to the entire 2008-2024 total of 15 declarations. According to Ars Technica, this unprecedented use of emergency powers has raised significant legal and environmental concerns.
• Craig Station case: A Colorado coal unit scheduled to close was ordered to stay on standby despite state analysis showing it wasn't needed for grid reliability. The Sierra Club highlights how such decisions impose unnecessary costs on ratepayers.
• Legal authority questioned: Emergency powers are meant for temporary crises, but the Administration is renewing orders indefinitely, potentially violating Federal Power Act requirements. Utility Dive discusses the legal challenges surrounding these orders.
• Cost and environmental conflict: Keeping coal online is more expensive than renewables and violates Colorado environmental laws, shifting costs to ratepayers. A study found that coal is more costly than solar in many regions.
• Litigation underway: Multiple states and environmental organizations are challenging these orders in federal court. The American Federation of Government Employees outlines ongoing litigation efforts against these policies.

The renewable energy share in U.S. electricity is projected to grow from 12% in 2020 to 50% by 2035, assuming increased investment and installation rates. Estimated data.

Understanding Emergency Powers Under the Federal Power Act

Let's start with the legal foundation here, because this matters more than you might think.

The Federal Power Act, originally passed in 1935 and updated over the decades, gives the Department of Energy some serious muscle during times of crisis. Specifically, Section 202(c) allows the Secretary of Energy to order temporary connection, generation, or transmission of electric energy when the country faces certain conditions.

But here's the critical part: those conditions have a very specific definition. The statute says the Secretary can act when the United States is at war or when "an emergency exists by reason of a sudden increase in the demand for electric energy, or a shortage of electric energy."

Notice the language? It's narrow. "Sudden increase." "Shortage." These are acute, time-limited crises. A power plant going offline in 2024 when you issued the order in 2025 doesn't really fit that definition. A summer heat wave causing unexpected demand spike? That fits. Having to plan ahead for potential future demand? That gets murkier.

The statute also includes built-in constraints that are often overlooked. The order "shall ensure that such order requires generation, delivery, interchange, or transmission of electric energy only during hours necessary to meet the emergency and serve the public interest, and, to the maximum extent practicable, is consistent with any applicable Federal, State, or local environmental law or regulation and minimizes any adverse environmental impacts."

That second part is getting a lot of attention right now. How do you square keeping a coal plant on standby with "minimizing adverse environmental impacts"? Coal burning produces particulate matter, nitrogen oxides, sulfur dioxide, and mercury. These aren't abstract environmental concerns—they kill people.

Research from Harvard and Johns Hopkins University has quantified this. Coal-fired power generation is responsible for roughly 13,200 premature deaths annually in the United States, according to analyses published over the past decade. These deaths come from respiratory diseases, heart attacks, and cancer caused by air pollution.

Coal is one of the most expensive energy sources when external costs are considered, with a levelized cost range of

The Craig Station Controversy: Colorado's Case Study

Let's talk specifics, because the details here reveal just how disconnected these emergency declarations are from actual grid conditions.

Craig Station, located in northwestern Colorado near the town of Craig, has been operating since the 1980s. The facility has three units. Unit 1 was scheduled to retire at the end of 2024. Units 2 and 3 were planned for shutdown in 2028. This wasn't a surprise—these closures have been on the books for years, giving the grid operator plenty of time to plan.

In December 2024, Secretary of Energy Chris Wright issued an order keeping Craig Unit 1 on standby. The stated reason? "The reliable supply of power from the coal plant is essential for keeping the region's electric grid stable."

Here's where it gets interesting. Colorado's Public Utilities Commission, which regulates utilities in the state, had already conducted a reliability analysis. Their conclusion was direct: "Craig Unit 1 is not required for reliability or resource adequacy purposes."

You read that right. The state's own regulatory body that's responsible for grid reliability said the plant wasn't necessary. Yet the federal government issued an emergency order anyway.

The order itself doesn't mandate that the plant actually generate electricity. Instead, it requires the plant to remain operational and available. It's a standby designation. But here's the problem: Colorado's environmental regulations would likely prohibit actual operation of the plant. Colorado has strict limits on airborne pollution and sets specific greenhouse gas emission caps. Operating Craig Unit 1 would almost certainly violate those regulations.

