Last week, in West Virginia v. EPA, 597 U.S. ____ (2022), the U.S. Supreme Court held that Section 111(d) of the Clean Air Act did not grant the Environmental Protection Agency (EPA) the ability to devise emissions caps based on the generation shifting approach the EPA took under the Obama administration's Clean Power Plan. The Court's opinion focused on the "major questions doctrine," which under constitutional separation of powers mandates that an administrative agency have a "clear congressional authorization" behind administrative actions and rulemaking. The EPA claimed Section 111(d) of the Clean Air Act gave it the ability to develop the Clean Power Plan to shift the nation's energy consumption from traditional energy sources (such as coal and natural gas) to renewables, with the goal to reduce coal power consumption by 11% by 2030 (from 38% in 2014 to 27%).