In this episode, I'm joined by Frank Rambo of the Horizon Climate Initiative to discuss "uneconomic dispatch" — the costly and polluting practice of running coal plants even when cheaper, cleaner options are available. We dig into why utilities get away with this, how the Trump administration is now trying to force them to continue via bogus "reliability" claims, and why fighting this practice at the state level is a huge, bipartisan win for both the climate and consumer pocketbooks.
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Text transcript:
David Roberts
Greetings, everyone. This is Volts for August 13, 2025, "Trump’s latest attempt to save coal." I’m your host, David Roberts. In the power sector, all the talk these days is about renewables, batteries, and natural gas, so it’s easy to forget that the US is still saddled with almost 200 filthy coal-fired power plants.
The amount of coal on the US grid has declined precipitously since the late 1990s, when it represented 50% of total generation; it’s down to 15% today and is steadily falling. However, it is not declining as fast as it would if it were competing in a pure market. What frequently happens is that utilities run coal plants even when they are not the cheapest option in order to justify keeping them alive. This "uneconomic dispatch" of coal plants costs ratepayers billions of dollars a year and boxes out renewables that might otherwise get built.
And that was all before Trump’s latest moves. His Department of Energy has released a new reliability report that uses a variety of absurd assumptions to argue that continuing to retire coal plants at the current rate will cast the entire US grid into chaos and blackouts. Citing emergency powers, Trump has issued several executive orders effectively requiring utilities to keep coal plants online, despite utilities, PUCs, and ratepayers saying they don’t want them.
It looks like "uneconomic dispatch" is about to get a lot more common. To dig in, I am talking today with Frank Rambo, who spent 15 years working on clean energy as a senior attorney at the Southern Environmental Law Center before launching his own Horizon Climate Initiative, where he is actively seeking partners and funding to expand the push against uneconomic dispatch. We are going to talk all about why it happens, how Trump is boosting it, and how it can be fought at the state level.
With no further ado, Frank Rambo. Welcome to Volts. Thank you so much for coming.
Frank Rambo
Yeah, I’m really happy to be here.
David Roberts
You know, coal is not my favorite thing, not my favorite thing to talk about, but I feel like a lot of people in Volts-world, a lot of people listening to this podcast, a lot of people following clean energy, have sort of like checked coal off their mental list as though it’s kind of already over in America, as though, you know, sort of like, "Oh, it’s expensive now, it’s a dinosaur, it’s dying, et cetera, et cetera." They sort of have that in their mind. But there are still lots of coal plants in the US, and they’re still being run, and they’re still creating greenhouse gas emissions, and they are not going gently into that good night, let’s just say. There are people fighting to keep them open longer, including Donald Trump.
So I want to start with what is the state of coal in the US. How many of these things are still out there running, and sort of like in the electricity sector, what percentage of our greenhouse gases are still coal?
Frank Rambo
My take on coal, like I have run into that and want to feel like the conversation has moved on from coal — I think that’s a mistake. We obviously, there’s a lot to talk about and that needs to be hashed out, especially the way things are so rapidly evolving. But you’re right, coal is still very much around and my take is that it’s a 20th-century energy resource struggling in a rapidly evolving 21st-century grid and it is circling the drain and it has been really for at least 15 years probably. But how quickly it goes down and I feel like, and I’ll argue how it goes down and the narrative that gets attached to its demise is really important both for, and this is probably the most important thing, for what it’s doing right now today.
Those questions will have a lot of impact on both the medium- and long-term climate fight. And these are the repercussions of those questions. That demise and how it happens and how quickly it happens. I mean, just on the greenhouse gas front, 20% of the nation’s CO2 emissions are still coming from coal.
David Roberts
Total CO2 emissions?
Frank Rambo
Yeah.
David Roberts
And I think it’s 20% of the nation’s CO2 emissions, but it’s not even close to that much of the nation’s electricity.
Frank Rambo
Right. It is about 15%, something like that, of the nation’s electricity. So yeah, it is the most intense. And the other thing I want to say at the outset, and a big reason why I work on this particular issue — that we’ll get into — about how coal is operated uneconomically, very unnecessarily, is immediacy. And part of that immediacy comes from, and I’m certainly not alone in this, a move towards really thinking about the short term. We have a lot of big long-term issues to hash out. Sometimes I think that can take attention away. And again, definitely this dovetails with your observation about coal and how some people just have wanted to move on or feel like we can move on.
It’s the short term, it’s what’s happening right now, and what can we do right now?
David Roberts
Well, there are so many big, difficult problems and like incremental small units of emissions saving that we’re scrabbling, fighting for. But like here are big, these are big units of greenhouse gases here. And they’re just low-hanging fruit and they’re right in front of us.
