No legal duty to conduct a further environmental review of the federal government's coal regulation scheme, as the adoption of the plan in 1985 was the major federal action that triggered the obligation of environmental review.
https://www.cadc.uscourts.gov/internet/opinions.nsf/FCE27F0BA64C40A1852582B100518555/$file/15-5294-1736645.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.