Huge solar plant in the works

Indonesia Coal Production Cuts reflect weaker China demand, COVID-19 impacts, falling HBA reference prices, and DMO sales to PLN, pressuring thermal coal output, miner budgets, and investment plans under the 2020 RKAB.

Key Points

Planned 2020 coal output reductions from China demand slump, lower HBA prices, and DMO constraints impacting miners.

✅ China demand drop reduces exports and thermal coal shipments.

✅ HBA reference price decline pressures margins and cash flow.

✅ DMO sales to PLN limit revenue; investment plans may slow.

The Energy and Mineral Resources (ESDM) Ministry is considering lowering the coal production target this year as demand from China has shown a significant decline, with China power demand drops reported, since the start of the outbreak of the novel coronavirus in the country late last year, a senior ministry official has said.

The ministry’s coal and mineral director general Bambang Gatot Ariyono said in Jakarta on March 12 that the decline in the demand had also caused a sharp drop in coal prices on the world market, and China's plan to reduce coal power has further weighed on sentiment, which could cause the country’s miners to reduce their production.

The 2020 minerals and coal mining program and budget (RKAB) has set a current production goal of 550 million tons of coal, a 10 percent increase from last year’s target. As of March 6, 94.7 million tons of coal had been mined in the country in the year.

“With the existing demand, revision to this year’s production is almost certain,” he said, adding that the drop in demand had also caused a decline in coal prices.

Indonesia’s thermal coal reference price (HBA) fell by 26 percent year-on-year to US$67.08 per metric ton in March, according to a Standards & Poor press release on March 5.  At home, the coal price is also unattractive for local producers. Under the domestic market obligation (DMO) policy, miners are required to sell a quarter of their production to state-owned electricity company PLN at a government-set price, even as imported coal volumes rise in some markets. This year’s coal reference price is $70 per metric ton, far below the internal prices before the coronavirus outbreak hit China.

The ministry’s expert staff member Irwandy Arif said China had reduced its coal demand by 200,000 tons so far, as six of its coal-fired power plants had suspended operation due to the significant drop in electricity demand. Many factories in the country were closed as the government tried to halt the spread of the new coronavirus, which caused the decline in energy demand and created electric power woes for international supply chains.

“At present, all mines in Indonesia are still operating normally, while India is rationing coal supplies amid surging electricity demand. But we have to see what will happen in June,” he said.

The ministry predicted that the low demand would also result in a decline in coal mining investment, as clean energy investment has slipped across many developing nations.

The ministry set a $7.6 billion investment target for the mining sector this year, up from $6.17 billion last year, even as Israel reduces coal use in its power sector, which may influence regional demand. The year’s total investment realization was $192 million as of March 6, or around 2.5 percent of the annual target. 

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Hedonistic Sustainability turns Copenhagen's ARC waste-to-energy plant into a public playground, blending ski slope, climbing wall, and trails with carbon-neutral heating, renewables, circular economy design, and green growth for climate action and liveability.

Key Points

A design approach fusing public recreation with clean-energy infrastructure to drive carbon-neutral, livable urban growth.

✅ Waste-to-energy plant doubles as recreation hub

✅ Supports carbon-neutral heating and renewables

✅ Stakeholder-driven, scalable urban climate model

“We call it hedonistic sustainability,” says Jacob Simonsen of the decision to put an artificial ski slope on the roof of the £485m Amager Resource Centre (Arc), Copenhagen’s cutting-edge new waste-to-energy power plant that feeds the city’s district heating network as well. “It’s not just good for the environment, it’s good for life.”

Skiing is just one of the activities that Simonsen, Arc’s chief executive, and Bjarke Ingels, its lead architect, hope will enhance the latest jewel in Copenhagen’s sustainability crown. The incinerator building also incorporates hiking and running trails, a street fitness gym and the world’s highest outdoor climbing wall, an 85-metre “natural mountain” complete with overhangs that rises the full height of the main structure.