Frank Rambo
They are absolutely the low-hanging fruit. And I just want to say one thing, just on that short term, one way that gets debated as well, "What’s your time frame?" I mean, in heating, you know, the actual heating of the atmosphere is really, it’s really kind of the point. It’s not just what’s coming out the smokestack or tailpipe or what have you.
David Roberts
But we should say, let me just interject that coal is also the largest source in the electricity sector of air pollutants as well. So you can also get giant reductions in particulate pollution and nitrous oxide, et cetera, with coal plants. Like again, low-hanging fruit.
Frank Rambo
Amen to that. I was specifically going to shout out, I feel like it needs to be mentioned because I don’t think it gets the attention it deserves, is black carbon. Which has a multiple pathway of how it impacts the heating that we’re experiencing right now. I mean, it’s this black, sooty — it’s in the particulate matter created by incomplete combustion. And of all the energy sources on the power grid, coal is the biggest black carbon emitter. So you’re talking in terms of mass, in terms of tons, that number is very small. And some of the numbers vary on the global warming potential over that 20-year, I think increasingly key to policy consideration of that 20-year time period.
There are definitely numbers out there, legitimate numbers of 3,200 times the CO2 global warming potential over that 20-year timeframe.
David Roberts
So just to sum up, if you want to go after air pollution, you want to go after particulate pollution, you want to go after short-term greenhouse gases, you want to go after long-term greenhouse gases—anything, you want to go after, coal is the worst of that thing.
Frank Rambo
Coal is where you want to be.
David Roberts
I mean, we’re somewhat preaching to the choir here, to this audience. I think we are. We all know coal is bad, but it just cannot be reinforced enough that it is like, it is like public enemy number one on virtually any metric you want to pick. But so then let’s talk about the next thing, which is the happy development of the last 20 years: coal’s competitors have become much cheaper to run than coal. So if we lived in a world of pure market forces, coal would probably be much deader than it is already. So what’s happening is, let me — one step back.
So when you run a grid — this is crucial background for what coal’s doing — now, when you run a grid, say if you’re an ISO or an RTO, you’re running a big competitive energy market. What you are supposed to do is if there’s another unit of demand, you are supposed to turn on the next increment of supply that is cheapest, right? You start with the cheapest power and work up from there. That is what you’re supposed to do when you’re running a market-based energy system. And in that hierarchy of what’s most expensive, coal is almost always going to be the most expensive, i.e., the very, very last thing you turn on, i.e., if you were just doing this procedure, what’s called "merit order," you would hardly ever run coal. But utilities are out there running coal anyway, even though it’s not the next step, even though it’s not the next most expensive. This is called uneconomic dispatch. So why don’t you tell us — I guess there’s two separate things here. One is in restructured markets that have competitive markets that are run by RTOs and ISOs, why are they doing it? And then maybe it’s a different question, the vertically integrated utilities, why are they doing it?
But they’re both doing it. So why run coal when it’s not the next most economic thing? Why do they do that?
Frank Rambo
Further complicating the question is that you can have vertically integrated monopoly utilities where the problem of uneconomic dispatch, that is running coal when there are cheaper resources available, operating in those areas with a regional grid operator, we have a regional market. So let me lay out some of the reasons and I’ll let you follow up to see where you want to dig in deeper. The number one reason has to do with incentives. Let me couch this specifically in terms of those vertically integrated monopoly utilities. Now, it could be a little bit different when they are operating in a region of the country with a regional grid operator, and we can maybe get into some of that nuance as well.
But essentially their primary regulator, who they primarily answer to, are state regulators. These are the state commissioners and the PUCs, PSEs. Their operating costs and particularly their fuel cost, in most states, it’s simply a pass-through cost. So by that I mean what happens — I’m going to generalize here — the utility will come into its state commission. State commission oversees all the major business operations of the utility, making sure that they’re not gouging and they’re treating their customers fairly, not overcharging. There will be a docket. It can happen at various frequencies, but it’s a regular docket. In many states it’s once a year, it goes by different names.
Basically, it’s a fuel cost recovery docket. So the utility will come in and say to its commission, make a request, "We burnt $100 million worth of coal last year. It’s a pass-through cost. We want to be able to recover it through the bills that we sent to our captive customers."
David Roberts
Yeah, we should just say pass-through just means ratepayers pay it.
Frank Rambo
Yes, ratepayers. "We’re going to take that $100 million." What the business as usual, what happens now, and this is what my work is seeking to change, is that that will just get rubber-stamped, it won’t get scrutinized, and they’ll get their $100 million.
David Roberts
And here we should just say again, like if you’re in a market-based system, it’s very transparent. You’re supposed to do the next cheapest thing. And it’s very clear to everyone if you’re not. It’s a little less clear from the outside what these vertically integrated utilities are doing. But we should say they do also have some formal, like PUCs, these regulatory bodies are supposed to ensure that the utility rates they’re charging ratepayers are just and reasonable. So when they say, "We burned a bunch of coal and we want to charge ratepayers for it," theoretically, they’re supposed to justify to the PUC that there is a good reason to burn the coal.
