Engineering360: "FERC Rule Change Would Bolster Coal and Nuclear Units"

As I read it, the proposed rule states that the various units must have the 90-day reserve fuel supply on-site, not the looser "be capable of having". There are statements that generating units currently have reserves of up to 120-days of coal on site, but there does not appear to be any statistical data or summary showing the on-site reserve of all the coal-fired plants in the USA along with the power output of the various plants.

Unfortunately, the text of the letter does not clearly demonstrate that the proposed or announced closings of various coal and nuclear generating facilities will affect the reliability. The text cites data showing that coal and nuclear facilities have had very high outputs, and that the announced closings would withdraw a fairly small (below 10%) portion of their contribution to overall system capacity.

Ideally we would see a simple table giving on-site reserves (0-30, 31-60, 61-90, 91-120 & over 120 days) in one column, the total of plant capacities in another column, and then the total capacities of plants with proposed closings in a third column. This sort of data would be very useful in evaluating the urgency of this proposed rule. If needed or appropriate, this data could be broken down into separate tables for the different RTO's involved, to give better evaluation of regional problems such as the one cited for the polar vortex (a simple data point of the capacity that was used would be a very clear comparison point for evaluation of the data in the tables).

Anyone have this data? --JMM