In Copenhagen, green transformation goes hand-in-hand with job creation, a growing economy and a better quality of life

Frank Jensen, lord mayor

It’s all part of Copenhagen’s plan to be net carbon-neutral by 2025. Even now, after a summer that saw wildfires ravagethe Arctic Circle and ice sheets in Greenland suffer near-record levels of melt, the goal seems ambitious. In 2009, when the project was formulated, it was positively revolutionary.

“A green, smart, carbon-neutral city,” declared the cover of the climate action plan, aligning with a broader electric planet vision, before detailing the scale of the challenge: 100 new wind turbines; a 20% reduction in both heat and commercial electricity consumption; 75% of all journeys to be by bike, on foot, or by public transport; the biogas-ification of all organic waste; 60,000 sq metres of new solar panels; and 100% of the city’s heating requirements to be met by renewables.

Radical and far-reaching, the scheme dared to rethink the very infrastructure underpinning the city. There’s still not a climate project anywhere else in the world that comes close, even as leaders elsewhere champion a fully renewable grid by 2030.

And, so far, it’s working. CO2 emissions have been reduced by 42% since 2005, and while challenges around mobility and energy consumption remain (new technologies such as better batteries and carbon capture are being implemented, and global calls for clean electricity investment grow), the city says it is on track to achieve its ultimate goal.

More significant still is that Copenhagen has achieved this while continuing to grow in traditional economic terms. Even as some commentators insist that nothing short of a total rethink of free-market economics and corporate structures is required to stave off global catastrophe, the Danish capital’s carbon transformation has happened alongside a 25% growth in its economy over two decades. Copenhagen’s experience will be a model for other world cities as the global energy transition unfolds.

The sentiment that lies behind Arc’s conception as a multi-use public good – “hedonistic sustainability” – is echoed by Bo Asmus Kjeldgaard, former mayor of Copenhagen for the environment and the man originally tasked, back in 2010, with making the plan a reality.

“We combined life quality with sustainability and called it ‘liveability’,” says Kjeldgaard, now CEO of his own climate adaptation company, Greenovation. “We succeeded in building a good narrative around this, one that everybody could believe in.”

The idea was first floated in the late 1990s, when the newly elected Kjeldgaard had a vision of Copenhagen as the environmental capital of Europe. His enthusiasm ran into political intransigence, however, and despite some success, a lack of budget meant most of his work became “just another branding exercise – it was greenwashing”.

We’re such a rich country – change should be easy for us

Claus Nielsen, furniture maker and designer

But after stints as mayor of family and the labour market, and children and young people, he ended up back at environment in 2010 with renewed determination and, crucially, a broader mandate from the city council. “I said: ‘This time, we have to do it right,’” he recalls, “so we made detailed, concrete plans for every area, set the carbon target, and demanded the money and the manpower to make it a reality.”

He brought on board more than 200 stakeholders, from businesses to academia to citizen representatives, and helped them develop 22 specific business plans and 65 separate projects. So far the plan appears on track: there has been a 15% reduction in heat consumption, 66% of all trips in the city are now by bike, on foot or public transport, and 51% of heat and power comes from renewable electricity sources.

The onus placed on ordinary Copenhageners to walk and cycle more, pay higher taxes (especially on cars) and put up with the inconvenience of infrastructure construction has generally been met with understanding and good grace. And while some people remain critical of the fact that Copenhagen airport is not factored into the CO2 calculations – it lies beyond the city’s boundaries – and grumble about precise definitions and formulae, dissent has been rare.

This relative lack of nimbyism and carping about change can, says Frank Jensen, the city’s lord mayor, be traced to longstanding political traditions.

“Caring for the environment and taking responsibility for society in general has been an integral part of the upbringing of many Danes,” he says. “Moreover, there is a general awareness that climate change now calls for immediate, ambitious and collective action.” A 2018 survey by Concito, a thinktank, found that such action was a top priority for voters.