Like there’s supposed to be some scrutiny of that, right?
Frank Rambo
There absolutely is. I mean, it’s like there’s a regulatory analog to what the market — and just because I know I’ll say it, like definitely at the state level, the touchstone standard is prudency. You know, has the utility been prudent in how it’s running its business? So, and if it has been prudent, "Okay, we’ll let you recover those costs." So what happens is whether they’re operating in a market or not and they run their coal uneconomically, that is, they run it even though they could have chosen something else. If they’re in that region with an energy market, they could have bought power on the market or there was some other resource that they could have called on themselves that would have been cheaper.
So that price difference, if they had taken that cheaper option, they would have burned less coal.
David Roberts
I mean, if you really strictly do that, you’re hardly ever going to burn coal, really is the current fact of the matter.
Frank Rambo
Yeah, exactly. And that’s part of this work. If we were really following this theory of lining everything up in order, as you said, from lowest cost to highest cost, as much as coal has declined, it would be much, much lower. And part of the value of this work is if we can get closer to that theory, make the practice of how the system operates market-wise, regulatory-wise, it’s really going to expose how little coal has a value to the grid.
David Roberts
And as you emphasize over and over again in your work, it will reduce costs for ratepayers. So here’s my question: when I’m a utility that’s doing this, I’m a vertically integrated utility, I’m burning coal even though it’s not the cheapest. I have to go to my PUC and I have to presumably tell them why. I have to justify myself. So what are they saying to their PUCs about why they allegedly have to do this?
Frank Rambo
Well, I think part of the problem, they don’t have to say much.
David Roberts
The PUCs don’t ask that.
Frank Rambo
Yeah, I mean, that’s it. A lot of times, these dockets are very quick.
David Roberts
Well, presumably someone somewhere has asked them at some point why they have to do it. Presumably, they have some story.
Frank Rambo
Well, they do, but they don’t get called on. I mean, this is why, this is why I work on this issue is because it really doesn’t happen that often. So there are, there are some instances. We can talk about it. There was a good decision out of the Michigan PUC last year. Now they can, to the extent they are entering for it, they’re saying reliability, they’re saying, "Look, these coal plants have operational constraints on them. The coal-fired boiler has certain operational constraints. Once we crank it up, we need to..." I think there’s a lot of debate about how much needs to be done.
David Roberts
Right. "We can’t just ramp them up and down willy-nilly. Once we start it, we need to keep it running." So this gets to the debate then of like how dispatchable are coal plants? How much can you ramp them? Of course, they have every incentive to say to the PUC that the coal plants are very inflexible and thus need to be running continuously if they’re ever started. But so this is, I guess, an open question then, like how flexible they can be?
Frank Rambo
It is one of those things that can be debated. It’s not a carbon copy for every coal plant. You know, there are variations in the technology and the age and so forth. They will also say, "Well, we’ve got this coal purchasing contract. We’ve got to buy all this coal. We’re contractually obligated to buy all this coal, or we’ve got to pay a fee." Some things that don’t come into the equation, but I think are happening, are, there is this concept that goes by the term of "used and useful," which is the idea that if the commission sees that a coal plant is not being run much, if at all, as it would typically be if it was adhering to these economic principles, the commission might say, "Well, wait a second, this is not a good value for the ratepayers that we were supposed to look after."
David Roberts
Why not just close it?
Frank Rambo
Yeah, close it. And if the utility, as it does, is still recovering its cost and a healthy rate of return on its investment in that coal plant, they don’t want that.
David Roberts
"We need to run it to show you that we need to run it."
Frank Rambo
I don’t want to, you know, portray the utilities as mustache-twirling, you know, devious, but it’s that. That motivation, that incentive, is definitely there.
David Roberts
Right, right, right, right, right. They have the incentive to keep coal plants open until they’re fully paid off.
Frank Rambo
If the PUC comes along and says, "That’s not ever running, there’s no point in keeping it open at all," then the utility has to eat a lot of those costs. So they don’t have to be evil, they just have to be responding to economic incentives.
I think the other thing that’s going on here that the utility is not going to say in a proceeding, but I’ve been in this field now for over 20 years, and I’ve gotten asked in my career, particularly once I moved to the advocacy side of things, "Why does the utility do this? That makes no sense. They shouldn’t be doing it." And I understand maybe it can be an unsatisfactory answer for people who are not familiar with this world, but I think it is hard to underestimate the inertia.
