Abuse of Power: Debunking the Trump Administration’s
National Security Argument for Coal
This column was published by the Center for American Progress" (www.americanprogress.org)
Vulnerabilities exist across the spectrum of energy resources
All energy resources face vulnerabilities. Natural gas power plants rely on pipeline delivery of fuel for operation, generally without on-site
storage. Additionally, natural gas pipelines increasingly depend on electricity at pumps, refineries, compressor stations, and monitoring, all of
which present vulnerabilities to natural and man-made events. At the same time, oil and refined petroleum products, renewables, and even
coal rely on modes of transmission, distribution, and storage that expose these resources to both physical threats as well as cyberthreats.
More comprehensive assessments of the resilience of energy infrastructure, such as large power transformers and reliance on railways to
transport energy commodities, have revealed equally or more serious vulnerabilities.

The reality is that severe weather continues to outrank all other threats to the U.S. electric grid, including to on-site coal storage. Residents of
Puerto Rico, the U.S. Virgin Islands, Florida, Texas, and other storm-ravaged locales can confirm this; in fact, residents of New York City, which
Secretary Perry recently speculated would turn “into a jungle because the lights go out,” can point him to Superstorm Sandy. Sandy damaged
substations, transformers, and power lines, causing blackouts; it even forced some nuclear plants to shut down some reactors in advance to
prevent damage. The U.S. Department of Energy (DOE) memo overlooks these very real threats to U.S. national security and energy
infrastructure.

The Trump administration is making good on its promises to coal industry supporters
Following several campaign promises, President Trump and his administration have repeatedly attempted to subsidize uneconomic coal and
nuclear power plants. In 2017, Secretary Perry directed the DOE to study the U.S. electric grid and then summarily rejected his own agency’s
findings, namely, that no evidence supported his claims emphasizing the need to subsidize nuclear and coal power plants. In a subsequent
proposed rule, Perry urged the independent Federal Energy Regulatory Commission (FERC) to order electricity market operators to subsidize
power plants with on-site fuel reserves, meaning nuclear or coal, again claiming a resilience threat. FERC unanimously rejected the idea, with
experts stating it “would blow the market up.” The influence of Trump’s donors on this effort is clear.

Other signs also point to the administration’s prioritization of ideology over fact-based analysis. Reports have indicated that President Trump
may nominate Bernard McNamee, who has led the coal bailout efforts from his DOE post as head of the Office of Policy, to fill a vacancy at
FERC. While addressing a nuclear industry audience, a top FERC political appointee described the collaborative effort among FERC, the DOE,
and the National Security Council to name which power plants are “critical” to the grid. The administration has carefully set the stage for this
latest move.

The Trump administration politicizes and dilutes national security tools
Given the absence of any exigent threat to the national electric grid, President Trump’s directive follows similar patterns of invoking national
security authorities to situations that do not demand them. Specifically, the Trump administration’s coal bailout proposal would direct grid
operators and, potentially, other entities to purchase any electricity used for defense purposes from a list of coal and nuclear power plants
under Defense Production Act (DPA) authorities. The DPA, a Truman-era procurement law, enables the government to procure products or
services needed for wartime, including to stimulate innovation to advance strategic goals. The proposal would also direct the DOE to use its
Federal Power Act Section 202(c) emergency authorities to keep nuclear and coal generators running. Section 202(c) authority enables the
secretary of energy to temporarily require the operation or connection of individual generation, distribution, or transmission facilities to maintain
normal operation of the electric grid to prevent or respond to a blackout or other localized power shortages.

In both cases, the proposal distorts the intent of the two laws and potentially undermines the ability of future administrations to respond to real
threats. The DPA authority would force grid operators to purchase electricity from coal and nuclear generators, ultimately passing the costs
along to consumers, and Section 202(c) would require these generators to produce it, despite it costing more than power from other
resources. The proposal may also further provide industry loans or require stockpiling excess fuel resources. Combined, the DPA and Federal
Power Act Section 202(c) authorities would support coal generation and mining, paying for both by wasting scarce taxpayer dollars while
forcing utilities to run their least efficient, most expensive, and highest-polluting power plants. According to a Brattle Group study, a DOE
subsidy of coal and nuclear plants could cost taxpayers up to $35 billion annually.

Conclusion
The Trump administration’s proposed use of these authorities would misinterpret their intent. Currently, no grid emergency exists that merits
invoking the DPA; in other words, there is not a lack of power supply to defense facilities or functions in the lead-up to an armed conflict, as the
law envisions. This proposed use of the DPA would not meet itsstandard of “promoting efficiency and competition,” either. In the case of
individual blackouts or service shortages, Section 202(c) can and should be utilized in a localized, limited, and strategic fashion—not by
subsidizing an entire class of generation.

U.S. Department of Defense (DOD) facilities certainly experience electricity outages, but the DOD plans for contingencies and services their
critical infrastructure with backup generators. Furthermore, the remoteness of these facilities makes a stronger argument for enhancing on-
site resilience through microgrids, nonfuel-dependent generation sources, such as renewable generation, and more on-site system
redundancies rather than increasing their dependence on the traditional centralized grid architecture that existing coal and nuclear power
plants utilize.

By isolating its risk assessment to a limited set of threats, metrics, and solutions to favor political outcomes, the administration obscures
other, possibly more imminent threats to U.S. energy infrastructure. The application of these emergency authorities—when there is neither an
emergency nor an efficient outcome from their use—would subvert the rule of law and the intent of the DPA and Federal Power Act Section 202
(c) provisions, opening the door to further abuses of power.

Luke H. Bassett is the associate director of Domestic Energy Policy at the Center for American Progress. Ned Price is the director of Policy and
Communications at National Security Action.
Getty/Michael WilliamsonA coal-fired power plant sits
near the Ohio River in West Virginia, November 2011.
By Luke Bassett and Ned Price
After several failed attempts to bail out coal power plants, President Donald
Trump and his administration have turned to co-opting national security tools and
arguments to pursue their domestic energy agenda. Recently, administration
officials have selectively targeted natural gas and renewable energy generation
resources, falsely claiming they pose greater risks to the electric grid than do
nuclear or coal resources. Specifically, Secretary of Energy Rick Perry
misconstrued the facts about certain electricity generation resources and their
relative vulnerability to threats, hiding behind his access to classified information
to short-circuit a policy debate and thereby strengthen his proposal in a way that
circumvents fact-checking.

This unprecedented use of defense arguments to favor certain electricity
generators over others defies competitive energy market rules. Furthermore, it
impairs the ability of experts, officials, and even the public to assess, prevent, or
respond effectively to actual threats to the energy system, thereby undermining
national security efforts as a whole.