Jensen is keen to stress the cooperative nature of the plan and says “our visions have to be grounded in the everyday lives of people to be politically feasible”. Indeed, involving so many stakeholders, and allowing them to actively help shape both the ends and the means, has been key to the plan’s success so far and the continued goodwill it enjoys. “It’s so important to note that we [the authorities] cannot do this alone,” says Jørgen Abildgaard, Copenhagen’s executive climate programme director.

Many businesses around the world have typically been reluctant to embrace sustainability when a dip in profits or inconvenience might be the result, but not in Copenhagen. Martin Manthorpe, director of strategy, business development and public affairs at NCC, one of Scandinavia’s largest construction and industrial groups, was brought in early on by Abildgaard to represent industry on the municipality’s climate panel, and to facilitate discussions with the wider business community. He thinks there are several reasons why.

“The Danes have a trading mindset, meaning ‘What will I have to sell tomorrow?’ is just as important as ‘What am I producing today?’” he says. “Also, many big Danish companies are still ultimately family-owned, so the culture leans more towards long-term thinking.”

It is, he says, natural for business to be concerned with issues around sustainability and be willing to endure short-term pain: “To do responsible, long-term business, you need to see yourself as part of the larger puzzle that is called ‘society’.”

Furthermore, in Denmark climate change denial is given extremely short shrift. “We believe in the science,” says Anders Haugaard, a local entrepreneur. “Why wouldn’t you? We’re told sustainability brings only benefits and we’ve got no reason to be suspicious.”

“No one would dare argue against the environment,” says his friend Claus Nielsen, a furniture maker and designer. “We’re such a rich country – change should be easy for us.” Nielsen talks about how enlightened his kids are – “my 11-year-old daughter is now a flexitarian ” – and says that nowadays he mainly buys organic; Haugaard doesn’t see a problem with getting rid of petrol cars (the whole country is aiming to be fossil fuel-free by 2050 as the EU electricity use by 2050 is expected to double).

Above all, there’s a belief that sustainability need not make the city poorer: that innovation and “green growth” can be lucrative in and of themselves. “In Copenhagen, green transformation goes hand-in-hand with job creation, a growing economy and a better quality of life,” says Jensen. “We have also shown that it’s possible to combine this transition with economic growth and market opportunities for businesses, and I think that other countries can learn from our example.”

Besides, as Jensen notes, there is little alternative, and even less time: “National states have failed to take enough responsibility, but cities have the power and will to create concrete solutions. We need to start accelerating their implementation – we need to act now.”

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Uranium Critical Mineral Reclassification signals a US executive order directing USGS to restore critical status, boosting nuclear energy, domestic uranium mining, streamlined permitting, federal support, and energy security amid import reliance and supply chain risks.

Key Points

A policy relisting uranium as a critical mineral to unlock funding, speed permits, and strengthen U.S. nuclear security.

✅ Directs Interior to have USGS reconsider uranium classification

✅ Speeds permits for domestic uranium mining projects

✅ Targets import dependence and strengthens energy security

In a strategic move to bolster the United States' nuclear energy sector, former President Donald Trump issued an executive order on January 20, 2025, directing the Secretary of the Interior to instruct the U.S. Geological Survey (USGS) to reconsider classifying uranium as a critical mineral. This directive aims to enhance federal support and streamline permitting processes for domestic uranium projects, thereby strengthening U.S. energy security objectives.

Reclassification of Uranium as a Critical Mineral

The USGS had previously removed uranium from its critical minerals list in 2022, categorizing it as a "fuel mineral" that did not qualify for such designation. The recent executive order seeks to reverse this decision, recognizing uranium's strategic importance in the context of the nation's energy infrastructure and geopolitical considerations.

Implications for Domestic Uranium Production

Reclassifying uranium as a critical mineral is expected to unlock federal funding and expedite the permitting process for uranium mining projects within the United States. This initiative is particularly pertinent given the significant decline in domestic uranium production over the past two decades. According to the U.S. Energy Information Administration, domestic production has decreased by 96%, from 4.8 million pounds in 2014 to approximately 121,296 pounds in the third quarter of 2024.

