In September, Energy Secretary Perry asked the Federal Energy Regulatory Commission (FERC) to adopt a new rule that would guarantee plants with 90-day on-site fuel, mostly coal and nuclear plants, full cost recovery. We submitted an initial set of comments to FERC in response to their Notice Inviting Comments, and we have now submitted reply comments.
In these reply comments, we argue that there is no record to support the Proposed Rule, that the studies cited by supporters of the Proposed Rule is methodologically flawed and therefore cannot be used to support the Proposed Rule, and that FERC should reject comments that seek to undercut state environmental policies.