So what happens when you're ordered by the federal government to keep a plant available, but your state forbids you from operating it? You maintain it anyway. And who pays for that maintenance? The ratepayers, of course. People who already planned on a slightly cheaper electricity rate after the plant was supposed to shut down.

The Explosion of Emergency Declarations: A Historical Anomaly

Now let's zoom out and look at the bigger picture, because the Craig Station order isn't an isolated incident.

Between 2008 and 2024, the Department of Energy issued exactly 15 Section 202(c) emergency orders. That's across two administrations, multiple economic cycles, a financial crisis, a pandemic, and various grid challenges. Fifteen orders in sixteen years.

In 2024 alone, the Trump Administration issued 16 emergency orders.

Let that sink in. More than double the historical rate. In a single year.

What changed? The frequency of actual grid emergencies? No. Grid reliability has generally improved over the past decade, despite the increasing prevalence of variable renewable energy. Extreme weather events? Yes, those have increased, but they're not new. The Administration itself issued emergency orders for the same reasons previous administrations did—maintaining generation capacity during periods of peak demand.

But there's a qualitative difference in how these are being applied. Previous emergency orders were typically temporary—lasting a few months through a demand peak, then expiring. The Trump Administration's orders show a different pattern: they're being renewed indefinitely.

Take the Michigan coal plant case. A facility ordered to stay open for what was initially framed as a summer demand emergency is still operating. Years later. The original emergency rationale—a surge in air conditioning demand during heat waves—is no longer the justification. It's just staying open because it's staying open.

This pattern raises a fundamental legal question: can you keep renewing emergency orders indefinitely and still call it an emergency? At some point, doesn't it just become regular regulatory policy?

Coal's share of U.S. electricity generation has significantly declined from 45% in 2013 to 18% in 2023, while grid reliability metrics have improved.

Why Coal? The Economics Don't Add Up

Here's one of the most frustrating aspects of this whole situation.

Coal is not cheap. People sometimes imagine coal as this economic powerhouse, the backbone of American energy. But that's not how the math works anymore. The economics of electricity generation have shifted dramatically over the past decade.

According to the U. S. Energy Information Administration, the levelized cost of electricity (LCOE) tells us what it costs to generate a megawatt-hour over a plant's lifetime, including all upfront and operating costs. Here are approximate 2024 figures:

• Wind (onshore):
  $35–$
  45 per MWh
• Solar (utility-scale):
  $30–$
  40 per MWh
• Natural gas (combined cycle):
  $45–$
  60 per MWh
• Coal:
  $60–$
  120 per MWh
• Nuclear:
  $110–$
  140 per MWh (initially)

Coal is only cheaper than nuclear, and only if you ignore the external costs—the health impacts, environmental damage, and climate effects. Once you factor those in, coal becomes one of the most expensive electricity sources on the market.

Yet the Administration keeps issuing orders to keep these plants running. Why? The official rationale is grid reliability and energy security. But if you dig deeper, the pattern suggests something else: political commitment to certain regions and industries.

Coal plants are concentrated in specific geographic areas. Appalachia, parts of the Midwest, the Rocky Mountain region. These are politically significant areas. Coal employment, though relatively small (about 50,000 people work in coal mining in the U. S. today, compared to about 250,000 in solar and 120,000 in wind), carries political weight in certain communities.

But using emergency powers meant to address acute crises as a tool for industrial policy is problematic. It stretches the legal authority beyond its intended purpose. And it creates distortions in the electricity market.

The Grid Reliability Argument: Is It Valid?

One of the most common defenses of these emergency orders is that they're necessary for grid stability. Coal plants provide "baseload power"—constant, reliable generation that doesn't depend on weather or time of day.

This argument has some merit, but it's increasingly outdated.

First, the grid isn't as dependent on baseload power as it used to be. Battery storage technology has improved dramatically. Companies like Tesla, LG, and Catl are producing batteries at scale that can store electricity and discharge it when needed. A 4-hour battery storage system costs about

Second, grid operators have sophisticated tools to manage variable renewable energy. Demand response programs can shift electricity use to times when renewable generation is abundant. Smart inverters can help stabilize voltage. Real-time market systems can coordinate generation and demand across wide geographic areas.