Current Uranium Supply Dynamics

Despite the push for increased domestic production, the U.S. remains heavily reliant on uranium imports. In 2022, 27% of U.S. uranium purchases were sourced from Canada, with an additional 57% imported from countries including Kazakhstan, Uzbekistan, Australia, and Russia; a recent ban on Russian uranium could further disrupt these supply patterns and heighten risks. This reliance on foreign sources has raised concerns about energy security, especially in light of recent geopolitical tensions.

Challenges and Considerations

While the executive order represents a significant step toward revitalizing the U.S. nuclear energy sector, several challenges persist, and energy dominance faces constraints that will shape implementation:

• Regulatory Hurdles: Accelerating the permitting process for uranium mining projects involves navigating complex environmental and regulatory frameworks, though recent permitting reforms for geothermal hint at potential pathways, which can be time-consuming and contentious.

• Market Dynamics: The uranium market is subject to global supply and demand fluctuations, and domestic producers may face competition from established international suppliers.

• Infrastructure Development: Expanding domestic uranium production necessitates substantial investment in mining infrastructure and workforce development, areas that have been underfunded in recent years.

Broader Implications for Nuclear Energy Policy

The executive order aligns with a broader strategy to revitalize the U.S. nuclear energy industry, where ongoing nuclear innovation is critical to delivering stable, low-emission power. The increasing demand for nuclear energy is driven by the global push for zero-emissions energy sources and the need to support power-intensive technologies, such as artificial intelligence servers.

Former President Trump's executive order to reclassify uranium as a critical mineral, aligning with his broader energy agenda and a prior pledge to end the 'war on coal', signifies a pivotal moment for the U.S. nuclear energy sector. By potentially unlocking federal support, including programs advanced by the Nuclear Innovation Act, and streamlining permitting processes, this initiative aims to reduce dependence on foreign uranium sources and enhance national energy security. However, realizing these objectives will require addressing regulatory challenges, market dynamics, and infrastructure needs to ensure the successful revitalization of the domestic uranium industry.

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Franco-German Nuclear Power Divide shapes EU energy policy, electricity market reform, and decarbonization strategies, as Paris backs reactors and state subsidies while Berlin prioritizes renewables, hydrogen, and energy security after Russian gas shocks.

Key Points

A policy rift over nuclear shaping EU market reform, subsidies, and the balance between reactors and renewables.

✅ Nuclear in EU targets vs. renewables-first strategy

✅ Market design disputes over long-term power prices

✅ Energy security after Russian gas; hydrogen definitions

Near the French village of Fessenheim, facing Germany across the Rhine, a nuclear power station stands dormant. The German protesters that once demanded the site’s closure have decamped, in a sign of Europe's nuclear decline, and the last watts were produced three years ago. 

But disagreements over how the plant from 1977 should be repurposed persist, speaking to a much deeper divide over nuclear power, which Eon chief's warning to Germany underscored, between the two countries on either side of the river’s banks.

German officials have disputed a proposal to turn it into a centre to treat metals exposed to low levels of radioactivity, Fessenheim’s mayor Claude Brender says. “They are not on board with anything that might in some way make the nuclear industry more acceptable,” he adds.

France and Germany’s split over nuclear power is a tale of diverging mindsets fashioned over decades, including since the Chernobyl disaster in USSR-era Ukraine. But it has now become a major faultline in a touchy relationship between Europe’s two biggest economies.

Their stand-off over how to treat nuclear in a series of EU reforms has consequences for how Europe plans to advance towards cleaner energy. It will also affect how the bloc secures power supplies as the region weans itself off Russian gas, even though nuclear would do little for the gas issue, and how it provides its industry with affordable energy to compete with the US and China. 

“There can be squabbles between partners. But we’re not in a retirement home today squabbling over trivial matters. Europe is in a serious situation,” says Eric-André Martin, a specialist in Franco-German relations at French think-tank IFRI. 

France, which produces two-thirds of its power from nuclear plants and has plans for more reactors, is fighting for the low-carbon technology to be factored into its targets for reducing emissions and for leeway to use state subsidies to fund the sector.

