Michelle Bloodworth is the CEO of America’s Power, a trade association representing the companies that supply fuel to and operate coal-fired power plants. In this episode, Bloodworth discusses the war on coal, the federal regulations that could shutter most of the remaining coal plants in the country, and why regulators at the state and federal levels need to be more focused on electricity reliability. (Recorded February 8, 2024.)

Episode Transcript

0:00 – Robert Bryce

 Hi, everyone. Welcome to the Power Hungry podcast. I’m Robert Bryce.


0:00 – Robert Bryce 

On this podcast, we talk about energy, power, innovation, and politics. And we’re going to talk a lot of power and politics today with my guest, Michelle Bloodworth. She is the president and CEO of America’s Power, which represents the coal-fired generators in America. Michelle, welcome to the Power Hungry podcast.


0:10 – Michelle Bloodworth 

Well, thank you, Robert. I certainly appreciate the opportunity to be here. I’ve followed your work for years and I can’t think of a better place to talk about certainly energy and the energy sector and certainly a lot of the challenges that we’re facing on Power Hungry podcast today.


0:27 – Robert Bryce 

Great. Well, now I mentioned America’s Power and you’re a trade association. I think you’ve changed your name in some recent years. But you are the president and CEO there. Your trade association represents the companies that, as I understand, supply and operate America’s coal-fired power plants. But that’s a brief introduction. Guests on this podcast introduce themselves. So now imagine you’ve arrived somewhere. You don’t know anyone. You have seconds to tell them who you are.


0:55 – Robert Bryce 

Please introduce yourself.


0:58 – Michelle Bloodworth 

All right, well, America’s Power, as Robert said, is the only national trade association who advocates on behalf of coal electricity, both at the federal and the state level. Our members consist of electricity generators, coal producers, transportation companies, and equipment manufacturers who are involved in some part of the coal supply chain. I always like to tell people that Certainly America’s power supports all energy resources which provide affordable and reliable energy.


1:31 – Michelle Bloodworth 

Because as most people know, all energy resources complement each other in different ways and in different times. I certainly do strongly believe that the coal fleet has been one of the foundations of the electricity grid. And certainly we need all resources. We don’t need to eliminate any resources. And I do think that coal, because of the fact that it provides reliable, resilient, and affordable electricity, will not only be needed now, but also in the foreseeable future.


2:03 – Robert Bryce 

Okay, good. And just so we’re clear, you’re based in Arlington, Virginia, is that correct?


2:09 – Michelle Bloodworth 

I am, yes. Okay, gotcha.


2:11 – Robert Bryce 

And how long have you been in your job? So I’ve been in my job about six and a half years.


2:17 – Michelle Bloodworth 

And prior to that, I worked for MISO, which is the Midwest grid operator. And then I also spent two decades of my career in the natural gas industry, both on the pipeline, the producer side and the LDC side. Gotcha.


2:33 – Robert Bryce 

Okay, so long history in the energy sector, including at MISO, Mid-Continent Independent System Operator. Okay, so good. Well, I looked up America’s Power. I like to do my homework. I looked at your Form Your revenues are about million. Now, for comparison, million in For comparison, the American Clean Power Association, which represents the solar and wind crowd and their batteries and the rest of them, had revenue of million. And just a little preface for my question here, because I’ve got to be very blunt here, and I’m not going to tell you something you don’t know.


3:10 – Robert Bryce 

America’s coal-fired fleet is getting killed. I mean, just very definitely. In the EIA’s numbers, coal-fired generation in the U.S. Since it’s fallen by more than half. In about terawatt hours per year were coming from coal-fired generation. In it was about terawatt hours. Is there a war on coal in America?


3:36 – Michelle Bloodworth 

Well, there’s certainly been a war on coal as it relates to this administration. Certainly no secrets. I wouldn’t say it’s just coal. I think there certainly are a lot of policies coming forward that really want to see the retirement of both natural gas and coal. I would also say that I’m cautiously optimistic. Certainly we’ve spent a long time over the past, I would say three or four years really expressing our concern over the accelerated rate of the retirement of coal plants.


4:09 – Michelle Bloodworth 

It’s not just America’s power now. You know, you’re hearing from the North American Electric Reliability Council, Jim Robb, we spent a lot of time with him, their CEO, all the electricity experts who that’s what they do every day is try to keep our lights on from these grid operators who are all expressing loud alarms about the rapid pace of the loss of dispatchable resources and how the grid is certainly not ready to replace those with the same capacity value and also the same reliability attributes that coal provides.


4:44 – Unidentified Speaker 



4:45 – Robert Bryce 

Well, I want to just ask that again, because I want to make sure that I understand what you’re saying. So is there a war on coal?


4:56 – Michelle Bloodworth 

Yes, I certainly think that there are a lot of people who are opposed to coal. However, I do believe that when people really understand the need to put reliability first, we’ve done a lot of polling. People become very supportive of coal and of thermal resources because of those attributes that we don’t have technology, whether that’s long duration battery storage, Whether that’s hydrogen, I certainly support carbon capture, but those technologies are decades away, and they’re certainly not widely deployable on a commercial basis.