Third, the specific plants being kept open via emergency orders aren't always the most critical for reliability. Craig Station, as noted, was explicitly deemed unnecessary by Colorado's own reliability analysis.

What's actually happening is a mismatch between the narrative ("we need this for grid reliability") and the reality ("we want to preserve this generation source for political and economic reasons").

The grid is getting more reliable, not less, even as coal generation declines. Over the past decade, coal's share of U. S. electricity generation has dropped from about 45% to about 18%. Meanwhile, the grid hasn't become less stable. If anything, metrics like grid frequency stability have improved.

None of this means the grid is perfect. Extreme weather events pose genuine challenges. Distribution infrastructure in some regions needs upgrades. The transition away from coal does require careful planning.

But those are reasons for policy planning and investment, not reasons to invoke emergency powers to keep aging coal plants on standby.

Estimated data shows that particulate matter, ozone formation, and acid rain contribute to approximately 13,000 premature deaths annually due to coal pollution.

Legal Challenges: How Courts Are Responding

The Administration's reliance on emergency declarations hasn't gone unchallenged.

In late 2024, a coalition of states and environmental organizations filed federal court challenges to these orders. The lawsuit names the Department of Energy and argues that the Administration is misusing emergency authority by:

1. Declaring emergencies that don't meet statutory criteria: The Federal Power Act requires an acute shortage or sudden demand increase. Foreseeable retirements scheduled years in advance don't fit this definition.

2. Using emergency powers for indefinite periods: The Michigan coal plant case shows orders being renewed repeatedly without the underlying emergency conditions changing. At some point, this becomes permanent policy rather than emergency response.

3. Violating environmental compliance requirements: The statute requires orders to be "consistent with any applicable Federal, State, or local environmental law." Keeping coal plants on standby (and potentially operating them) violates state environmental laws.

4. Failing the "public interest" test: Even if an emergency existed, the order must serve the public interest. Given coal's health costs and higher electricity prices, this is questionable.

These are serious legal arguments. They're not frivolous. And they're being brought by experienced attorneys and state governments with resources to pursue them.

The Supreme Court, in recent years, has shown skepticism toward executive branch overreach. Cases like West Virginia v. EPA (2022) established that agencies cannot use general statutory authority to make major policy decisions. Invoking emergency powers to fundamentally reshape the electricity generation mix might fit that pattern of impermissible overreach.

That said, courts are typically reluctant to second-guess executive decisions about national security and energy. The outcome is genuinely uncertain.

Environmental Law Conflicts: The State vs. Federal Tension

One of the most interesting aspects of the Craig Station case is the clash between federal emergency orders and state environmental law.

Colorado doesn't want coal plants operating in the state. The state has strict air quality standards, particularly for ozone formation, which is driven by nitrogen oxides and volatile organic compounds emitted by coal combustion. Colorado also has a law requiring utilities to reduce greenhouse gas emissions.

Craig Station, if operated, would violate these state regulations. But the federal emergency order doesn't explicitly prohibit operation—it just requires the plant be maintained and available. This creates a legal gray area.

Can the federal government order a plant be kept available for operation even if actually operating it would violate state law? The statute says orders should "to the maximum extent practicable" be consistent with state law. But what if operation and state law are fundamentally incompatible?

Historically, federal energy infrastructure has been able to override state environmental requirements in some contexts. The Natural Gas Act, for example, gives the Federal Energy Regulatory Commission authority to approve pipelines even when states object. But Section 202(c) explicitly carves out a requirement for environmental consistency. That's different.

Colorado has the authority to challenge any actual operation of Craig Unit 1, and likely would. But the standby requirement still imposes costs. The plant must be maintained in operating condition. Equipment must be kept ready. Insurance and security costs accrue. These get passed to ratepayers.

It's worth noting that Colorado isn't anti-coal because it's ideologically opposed to coal. The state's concern is practical: coal plants emit pollution that harms public health and violates air quality laws. That's a legitimate regulatory interest.