For Germany, which closed its last nuclear plants this year and, having turned its back on nuclear, has been particularly shaken by its former reliance on Russian gas, there’s concern that a nuclear drive will detract from renewable energy advances.

But there is also an economic subtext in a region still reeling from an energy crisis last year, reviving arguments for a needed nuclear option for climate in Germany, when prices spiked and laid bare how vulnerable households and manufacturers could become.

Berlin is wary that Paris would benefit more than its neighbours if it ends up being able to guarantee low power prices from its large nuclear output as a result of new EU rules on electricity markets, amid talk of a possible U-turn on the phaseout, people close to talks between the two countries say.

Ministers on both sides have acknowledged there is a problem. “The conflict is painful. It’s painful for the two governments as well as for our [EU] partners,” Sven Giegold, state secretary at the German economy and climate action ministry, where debates about whether a nuclear resurgence is possible persist, tells the Financial Times. 

Agnès Pannier-Runacher, France’s energy minister, says she wants to “get out of the realm of the emotional and move past the considerable misunderstandings that have accumulated in this discussion”.

In a joint appearance in Hamburg last week, German chancellor Olaf Scholz and French president Emmanuel Macron made encouraging noises over their ability to break the latest deadlock: a disagreement over the design of the EU’s electricity market. Ministers had been due to agree a plan in June but will now meet on October 17 to discuss the reform, aimed at stabilising long-term prices.

But the French and German impasse on nuclear has already slowed down debates on key EU policies such as rules on renewable energy and how hydrogen should be produced. Smaller member states are becoming impatient. The delay on the market design is “a big Franco-German show of incompetence again”, says an energy ministry official from another EU country who requested anonymity. 

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Power Grid Attacks surge across substations and transmission lines, straining critical infrastructure as DHS and FBI cite vandalism, domestic extremists, and cybersecurity risks impacting resilience, outages, and grid reliability nationwide.

Key Points

Power Grid Attacks are deliberate strikes on substations and lines to disrupt power and weaken grid reliability.

✅ Physical attacks rose across multiple states and utilities.

✅ DHS and FBI warn of threats to critical infrastructure.

✅ Substation security and grid resilience upgrades urged.

Even before Christmas Day attacks on power substations in five states in the Pacific Northwest and Southeast, similar incidents of attacks, vandalism and suspicious activity were on the rise.

Federal energy reports through August – the most recent available – show an increase in physical attacks at electrical facilities across the nation this year, continuing a trend seen since 2017.

At least 108 human-related events were reported during the first eight months of 2022, compared with 99 in all of 2021 and 97 in 2020. More than a dozen cases of vandalism have been reported since September.

The attacks have prompted a flurry of calls to better protect the nation's power grid, with a renewed focus on protecting the U.S. power grid across sectors, but experts have warned for more than three decades that stepped-up protection was needed.

Attacks on power stations on the rise 
Twice this year, the Department of Homeland Security warned "a heightened threat environment" remains for the nation, including its critical infrastructure amid reports of suspected Russian breaches of power plant systems. 

At least 20 actual physical attacks were reported, compared with six in all of 2021. 
Suspicious-activity reports jumped three years ago, nearly doubling in 2020 to 32 events. In the first eight months of this year, 34 suspicious incidents were reported.
Total human-related incidents – including vandalism, suspicious activity and cyber events such as Russian hackers and U.S. utilities in recent years – are on track to be the highest since the reports started showing such activity in 2011.

Attacks reported in at least 5 states
Since September, attacks or potential attacks have been reported on at least 18 additional substations and one power plant in Florida, Oregon, Washington and the Carolinas. Several involved firearms.