David Roberts
And the culture of conservatism and doing things the way we’ve always done it, how much that prevails in the utilities. Again, a monopoly utility, you know, they are a great investment. They answer to their shareholders. They just want to keep doing things the way they’ve always done it. And one way that gets manifested, it’s like, "Well, we run coal plants this way. Let’s keep doing that." You know, whether it’s a conscious or subconscious thing, that definitely plays into it.
Well, here’s a question I guess is probably on people’s minds: so you have a lot of utilities that still have coal plants out there across the country who just occasionally start them up and run them for a while, even though they’re not the next most valuable thing for these various reasons. But I guess one question is how substantial of a problem is that? Like, are they doing it often enough that they are really like clogging up grids and keeping other sources off? Like, is it a substantial enough problem that it’s actually affecting what gets built?
Frank Rambo
Right, right, yeah. So just more to talk about, about the direct impacts, the short-term, like immediate impacts of this practice. But there are very important ways in which this practice has ripple effects outside of that immediate coal plant. And you’ve teed up one, and this is some work that we supported and funded — an analysis by NRDC and an expert outfit called Grid Strategies — to really drill down on this practice in one of the big Midwestern markets, MISO (Midcontinent Independent System Operator). They looked at 2021, 2023, assessed a number of things, but let’s pull out one thing that they assessed: looking at this link between what frequently happens, particularly in areas like this in Midwest and this MISO area, of wind farms being told by the grid operator, "You’ve got to dial back your wind farm, you can’t put all the energy that you can onto the system because it’s going to cause a reliability issue."
David Roberts
Well, that’s just math. I guess if you got more of one thing on the grid, you can have less of other things.
Frank Rambo
Right. Well, now the reasons for that kind of order being given by the grid operator to the wind farms can be any, and to restrict their output or curtail their output. So it’s often called curtailment. There can be a number of explanations. But one thing that Grid Strategies looked into was this link between episodes of instances of wind power having to be curtailed and whether that power that was on the system that was clogging the lines was from uneconomic coal power. What was the link? And they found that 25% over that three-year period, 25% of the power that had to be curtailed that was cheap and clean but couldn’t go was because uneconomic coal power was essentially clogging the lines.
David Roberts
And we should say it is pretty much impossible to be cheaper than wind when it’s blowing because it’s basically zero cost. You’re curtailing free power in order to run the very most expensive form of power, basically.
Frank Rambo
And it’s a classic insult to injury.
David Roberts
Right. So this is just to say this is not just kind of irritating. It happens at a large enough scale that it materially affects, like there’s a wind curtailment. I’ve been reading articles about this. Like, if you’re a renewable energy developer and you’re looking at a grid where coal can kind of stomp on and run whether it’s cheap or not, you are going to shy away from that grid. Right. Because it’s your cheapness that is your whole sales pitch. Like, if cheapness doesn’t matter, then you know you’re going to go build somewhere else. So this is a substantial problem.
Now, as we say, it’s more obvious when it’s happening in a market area, in a restructured market area. Just because everybody has access to that information. It’s quite glaring when, you know, when it comes on. So there have been a lot of, there’s been a lot of advocacy from Sierra Club and others over the years bashing away at PUCs in those areas, trying to get them to disallow this, trying to get them to dial this back. And there have been some successes in those areas. So, like, talk about, like, what happened in Michigan.
Frank Rambo
Yeah. So that was one of these fuel cost proceedings, fuel cost recovery proceedings. The utility is Indiana Michigan Power. It’s relatively small. It’s part of the whole American Electric Power (AEP) universe. It’s got territory in Michigan, Indiana, and Ohio. So they had to come in, they came into Michigan, they made this request: "We want to get around $100 million for what we burn on coal." And the advocates really, in that case, there are a number of groups involved. As in many states, the Attorney General’s office in Michigan has a Consumers Division, and they’ll have somebody who specializes in doing legal proceedings and helping protect customers through advocacy, protecting ratepayers at the PUC.
So the AG’s office there gets a lot of credit for getting on this issue. And sure enough, the Michigan PSC said to I&M Power, it’s like, "Okay, you’ll get all this, but we’ve looked at the data." Like, you know, the AG was able to get the data. They had their experts testifying, showing that the periods of time where I&M Power was burning coal, using coal power, when it could have been buying power on the market for a cheaper price, and said to the, you know, the AG’s office. Another said to the commission, "Okay, you know, that amount of coal that they burnt during those hours, that was not prudent. That was not a prudent use of the ratepayer’s money. They should have done the cheaper thing." And the PUC agreed and they rejected part of the request for that roughly $100 million.
David Roberts
So, shareholders had to eat that, basically?
Frank Rambo
Yeah.
David Roberts
Wow, a miracle.
