The EIA's most recent retirement tracker lists approximately 80 GW of US coal-fired generation with announced retirement dates between 2025 and 2032. An additional 30 to 40 GW sits in the economic-pressure category, plants whose dispatch economics have collapsed against gas and renewables but whose retirement filings have not yet cleared state PUC review. The total addressable retirement pool is therefore 110 to 120 GW, roughly a fifth of the installed US thermal fleet. The Trump administration's January 2025 emergency orders delayed at least 15 named plant retirements, but delay is not reversal. The plants are still leaving.
The number that matters more is not the retiring capacity but what stays behind. Each retired coal plant leaves a fixed asset stack that does not depreciate the way the boiler does. Capacity Interconnection Rights at the existing point of interconnection. Substation infrastructure typically rated 345 kV to 765 kV. Water withdrawal permits often grandfathered at 50 to 500 million gallons per day. Class 1 rail access. Industrial zoning, frequently with Foreign Trade Zone overlay. A unionized workforce shed of electrical, mechanical, and instrumentation trades. These six assets are what AI campus developers are now bidding for. The plant is gone; the plant's rights are the product.
What The Plant Actually Was
A 2,000 MW coal plant occupies between 800 and 2,500 acres depending on era, ash pond geometry, and rail siding configuration. The boiler island and turbine hall account for less than 15 percent of the developed footprint. The remaining 85 percent is what survives.
The Capacity Interconnection Right is the most valuable component. Under FERC Order 2023 and the predecessor Order 845, the CIR is a separately transferable property right attached to the point of interconnection, not to the generating asset. When a coal plant retires, the CIR can be retained by the site owner, transferred to a successor generator on the same parcel, or in some ISO/RTO regimes sold separately from the underlying land. The queue position behind that CIR represents anywhere from four to nine years of avoided interconnection study time. In PJM's current queue, that time-value alone is being priced at $700,000 to $1.2 million per MW in bilateral transactions.
The substation is the second component. A coal plant of 2,000 MW typically interconnects through a 500 kV or 765 kV switchyard with multiple transmission paths radiating outward. Replacing that switchyard on a greenfield site costs $80 to $150 million and requires 36 to 60 months of permitting and construction. The retired plant's switchyard, in most cases, remains energized after the boiler comes down.
Water rights are the third. The Clean Water Act Section 316(b) intake permits issued to mid-century coal plants were sized for once-through cooling at scales that no new industrial facility could permit today. Homer City's withdrawal permit on the Two Lick Creek system, the Sherco withdrawal on the Mississippi, the Bowen withdrawal on the Etowah, the Gibson withdrawal on the Wabash. These are unreplicable. A 1,000 MW AI campus with closed-loop cooling needs roughly 5 to 15 MGD makeup water. A grandfathered 200 MGD permit is a 13 to 40x headroom on a constraint that has become the single largest siting blocker outside power itself.
The fourth is rail. Coal plants of this generation were sited against Class 1 rail because the fuel required it. Norfolk Southern, CSX, BNSF, and Union Pacific sidings remain in place after the coal trains stop. For an AI campus, the rail asset matters for transformer delivery, switchgear, and module logistics during construction; nameplate transformers above 500 MVA cannot move by road.
The fifth is zoning and FTZ status. Coal plant parcels are zoned heavy industrial by-right in every state, and many sit inside designated Foreign Trade Zones with duty-deferral treatment for imported equipment. A greenfield parcel requires rezoning, conditional use permits, and public hearings that consume 18 to 36 months. The brownfield does not.
The sixth is the workforce. A retired 2,000 MW coal plant displaces 250 to 400 direct operations staff and a multiple of that in contractors. The skills inventory is electrical journeymen, mechanical millwrights, instrumentation technicians, water treatment operators, and high-voltage switching qualified workers. These are the same trades an AI campus consumes during construction and operation.
The Retirement Schedule
The EIA Form 860 dataset, cross-referenced against state PUC retirement filings and IRP updates, produces a roster of named plants whose CIR will become available in the 2025 to 2032 window. The list is not speculative.
Homer City in Indiana County, Pennsylvania, retired its 1,884 MW coal capacity in 2023 and is currently being repositioned as a 4,500 MW combined-cycle gas and data campus, retaining its 500 kV PJM interconnection and the Two Lick reservoir water rights. Bruce Mansfield in Beaver County, Pennsylvania, retired 2,490 MW in 2019 and sits on the Ohio River with 765 kV switchyard access. Conesville in Coshocton County, Ohio, retired 2,080 MW in 2020 with AEP transmission inheritance. Cheswick north of Pittsburgh retired 570 MW in 2022. The Shippingport corridor downriver from Pittsburgh contains multiple parcels with overlapping interconnection.
In MISO, Sherco in Sherburne County, Minnesota, is retiring 2,400 MW across three units through 2030, with Xcel Energy publicly soliciting industrial reuse proposals. Coal Creek Station in McLean County, North Dakota, transferred to Rainbow Energy with 1,150 MW of interconnection retained. San Juan Generating Station in New Mexico retired 1,683 MW in 2022. Cumberland in Stewart County, Tennessee, is TVA's 2,470 MW retirement scheduled through 2028.
In the Southeast, Bowen in Bartow County, Georgia, accounts for 3,200 MW with retirement filings indicating 2027 to 2028 closure of remaining units. Gibson in Gibson County, Indiana, is 3,345 MW on the Wabash. Rockport in Spencer County, Indiana, is 2,600 MW with bilateral PPA pressure mounting. Mountaineer in Mason County, West Virginia, is 1,300 MW with AEP transmission.
The regional concentration is unambiguous. PJM territory contains more than 35 GW of the announced retirement pool. MISO contains roughly 22 GW. SERC and TVA combined contain approximately 15 GW. ERCOT contains less in absolute terms but moves faster procedurally. WECC's retirements are dominated by California IOU filings with limited brownfield reuse potential due to land-use constraints.