• In Florida: Six "intrusion events" occurred at Duke Energy substations in September, resulting in at least one brief power outage, according to the News Nation television network, which cited a report the utility sent to the Energy Department. Duke Energy spokesperson Ana Gibbs confirmed a related arrest, but the company declined to comment further.
• In Oregon and Washington state: Substations were attacked at least six times in November and December, with firearms used in some cases, local news outlets reported. On Christmas Day, four additional substations were vandalized in Washington State, cutting power to more than 14,000 customers.
• In North Carolina: A substation in Maysville was vandalized on Nov. 11. On Dec. 3, shootings that authorities called a "targeted attack" damaged two power substations in Moore County, leaving tens of thousands without power amid freezing temperatures.
• In South Carolina: Days later, gunfire was reported near a hydropower plant, but police said the shooting was a "random act."

It's not yet clear whether any of the attacks were coordinated. After the North Carolina attacks, a coordinating council between the electric power industry and the federal government ordered a security evaluation.

FBI mum on its investigations
The FBI is looking into some of the attacks, including cyber intrusions where hackers accessed control rooms in past cases, but it hasn't said how many it's investigating or where. 

Shelley Lynch, a spokesperson for the FBI's Charlotte field office, confirmed the bureau was investigating the North Carolina attack. The Kershaw County Sheriff's Office reported the FBI was looking into the South Carolina incident.

Utilities in Oregon and Washington told news outlets they were cooperating with the FBI, but spokespeople for the agency's Seattle and Portland field offices said they couldn't confirm or deny an investigation.

Could domestic extremists be involved?
In January, the Department of Homeland Security said domestic extremists had been developing "credible, specific plans" since at least 2020, including a Neo-Nazi plot against power stations detailed in a federal complaint, and would continue to "encourage physical attacks against electrical infrastructure."

In February, three men who ascribed to white supremacy and Neo-Nazism pleaded guilty to federal crimes related to a scheme to attack the grid with rifles.

In a news release, Timothy Langan, assistant director of the FBI’s Counterterrorism Division, said the defendants "wanted to attack regional power substations and expected the damage would lead to economic distress and civil unrest."

Why is the power grid so hard to protect?
Industry experts, federal officials and others have warned in one report after another since at least 1990 that the power grid was at risk, and a recent grid vulnerability report card highlights dangerous weak points, said Granger Morgan, an engineering professor at Carnegie Mellon University who chaired three National Academies of Sciences reports.

The reports urged state and federal agencies to collaborate to make the system more resilient to attacks and natural disasters such as hurricanes and storms. 

"The system is inherently vulnerable, with the U.S. grid experiencing more blackouts than other developed nations in one study. It's spread all across the countryside," which makes the lines and substations easy targets, Morgan said. The grid includes more than 7,300 power plants, 160,000 miles of high-voltage power lines and 55,000 transmission substations.

One challenge is that there's no single entity whose responsibilities span the entire system, Morgan said. And the risks are only increasing as the grid expands to include renewable energy sources such as solar and wind, he said. 

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FERC Grid Resiliency Pricing Opposition underscores industry groups, RTOs, and ISOs rejecting DOE's NOPR, warning against out-of-market subsidies for coal and nuclear, favoring competitive markets, reliability, and true grid resilience.

Key Points

Coalition urging FERC to reject DOE's NOPR subsidies, protecting reliability and competitive power markets.

✅ Industry groups, RTOs, ISOs oppose DOE NOPR

✅ PJM reports sufficient reliability and resilience

✅ Reject out-of-market aid to coal, nuclear

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy's (DOE) proposed rulemaking on grid resiliency pricing and electricity pricing changes within competitive markets, in the next step in this FERC proceeding.

Action by FERC, as lawmakers urge movement on aggregated DERs to modernize markets, is expected by December 11.

In these comments, this broad group of energy industry associations notes that most of the comments submitted initially by an unprecedented volume of filers, including grid operators whose markets would be impacted by the proposed rule, urged FERC not to adopt DOE'sproposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Just a small set of interests - those that would benefit financially from discriminatory pricing that favors coal and nuclear plants - argued in favor of the rule put forward by DOE in its Notice of Proposed Rulemaking, or NOPR, as did coal and business interests in related regulatory debates. But even those interests - termed 'NOPR Beneficiaries' by the energy associations - failed to provide adequate justification for FERC to approve the rule, and their specific alternative proposals for implementing the bailout of these plants were just as flawed as the DOE plan, according to the energy industry associations.