Frank Rambo
And so it was not now, now, and this is an important part. The number was not, I don’t know, in the realm of the dollars that get thrown around in the world of utilities and the power grid. It was a $10 or $11 million rejection. It’s called a disallowance. "We’re going to disallow those costs." But I mean, here’s the thing that it’s important to remember about these utilities: they are private companies. Right. They have been given by the state a monopoly, but they answer to their shareholders. That’s who they have always on their mind.
And when you — it does not take much if you really want to change. I feel like if you really want to change the utilities’ behavior, hit them in the bottom line. So their shareholders are not going to be happy that they have $10, $11 million less, because they made this mistake, because they weren’t on their game, because they don’t have the procedures in place to make sure they are doing and making the prudent choice that does protect ratepayers.
David Roberts
So there’s hope here that the shareholders will then pressure the utility executives to quit this if it starts costing shareholders real money.
Frank Rambo
Right.
David Roberts
But that’s like a light in the darkness. And that’s in a market area. That’s in an open market area. Has anyone been able to get to these vertically integrated utilities? Because just like what they do and why they do it is much more obscure. It’s much more difficult to see from a public perspective. And I feel like PUCs are a little bit more kind of captured and cozy in those vertically integrated areas. Maybe that’s not fair, but has anyone been able to have any success getting to this practice in one of those vertically integrated utilities?
Frank Rambo
Yeah. And again, I just want to be clear, like I&M Power, it’s operating in that market. It is a vertically integrated utility. So we’re talking about where you have these markets and you don’t. But you’re right. So areas like the Southeast...
David Roberts
So, operating in a monopoly area. An area without a market.
Frank Rambo
Exactly. They’ve got that monopoly territory. West is a bit in flux, but. So maybe the Southeast is the best example.
David Roberts
The West and the Southeast, basically, I’d say, are the two areas without a market where this is the most.
Frank Rambo
And you’re exactly right, it is. It’s definitely a tougher nut to crack. I mean, I happen to know because before I launched Horizon Climate Initiative about two and a half years ago, I led the clean energy program at an organization called Southern Environmental Law Center, which operates in six states in the Southeast, most of which don’t have a regional market. So I actually have some personal familiarity with thinking about this issue in those contexts. And we did make a run at this issue, and it is hard. And that is the story of the advocacy on this issue, is that it’s been very piecemeal and not at the intensity and not coordinated and not sort of fleshed out in the way I think it should be.
I mean, that’s the kind of world I want to see. So the answer, the short answer to your question, is no, there really haven’t been great ways to do it now. But there are ways.
David Roberts
I mean, you go through the PUC, right? I mean, the PUC still has the power to do it. You just have to persuade the PUC.
Frank Rambo
Yeah. And that’s another thing about this work, no matter really where you are. And this gets to the immediacy point to take on this issue. Now, we’ve talked about some of the challenges already, particularly in the regions of the country that don’t have this regional market that gives you transparency and another advocacy opportunity. But it does have some, definitely has some things going for it, which are: we can win on this issue today. This is about reducing CO2 emissions and saving costs. That doesn’t require building anything. It doesn’t require a new policy, it doesn’t require law.
David Roberts
And I just want to emphasize something you just said. Crucially, by definition, when they do this, it costs ratepayers more money than they ought to be paying. So, by definition, if you can stop it happening, you are saving ratepayers money. It’s an absolute consumer win alongside the environmental.
Frank Rambo
I mean, my theory is that this issue has not been pressed enough, hard enough by different types of advocates and interests consistently enough to really make serious inroads, particularly in those areas of the country like the Southeast. But I think that pressure really can be broad. I mean, there are groups that show up in these proceedings, particularly in the Southeast, like SELC and others that know these commissions. And I think the other thing that gives this issue a particular potency and salience, particularly lately, and I think particularly since the results of the November election, is that, first of all, it’s really state, local.
This is not — there are some federal — and I think we’ll get into some of the federal shenanigans, but this, like the advocacy, like the heart of this advocacy, it does not rely on anything that’s federal. It’s all state, it’s all local. And it does go to that pocketbook issue at a time of rising rates, and rising concern about those rates.
David Roberts
The conventional wisdom is that clean energy people need to pivot to focus directly on cost of living. Like, that’s the big thing now for the next five years, cost of living is going to be the most important thing. Here is like, I mean, this is like a win-win on cost of living and all the other things. Before we run out of time, let’s get to the main— one of the main things I want to talk about, which is: so the Trump administration just came out with this reliability report which basically says, "Danger, danger. If renewable energy keeps coming on at its current pace and big fossil fuel power plants continue retiring at their current pace, the entire grid is going to fall apart by 2030. We’re going to have 100 times more blackouts and brownouts. The world is going to fall apart. Therefore, among other things, we need all the firm power we can get online, and therefore, we should keep coal plants online and running."
