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The Trump Administration has responded to continued retirements of coal and nuclear units by proposing policies intended to prevent any further retirements of the traditional “baseload” fleet, under the premise that such retirements impair grid reliability, “resilience” and, more recently, national security. The first attempt at imposing a policy designed to deter retirements occurred when the U.S. Department of Energy (DOE) proposed a rule for Federal Energy Regulatory Commission (FERC) consideration in October 2017. That proposal, which would have required cost-of-service based payments to merchant coal and nuclear plants in certain Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs) regions, was unanimously rejected by the FERC in January 2018. The FERC decided instead to examine the premise of grid resilience in greater depth at a regional level.

The second major policy attempt was described in a May 31, 2018 article by Bloomberg Energy, which revealed a draft memorandum (“Draft Memo”) by the DOE that outlined a proposal to prevent retirement of certain generation plants (“Subject Generation Facilities” or SGFs) that might, according to […]

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