Last week, the U.S. Secretary of Energy Rick Perry released a notice of proposed rulemaking (NOPR) that directed the Federal Electricity Reliability Council (FERC) to come up with a new way to pay coal and nuclear power plants more than other power generators (renewables and natural gas) for the energy they generate. The additional revenue would be in recognition of the coal and nuclear power plants’ ability to be “resilient” power sources, which the NOPR defines as having a 90-day stockpile of fuel onsite.

Immediately a number of problems were identified with the NOPR. First, the memo requests an accelerated timeline to implement the new rule and a bevy of unlikely energy industry allies (including wind,

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