How A Coal Plant Becomes A Compute Campus
The transaction structures are converging on three patterns.
The first is option-to-purchase from the utility. The utility retains ownership of the parcel post-retirement, signs an exclusive option agreement with a developer for 18 to 36 months, and during the option period the developer funds the interconnection study amendment, environmental remediation scoping, and ratepayer impact analysis. The option strike is typically $40,000 to $120,000 per acre, well below the per-acre value implied by the CIR alone.
The second is a joint venture on the existing site. The utility contributes the land, the CIR, the switchyard, and the water rights. The developer contributes capital, EPC management, and the hyperscaler tenant relationship. Cash flow splits favor the utility on capacity payments and the developer on real estate and tenant lease economics. This structure dominates in regulated states where the utility cannot cleanly divest a rate-base asset.
The third is CIR sale separately from the real estate. Under FERC Order 2023's clarified transferability rules, the interconnection right can be assigned to a third party at the same point of interconnection so long as the modification is deemed non-material. The buyer of the CIR may not buy the land. The buyer of the land may not buy the CIR. The disaggregation is occurring because the two assets have different optimal buyers.
The FERC Order 2023 framework, finalized in 2023 and now in implementation across all ISOs/RTOs, codifies CIR transfer mechanics and the non-material modification standard. Material modifications trigger a restudy and queue re-entry. Non-material modifications preserve queue position. The boundary between the two is where the litigation will sit for the next five years.
The Labor Inheritance
The US coal generation workforce in 2024 was approximately 78,000 direct employees, down from 175,000 in 2010. The retirement schedule above will displace 40,000 to 60,000 additional workers nationally by 2032. The skills overlap with AI campus construction and operations is high.
IBEW Local 459 in Indiana County, IBEW Local 712 in Beaver County, IBEW Local 1393 in southern Indiana, IBEW Local 245 in Toledo, UMWA District 17 in West Virginia. These locals have collective bargaining relationships with utility owners that in several cases include site-reuse preference clauses negotiated during retirement settlements. The clauses commit successor industrial users to first-call hiring from the displaced workforce for trades-overlap roles.
State workforce boards in Pennsylvania, Ohio, Indiana, and West Virginia have begun co-funding electrical and instrumentation retraining programs explicitly aimed at data center operations and construction trades. The retraining cost per worker is approximately $8,000 to $15,000, against a productive deployment value to the receiving employer of $90,000 to $140,000 in annual wages.
Why PJM Is The Deepest Pool
PJM Interconnection covers thirteen states and the District of Columbia, contains the densest mid-Atlantic and Ohio Valley coal fleet, and operates the largest organized capacity market in North America. The convergence of three factors produces the depth.
First, the retirement pool. More than 15 named plants in the 2,000 to 4,500 MW range sit inside PJM territory with announced or expected retirements before 2032.
Second, the queue dynamics. PJM's interconnection queue reform, completed in 2023, created a cluster study process that disadvantages new greenfield entrants while preserving the position of existing interconnections. A retired coal plant's CIR is in many cases the only path to PJM interconnection at scale before 2030.
Third, the load growth. PJM's 2024 load forecast added roughly 40 GW of expected data center demand by 2030, concentrated in northern Virginia, central Pennsylvania, and the Ohio Valley. The geographic overlap with the coal retirement pool is almost exact.
MISO is the secondary pool. The fleet is younger, the retirements are slower, but Sherco, Coal Creek, and the Indiana plants represent 15 to 20 GW of accessible brownfield over the period. MISO's queue is less constrained than PJM's, which paradoxically reduces the relative value of an existing CIR.
SERC and TVA contain meaningful retirement capacity but with fewer competing buyers and less developed brownfield-reuse transaction infrastructure. Pricing per-MW of CIR transfer in SERC currently runs 40 to 60 percent below PJM comparables.
ERCOT operates outside the FERC framework, which means CIR transfer mechanics are governed by ERCOT protocols rather than FERC Order 2023. The Texas coal fleet is smaller, the retirement pace is faster on economic grounds, and the queue-to-interconnection time is shorter. ERCOT brownfield premiums are accordingly smaller in absolute dollar terms.
What Becomes True By 2030
By 2030, more than 60 percent of new US AI campuses above 500 MW will site on or adjacent to retired or retiring coal infrastructure. The CIR transfer market will be the single most contested asset class in US power, with documented per-MW transfer valuations exceeding $1 million in PJM and crossing $500,000 in MISO and SERC.
The Ohio-Pennsylvania-West Virginia corridor will become the highest-density AI training cluster in the United States outside of Texas, driven by Homer City, the Shippingport parcels, Mountaineer, and adjacent transmission inheritance. The corridor will absorb 15 to 25 GW of new compute load against a coal-retirement base that supplied the same transmission lineage for sixty years.
State-level brownfield reuse incentive packages will emerge as competitive economic development instruments. Pennsylvania, Ohio, Indiana, West Virginia, and Minnesota will each pass variants of property tax abatement, CIR transfer fee waivers, and workforce retraining cost-share, structured to attract AI campuses to retired plant sites rather than greenfield parcels. The cost-causation rate riders that funded stranded asset recovery in the 2010s will be rewritten as industrial-reuse capture mechanisms in the late 2020s.
The disaggregation of CIR from real estate will produce a class of CIR-only intermediaries: entities that acquire and hold interconnection rights across multiple retired plants, then resell or lease to compute developers who acquire the land separately. The intermediary's economic function is queue arbitrage; the legal function is preserving non-material modification status across transactions.
The map of American compute is not moving to where the fiber is. It is moving to where the coal was.