'The joint comments filed today with partners across the energy spectrum reflect the overwhelming majority view that this proposed rulemaking by FERC is unprecedented and unwarranted, said Todd Foley, Senior Vice President, Policy & Government Affairs, American Council on Renewable Energy.

We're hopeful that FERC will rule against an anti-competitive distortion of the electricity marketplace and avoid new unnecessary initiatives that increase power prices for American consumers and businesses.'

In the new reply comments submitted in response to the initial comments filed by hundreds of stakeholders on or before October 23 - the energy industry associations made the following points: Despite hundreds of comments filed, no new information was brought forth to validate the assertion - by DOE or the NOPR Beneficiaries - that an emergency exists that requires accelerated action to prop up certain power plants that are failing in competitive electricity markets: 'The record in this proceeding, including the initial comments, does not support the discriminatory payments proposed' by DOE, state the industry groups.

Nearly all of the initial comments filed in the matter take issue with the DOE NOPR and its claim of imminent threats to the reliability and resilience of the electric power system, despite reports of coal and nuclear disruptions cited by some advocates: 'Of the hundreds of comments filed in response to the DOE NOPR, only a handful purported to provide substantive evidence in support of the proposal. In contrast, an overwhelming majority of initial comments agree that the DOE NOPR fails to substantiate its assertions of an immediate reliability or resiliency need related to the retirement of merchant coal-fired and nuclear generation.'

Grid operators filed comments refuting claims that the potential retirement of coal and nuclear plants which could not compete for economically present immediate or near-term challenges to grid management, even as a coal CEO criticism targeted federal decisions: 'Even the RTOs and ISOs themselves filed comments opposing the DOE NOPR, noting that the proposed cost-of-service payments to preferred generation would disrupt the competitive markets and are neither warranted nor justified.... Most notably, this includes PJM Interconnection, ... the RTO in which most of the units potentially eligible for payments under the DOE NOPR are located. PJM states that its region 'unquestionably is reliable, and its competitive markets have for years secured commitments from capacity resources that well exceed the target reserve margin established to meet [North American Electric Reliability Corp.] requirements.' And PJM analysis has confirmed that the region's generation portfolio is not only reliable, but also resilient.'

The need for NOPR Beneficiaries to offer alternative proposals reflects the weakness of DOE'srule as drafted, but their options for propping up uneconomic power plants are no better, practically or legally: 'Plans put forward by supporters of the power plant bailout 'acknowledge, at least implicitly, that the preferential payment structure proposed in the DOE NOPR is unclear, unworkable, or both. However, the alternatives offered by the NOPR Beneficiaries, are equally flawed both substantively and procedurally, extending well beyond the scope of the DOE NOPR.'

Citing one example, the energy groups note that the detailed plan put forward by utility FirstEnergy Service Co. would provide preferential payments far more costly than those now provided to individual power plants needed for immediate reasons (and given a 'reliability must run' contract, or RMR): 'Compensation provided under [FirstEnergy's proposal] would be significantly expanded beyond RMR precedent, going so far as to include bailing [a qualifying] unit out of debt based on an unsupported assertion that revenues are needed to ensure long-term operation.'

Calling the action FERC would be required to take in adopting the DOE proposal 'unprecedented,' the energy industry associations reiterate their opposition: 'While the undersigned support the goals of a reliable and resilient grid, adoption of ill-considered discriminatory payments contemplated in the DOE NOPR is not supportable - or even appropriate - from a legal or policy perspective.

About ACORE

The American Council on Renewable Energy (ACORE) is a national non-profit organization leading the transition to a renewable energy economy. With hundreds of member companies from across the spectrum of renewable energy technologies, consumers and investors, ACORE is uniquely positioned to promote the policies and financial structures essential to growth in the renewable energy sector. Our annual forums in Washington, D.C., New York and San Franciscoset the industry standard in providing important venues for key leaders to meet, discuss recent developments, and hear the latest from senior government officials and seasoned experts.

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