Estimated data shows that solar energy costs significantly less per megawatt-hour than coal, highlighting the economic advantage of renewable energy investments.

The Renewable Energy Transition: What the Timeline Actually Looks Like

One argument sometimes made in favor of keeping coal plants running is that the renewable energy transition is too fast, and we need more time.

Let's look at the actual timeline.

In 2020, renewables (wind and solar) provided about 12% of U. S. electricity. In 2024, that number was around 22%. Impressive growth, but still less than a quarter of total generation.

For that growth to continue—let's say reaching 50% by 2035—we'd need sustained investment and installation. That's about 40 gigawatts of new wind and solar capacity per year. We're currently installing about 30-35 gigawatts per year.

Increasing that would require:

• More manufacturing capacity (solar panel factories, wind turbine production)
• Grid infrastructure upgrades (transmission lines, distribution equipment)
• Battery storage deployment (for grid stability)
• Workforce training and hiring

These are sizable challenges, but they're not impossible. And they take years to implement. Ordering coal plants to stay open indefinitely doesn't actually speed up any of these transition steps. It just delays inevitable retirements.

Meanwhile, the coal plants themselves are aging. Craig Station's units have been operating for 35+ years. Equipment degradation increases maintenance costs and reduces reliability. You're paying more to keep increasingly unreliable equipment running.

A better approach would be to accelerate the renewable transition directly: mandate faster buildout of wind and solar, invest in battery storage, upgrade the grid. These address the actual constraints, not the symptoms.

Instead, the Administration is trying to solve a transition problem using emergency powers meant for acute crises.

Health Costs and Externalities: The True Price of Coal

Here's something that rarely gets discussed in policy debates: coal's health costs.

When a coal plant burns fuel, it emits particulate matter (tiny particles that lodge in lungs), nitrogen oxides (which form ground-level ozone), sulfur dioxide (which becomes acid rain), and mercury (a neurotoxin). These are documented, measurable harms.

The American Lung Association and various academic institutions have quantified these costs. A 2019 study in Environmental Research Letters found that coal-fired power generation causes approximately 2,000 premature deaths annually through particulate matter pollution alone. When you add ozone formation, acid rain, and other pathways, the total rises to roughly 13,000 premature deaths per year.

What's the economic value of a human life? Regulatory agencies use different numbers depending on context, but a commonly cited figure is

These costs aren't borne by coal companies. They're borne by society. Hospitals treat respiratory disease caused by coal pollution. Families lose breadwinners to heart attacks linked to air pollution exposure. Children develop asthma.

When you're comparing the cost of coal electricity to renewable electricity, the honest comparison includes these health externalities. Once you do that, coal is far more expensive.

Yet these costs never appear in the emergency orders issued by the Department of Energy. The analysis is purely engineering and market-focused, not holistic.

The Political Geography of Coal

Why coal, specifically? Why are emergency orders being issued to keep coal plants running instead of, say, ordering solar farms to be built or nuclear plants to stay online?

The answer is political geography.

Coal production and coal power plants are concentrated in specific regions: Appalachia, parts of the Midwest, Wyoming, Montana, Colorado. These regions have political significance. Coal communities have cultural attachment to the industry. And coal regions are represented by elected officials with sufficient political power to advocate for coal policy.

Wind energy, by contrast, is spread across the Great Plains, Texas, and various other regions. Solar is increasingly distributed. Neither has the concentrated political power of coal.

This isn't unique to the Trump Administration. During the Obama Administration, there were attempts to support coal communities (even while overall policy was moving away from coal). During the Biden Administration, the Inflation Reduction Act included provisions for coal communities and coal workers in transition.

But there's a difference between transition support and emergency orders. Transition support acknowledges that coal communities need economic support as they shift to other industries. Emergency orders pretend the coal industry isn't really declining and can be kept alive indefinitely through federal mandate.

One only works. The other is denial.

Comparison: How Other Countries Handle Energy Transitions

It's instructive to look at how other developed nations are managing energy transitions.

Germany is shutting down its last coal plants by 2038. That date was set by law in advance, giving power companies, workers, and communities time to plan. The transition is intentional, not chaotic.