The first thing I want to know is, and this is always a question with anything Trump does, is, like, what legal force does this have? You know, he can say this, like Chris Wright, the DOE secretary, can come out and say this, but, like, legally, what force does it have?
Frank Rambo
Well, the report that it came out on July 7, you accurately summed it up there. The report by itself doesn’t have any legal force, but we have already seen what could come of this. I mean, why the Department of Energy issued this report was because of an executive order that Trump issued in April directing this report. But even before that report came out, in late May, the Department of Energy more or less explicitly — I think maybe in one case, explicitly, definitely impliedly in other — you know, referencing this clearly where the administration wants to go on this issue — issued two emergency orders invoking the same legal authority under the Federal Power Act to issue an emergency order keeping two plants online.
One plant was a coal plant in Michigan that was going to be scheduled to be retired, taken offline in a week. A week after this, they got this emergency order. In the other case, it was oil and gas units in Pennsylvania. And I think for that, it was like the next day it was going to go offline. So these are terms, unfortunately, that we might have to get used to, it’s a "reliability intervention." And there is emergency authority under the Federal Power Act for the Department of Energy.
David Roberts
Yes, climate campaigners used to yell at Joe Biden to declare a climate emergency under those same powers.
Frank Rambo
Yeah. So this is an incredibly aggressive — there is no precedent for using this authority in this way. So what Secretary Wright said in both of these cases is, okay, here’s some national and maybe sort of like some national assessment by the entity that looks at reliability nationally, NERC, expressing, you know, they really cherry-picked some statements in there that demand for electricity, demand growth is really going to be skyrocketing and it’s a cause for concern. Which is like, "No kidding, you know, welcome to the conversation that’s been going on for at least two years."
David Roberts
Yes, and they’re really trying to make a lot of the fact — like, this has always kind of been their thing, but they’re really trying to make a lot of the fact that renewables specifically are not reliable and that you need, like, this is their new wedge to get coal back in. Is this idea that a grid running on just renewables is not going to be stable or reliable enough for these big data centers? And this is a common — a very, like, it’s not just the Trump, you know, like, it’s a very common — a lot of people are trying to push that line.
Frank Rambo
Right. One of the odd things about these orders, they’re citing the real mismatch between the kind of language they’re pulling from various sources and their solution, which is "Keep this one plant online." There’s a restriction, 90 days. Like, wait, what? Like, how is keeping this expensive, very expensive coal plant online have anything to do with these broad statements that you have earlier in your order? So it said, so, like, you got a utility, you’ve got to comply using this legal authority. You got to run this plant. And like, in the Michigan case, I think that the chair of the PUC has gone on record as saying, "We didn’t ask for this. This is uncalled for. The Michigan AG thinks it’s uncalled for. The grid operator thinks it’s unnecessary."
David Roberts
This is what I’m curious about. Like, do these executive orders create any legal obligation that they have to do something, or is it just sort of like — is it just sort of like exhorting them? You know what I mean? Is it just yelling at them, or do they have to do something in response?
Frank Rambo
Well, these individual emergency orders that came out for these two plants, they absolutely have to comply. They are complying right now. They’re racking up extra costs.
David Roberts
So right now there’s a coal plant being kept online. Yeah. That the grid operators don’t want, the utility doesn’t want it, ratepayers don’t want it, the PUC doesn’t want it. It’s literally just Trump forcing this individual coal plant to stay online.
Frank Rambo
Yeah. It’s having to be complied with. I mean, there are legal challenges, there’s some legal process that’s going on. So this will get, you know, it’ll be — there’ll be some legal decision, but in the meantime, yeah, it’s happening right now.
David Roberts
Do you think this is one of those things that’s going to end up going all the way to the Supreme Court, and then they’re just going to give him another green flag to do whatever he wants? Do you have any legal prognostications?
Frank Rambo
I mean, I would not bet against that. I mean, right now, I think the Michigan case, I think the Michigan AG has just filed, there’s a process for asking for the DOE to reconsider. DOE did not respond to that. So that allowed the Michigan AG to file a lawsuit in federal court at the lowest level. So, you know, who knows how long it’s going to take to get up, you know, if the Supreme Court even, you know, takes it. I mean, there’s a lot of variables, but it does have some parallels, certainly with stuff that this administration is doing in other contexts.
David Roberts
But just legally speaking, the reliability report is just sort of background. The only thing that’s going to have legal force is one individual sort of emergency order about one individual coal plant at a time. Like, is that how they’re going to proceed here?
Frank Rambo
Well, you know, of course, another thing with this administration is you never know exactly what they’re going to try. So, you know, caveat there that, you know, there’s a lot that’s unprecedented about this administration. So I don’t want to rule anything out. But yeah, certainly one thing that I think we should be expecting is that there could be other emergency orders that say, "Do this, do this. I’m invoking this emergency authority." But you’re right, as you’re kind of intimating, I guess it is possible that the Department of Energy will now use its July 7 report, which is seriously, seriously flawed.