France, which gets about 70% of its electricity from nuclear power, has a clear energy strategy that's integrated across policy domains. It's not perfect, but it's coherent.

Denmark gets nearly 50% of its electricity from wind power. This required massive investment in grid infrastructure and international interconnections. But it happened through deliberate policy, not emergency orders.

The U. S. is a much larger and more diverse country, so direct comparisons are imperfect. But these examples show that managed energy transitions are possible. They require planning, investment, and acceptance that some industries will decline while others grow.

What they don't require is invoking emergency powers to keep aging infrastructure running indefinitely.

The Precedent Problem: Why This Matters Beyond Energy

One reason the legal challenges to these emergency orders matter is precedent.

If the Trump Administration can invoke emergency powers to keep a coal plant on standby, what's to stop a future administration from using the same power to:

• Mandate renewable energy buildout
• Shut down fossil fuel plants
• Requisition private electricity generation for government use
• Impose other requirements on the energy system

Emergency powers are supposed to be reserved for genuine crises. They exist because sometimes you need to act quickly without the normal procedural requirements. But once you start using them for routine policy goals—even policy goals framed as emergency-related—you've broken the concept.

This is a broader governance problem, not unique to energy. When executive emergency powers expand beyond their intended scope, it affects the balance of power between branches of government and between federal authority and state authority.

Courts rightly take this seriously.

What Happens Next: The Path Forward

There are several possible futures here.

Scenario 1: Courts block the orders. The legal challenges succeed, courts rule that the emergency declarations violate the Federal Power Act, and the orders are vacated. Coal plants retire as originally scheduled. This is the "rule of law" outcome.

Scenario 2: Courts uphold the orders. The Administration's legal team makes a convincing argument that emergency powers are appropriately broad, and courts defer to executive judgment. Coal plants stay on standby indefinitely. This sets a precedent for expansive emergency authority.

Scenario 3: Legislative action. Congress amends the Federal Power Act to either expand or restrict emergency powers, clarifying the scope and duration of such orders. This is the "proper procedure" outcome but requires congressional action.

Scenario 4: Negotiated settlement. States and utilities negotiate deals with the Administration where some coal plants retire on modified timelines in exchange for other concessions (like transmission investment or renewable development).

My guess is that some combination of these will play out. Courts will probably give the Administration some latitude but also impose constraints. There may be congressional attention, though not necessarily legislation. And states may negotiate compromises.

But what won't happen is coal becoming economically competitive again. The underlying economics don't change based on emergency orders. Coal generators are old, expensive, and dirty. No executive order changes that fundamental reality.

The Broader Energy Strategy: What's Actually Needed

Beyond the legal and political disputes, there's a real question about what energy strategy the U. S. should have.

The country needs:

1. Reliable baseload power (whether from coal, nuclear, hydro, or other sources)
2. Affordable electricity (not requiring excessive subsidy)
3. Low environmental impact (meeting air quality and climate goals)
4. Grid stability (preventing blackouts and managing demand fluctuations)
5. Transition support for affected workers and communities

Coal plants address goal #1 pretty well, and historically have been affordable (though no longer). They fail at goals #3 and #5 (no transition support).

Renewables address goals #2, #3, and #4 increasingly well, but require battery storage and grid upgrades to fully address #1.

Nuclear addresses all five goals, but faces upfront cost and regulatory challenges.

A rational strategy would involve:

• Accelerating renewable deployment (particularly in high-capacity regions)
• Investing in battery storage (reducing the need for backup generation)
• Upgrading transmission infrastructure (connecting renewable generation to load centers)
• Supporting nuclear energy (existing plants continue running; new capacity where appropriate)
• Transition programs for coal communities (retraining, economic development)
• Phased coal retirement (on planned timelines with adequate notice)

Emergency orders to keep coal plants running addresses none of these strategic needs. They're a distraction from actual energy policy.

FAQ

What is a Federal Power Act Section 202(c) emergency order?

It's a directive issued by the Secretary of Energy allowing temporary operation or connection of electricity generation facilities during wartime or when an acute shortage of electric energy exists. The statute permits these orders only when there's an immediate crisis requiring urgent action, not for routine policy goals.

Why did the Trump Administration order Craig Station to stay open?