There’s a saying, I don’t know whether you ever heard it in this field among people who do the modeling that says, "All models are wrong, some are useful." But I think what the DOE here did is definitely wrong, and it’s not even useful.
David Roberts
I mean, they practically admit it. They practically say upfront that the goal is to keep the coal industry going. That is the point. That’s what he promised during the campaign. So clearly everything in the report is very obviously backfilled to reach that conclusion.
Frank Rambo
Yeah, that’s my conclusion. I mean, the assumptions they made, three key assumptions. Two were very aggressive, but maybe plausible, and one other key assumption they made, there’s no basis in reality for it. And on their solution, right, so they totally misidentify the problem. They kind of create the problem that they want to now have their solution to. Now, the thing about coal, as it’s been circling the drain, the coal plants that are left are running much less. They’re not running as these baseload where you run it, you might dial it down at night when demand for electricity is lower, but you’re basically always running it.
They are now running much less. They’re running more where they’re having to cycle through, to cycle on and off. And a coal-fired boiler is not built to operate that way. Again, it’s a 20th-century resource for a 21st-century grid, and that causes a lot of maintenance issues. So that they have to — all of a sudden it’s called a "forced outage." They have to take it offline. So it’s somewhat ironic they are relying on — the DOE is relying on — the one, one of the resources that’s becoming less and less reliable.
David Roberts
Yes. So even if you take all the environmental considerations off the table and are just looking at this notion that we’ve got a bunch of big loads coming online and we need big reliable sources, even purely through that lens, you wouldn’t go to a coal plant. Like even, like even just building a new gas plant is cheaper than running an existing coal plant. Like people say, you know, solar and batteries are expensive. And they are, but they’re less expensive than a coal plant. Like any of the other firm power alternatives almost are cheaper than this.
Frank Rambo
I agree with that. And also it is a serious error to just look at ways to supply electricity. You can look on the demand side and there’s been a lot of discussion. Right. On the load flexibility that if you require one of these data centers, just like say "Hey, maybe 0.5% of the time or 0.25% of the time," the utility says "we’ll have to call on you to dial back how much energy you’re using." Having that flexibility to effectively create room for 75 to 100 gigawatts of data center demand.
David Roberts
I’ve done several pods on data center flexibility recently and just load flexibility generally. And of course, if you want to reach the conclusion that you need to keep coal open, you basically have to assume zero demand flexibility. Just a little bit of demand flexibility wipes out your case for coal almost immediately. So they have to ignore that. So I’m wondering, sort of like bringing these two discussions together. There’s this ongoing thing of uneconomic dispatch. There’s this ongoing — I guess you’d even just call it a habit, a habit of utilities of running these coal plants periodically even though they’re not the next in the merit order.
There’s this ongoing fight about that. It’s gained some ground in market areas. Not as much in the non-market areas. The best way, I think, to improve the visibility and to reduce that in those non-market areas is to bring markets into those areas. Like, would you, is that, I mean, is that your basic diagnosis? Like, it would be great if the West and the Southeast developed some sort of market?
Frank Rambo
Yeah. There’s no doubt that making progress on this issue is easier if there’s one of those regional markets. But again, I’ve been down in the trenches in one of these areas that does not. And there really is a way, though, to win here.
David Roberts
Well, my question that I was trying to get around to is, is this new push from the Trump administration, this new reliability report, all this pressure, basically this, you know, as you say, there’s only limited circumstances where they can actually force utilities to do this. It requires, like, at least for now, it requires sort of like these individual emergency orders. But I wonder if you think that this general pressure to keep coal plants open from the top is going to influence PUCs and utilities and make this fight harder at the state level. Is that, do you worry about that?
Frank Rambo
I think there’s definitely that, again, this is something, right, of a pattern outside of this context of this administration of intimidation. It gets called intimidation or bullying or sending the signal. Like clearly, you know, "State, we’re exerting some influence on you because you may, state commission, maybe you won’t agree to a proposed coal retirement date now because you think it will be undone or it’ll put you on the wrong side of this."
David Roberts
Or they’ll just, they’ll come after you for revenge, which is entirely plausible.
Frank Rambo
I think also, though, this is an opportunity, it’s kind of like I’m not much of a boxer, but right where you throw, if you’re throwing a punch like the Trump administration is doing, you kind of leave yourself open. And getting back to the energy affordability debate, when he was on the campaign trail, Trump talked about energy affordability. "I’m going to bring your energy bills down 50% in 12 months."
David Roberts
Yeah. What happened to that?
Frank Rambo
And the fossil industry, they talk about energy affordability all the time. And energy affordability, high prices are all over these executive orders. And I think it’s a mistake for those of us who see this as a bad move on the climate to not — like, we need to pick up the gauntlet, we need to highlight this issue.
David Roberts
We’re winning that argument too.
Frank Rambo
Right. You say you’re for energy affordability. Let’s talk about coal. Let’s talk about how it is already today — like getting back to the work with all these groups that we’re supporting on economic operation of coal — it costs $5 billion. One of my foundational grants was to RMI to set up a tool that’s online that does a great job — because this practice is very hidden, it’s so dispersed — they do a great job of gathering the data and presenting it in a very user-friendly way. And their calculation that you can see, everybody can go see, is in 2024, the excess cost, because of this practice, the utilities and others get away with the cost: $5 billion extra and it’s like $24 billion over the last 10 years.
David Roberts
Yeah, that’s not a small amount. And I think this is one of those things where the public’s general impression, I think, is like, as usual, like 10 to 15 years old. You know, like the public does not — it’s so hard to keep, I mean it’s like genuinely hard to keep up with this area. But like the public especially, I think they still, the public has no idea. If the public knew that utilities just fire up coal plants periodically for their own yayas, even though coal plants are wildly more expensive than everything else they have at their fingertips and that that was costing them money, I feel like surely that would penetrate.
Frank Rambo
Well, in this case, again, like a really important—I think I referenced this up near the top of the narrative that gets attached to coal’s demise. One of the groups that I work with and support is called Resource Media. They do communications work, and they did some opinion research with one of our community, state, local organizations in Indiana on several aspects about coal. And they had some really interesting findings. One of which is when people were asked, is coal — basically, "Is coal expensive?" Well, first of all, if you’re a Democrat, like only like 40% of people thought coal was expensive.
If you’re a Republican, it’s like 10% of Republicans. And you know what it reminds me of is I don’t know whether you’ve ever seen this, that they say, I think there’s some study or literature out there that says your musical taste gets set right when you’re like between 13 and 16 years old or something like that.
David Roberts
So true. This explains so much of our politics. Honest to God.
Frank Rambo
Yeah. And I think that is the same way the attitudes about coal and, you know, other things that — and this gets also back to your opening about a lot of us who are in the space and have been watching coal circle the drain for so many years and see the writing on the wall. I think we can forget that so many people who are not paying attention, who have more important things to do, they’ve got to worry about daycare, they’ve got to worry about the car in the shop. But here’s another thing they found with that opinion research.
When you talked about keeping coal plants open, again, there was a real partisan divide there. Republicans are like 33% more likely to say, "Go, keep that open, keep that open." But when you frame it as, "Should utilities stop charging customers for coal power if it isn’t the lowest cost energy available?"
David Roberts
No partisan — like across the board, bipartisan, 8 in 10 people: "Yeah, that is a bad thing." So I really do think that this is a great issue to highlight. Let’s have that energy affordability debate. Let’s pick up the gauntlet, and let’s see who’s on the right side of that.
Yeah, yeah. In general, I feel like the best argument for clean energy people right now is not climate or pollution. It’s just "We’ve got the better stuff and there are big incumbent dinosaurs between you, the public, and a cooler, better world." Right. Like, we’ve got the cool stuff now. We don’t need the public to eat more expensive or be virtuous, you know, like.
Frank Rambo
This is a classic political story. "There’s a bunch of incumbents in the way of a newer, better world. Let us knock them out of the way." And this is like the mascot of that argument. This is the clearest example of that argument. It could not be more cut and dried. So this is like communications dynamite. I think like the idea that utilities are doing this is just like, yeah, everybody should be shouting about this. If we had a giant communications machine, which we don’t, but that’s a different pod. Okay, well, this is great, Frank.
David Roberts
Thank you for walking me through this. I think a lot of people listening to Volts probably sort of like kind of suspected this is what was going on. But it’s good to really nail it down that utilities really are doing this, and the Trump administration really is trying to get them to keep doing this, and it really is dumb and expensive, and there really is no justification for it.
Frank Rambo
Yeah, this issue really brings — it’s like, I think of it as like a crucible in this one issue and all these different big ideas and just bringing it down and making it very concrete and real. In a way that so many of these big energy debates are so conceptual and far, long-term, and kind of global. This makes it real.
David Roberts
Thank you for your time, Frank.
Frank Rambo
Okay. Dave, really enjoyed it. I could talk for another hour.
David Roberts
Thank you for listening to Volts. It takes a village to make this podcast work. Shout out, especially, to my super producer, Kyle McDonald, who makes me and my guests sound smart every week. And it is all supported entirely by listeners like you. So, if you value conversations like this, please consider joining our community of paid subscribers at volts.wtf. Or, leaving a nice review, or telling a friend about Volts. Or all three. Thanks so much, and I'll see you next time.
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