The Department of Energy stated that the plant's power was "essential for keeping the region's electric grid stable." However, Colorado's own Public Utilities Commission concluded that the plant was not required for reliability. The real motivation appears to be political support for coal regions rather than genuine grid need.

Is keeping coal plants on standby actually cheaper than building renewable capacity?

No. Keeping old coal plants on standby costs money in maintenance, insurance, and staffing while generating little revenue. Building new renewable capacity with battery storage costs less per megawatt-hour and decreases over time as technology improves. Coal generation currently costs

How do these emergency orders affect state environmental law?

There's a fundamental tension. Federal emergency orders don't explicitly override state law, but they create an expectation that plants be available for operation. Colorado law prohibits operating coal plants that violate air quality standards. This puts utilities in a legally uncertain position and shifts compliance costs to ratepayers.

What legal challenges are pending against these orders?

Multiple states and environmental organizations have filed federal court challenges arguing that the emergency declarations don't meet statutory criteria (no acute shortage exists), violate environmental law requirements, and represent an improper use of emergency authority for routine policy. Cases are ongoing and outcomes are uncertain.

Could these emergency orders set a precedent for future energy policy?

Yes, and that's a serious concern. If courts allow the executive branch to use emergency powers for non-emergency policy goals, it expands executive authority in ways that affect separation of powers and federalism. A court decision upholding these orders would likely be cited in future cases involving other industries and emergency claims.

How much has coal generation declined as a share of U. S. electricity?

Coal generation has dropped from approximately 45% of U. S. electricity in 2014 to about 18% in 2024. This decline has occurred without grid destabilization or reliability problems. Meanwhile, renewable generation has grown from 12% to 22%, driven by cost improvements and policy support.

What would a better approach to energy transition look like?

Instead of emergency orders to keep coal online, a rational strategy would include accelerating renewable deployment, investing in battery storage and grid infrastructure, supporting nuclear energy where appropriate, and providing genuine transition assistance to coal communities (retraining, economic development, pension support). This addresses actual energy needs while supporting affected workers.

Conclusion: Energy Policy in an Age of Uncertainty

The coal plant emergency orders reflect a government struggling to reconcile several conflicting goals: preserving coal communities, ensuring grid reliability, managing costs, and meeting environmental requirements.

But the method chosen—invoking emergency powers meant for acute crises—is the wrong tool for this job.

Emergency orders are appropriate for genuine emergencies: a sudden power plant failure, a hurricane disrupting generation, a cyber attack threatening the grid. They're not appropriate for managing long-term energy transitions that everyone sees coming.

The facts are these: coal plants are expensive, getting older, and generate pollution. Renewable energy is cheap and getting cheaper. Battery storage is improving. The grid is getting more reliable, not less. These trends aren't surprising—they've been clear for years.

Managing this transition requires planning, investment, policy support, and acknowledgment that some workers and communities will need help adapting. These are serious policy challenges.

But they're not emergencies in the legal sense. And treating them as such undermines emergency authority as a concept.

The courts will ultimately decide whether the Administration's approach is legal. But from a policy perspective, everyone would be better served by honest energy strategy rather than emergency orders disguising routine industrial policy.

The electricity system that powers America needs to evolve. Coal's role in that system is diminishing. That's a fact, not a crisis. And facts are best addressed through policy, not emergency proclamation.

Key Takeaways

• The Trump Administration issued 16 Section 202(c) emergency orders in 2024, exceeding the 2008-2024 total, raising legal concerns about misuse of temporary emergency authority for permanent policy goals
• Craig Station coal plant in Colorado was ordered to stay on standby despite state analysis concluding it wasn't needed for grid reliability, illustrating the disconnect between stated justifications and actual need
• Coal electricity costs
  $60–$
  120 per megawatt-hour compared to
  $30–$
  40 for solar, making emergency orders a costly subsidy for economically uncompetitive generation
• Federal courts are evaluating whether emergency orders violate environmental law requirements and statutory criteria, with outcomes potentially affecting executive authority across multiple domains
• A rational energy strategy would address coal community transitions directly through retraining and economic development rather than artificially keeping coal plants online indefinitely

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