5:32 – Robert Bryce 

And so I do see the conversation changing.


5:36 – Michelle Bloodworth 

Yeah, I agree.


5:37 – Robert Bryce 

And I want to talk about FERC and NERC and the warnings that they’ve made and the RTOs as well have warned about this in very clear terms. But who’s waging the war? From where is the, I mean, what is, who’s waging the war and what’s the ideology behind it?


5:53 – Michelle Bloodworth 

Yeah, I think because electricity is so complex, certainly the NGO community is supporting This administration’s goal to completely decarbonize the electricity sector by certainly from an engineering and a physics and a realistic standpoint, that is not realistic and not


6:15 – Unidentified Speaker 

achievable as we certainly are seeing.


6:18 – Michelle Bloodworth 

There are many challenges to the grid transition, which I can talk about those in a minute, but our biggest challenges are six environmental regulations and certainly three, Half of those were promulgated in less than three months. Just even trying to assess the impact, you know, the implications of these regulations. Certainly the most onerous one is the carbon rule, which many call Clean Power Plan which really would put the entire coal fleet at risk by when all these electricity grid operators and NERC are saying, you know, three quarters of the country is at elevated or high risk of blackouts.


7:01 – Michelle Bloodworth 

And that is unheard of with a country who certainly can be energy independent.


7:08 – Robert Bryce 

Well, let’s talk about the grid for just a minute.


7:13 – Unidentified Speaker 

I think you’re exactly right when you say it’s incredibly complex, and it is.


7:16 – Robert Bryce 

And we take electricity for granted in the United States. And as I’m sure you know, I’ve written about electricity a little bit and am pretty familiar with the business. But it is an insanely complicated grid that we have in the United States. Over electricity providers. You’ve got the RTOs. You’ve got the PUCs at the state level. You have all these NGOs. You have the investor-owned utilities. You have the publicly-owned utilities. You have the co-ops. You have the federal entities.


7:41 – Robert Bryce 

That’s the preface for this question, which is a simple one, but it goes and underscores all the things you’re talking about. Who is responsible for the reliability of the electric grid in America?


7:52 – Michelle Bloodworth 

And I think you point out a great problem, because there’s not one entity who is, you know, accepts that they’re fully responsible for the reliability of the grid. And so the challenge is, is that Certainly it’s going to take states, legislation and policy decisions that they’re making about the timelines of decarbonization. We are seeing state utility commissioners also sound large alarms. I haven’t seen, at least in my career, publicly a state utility commission. South Dakota commissioners a couple weeks ago basically sent a letter, public letter, to the utility that they regulate in South Dakota because of three large coal plants totaling about megawatts that they plan to retire in Minnesota.


8:45 – Michelle Bloodworth 

The Minnesota State Utility Commission approved those retirements, and South Dakota is basically saying, you know, we’re going to have blackouts. We’re listening to MISO. We’ve looked at their analysis. MISO is showing they’re going to have a gap next year. That gap grows through Again, even when they look at all the renewables that are in the queue, but their ability to connect those. Certainly we have a tremendous amount of transmission According to the Electric Power Research Institute, if we’re going to be able to replace and decarbonize the entire electricity grid by then we’re going to have to add a million megawatts of wind, solar, and some battery storage.


9:32 – Michelle Bloodworth 

Certainly, that has a price tag of about a trillion dollars. We all know how hard it is to get transmission built. Certainly there is transmission that is needed, but that typically takes to years. We have inadequate natural gas infrastructure. Certainly we’ve seen a lot of that during these extreme winter events. It’s certainly hard to get any of that permitted. And then I also talk about technology. You know, we don’t have the technology to be able to replace fossil fuels And then all while we’re trying to electrify the economy, we are seeing more electricity demand growth.


10:12 – Michelle Bloodworth 

Utilities are increasing their forecast just from even a year ago. We’ve seen that in Georgia. We’ve seen that in Kansas. PJM has tripled their electricity demand forecast, which is why we’re seeing the need to delay many of these coal plant retirements and now even natural gas as well.


10:34 – Robert Bryce 

So I I want to make sure I’m hearing what you’re saying because I’m familiar with the issues you’re talking about, but is there any Who owns the reliability issue? I’m going to preface that my friend, Meredith Angwin, I was speaking with her this morning. She wrote the fabulous book, Shorting the Grid. We’ve talked about these ideas about deregulation, restructured markets, et cetera, and she said people will challenge her and say, well, you’re in favor of monopolies, the old vertically integrated utilities, and her reply is, I’m not in favor of monopolies.


11:05 – Robert Bryce 

I’m in favor of accountability. So who is responsible for reliability of the electric grid in America? Because this is ultimately what we’re talking about, isn’t it? Where does the buck stop when it comes to reliability?


11:20 – Michelle Bloodworth 

And again, if you look in MISO, MISO would tell you it’s a shared responsibility between state utility commissioners.


11:28 – Multiple Speakers 

If it’s a shared responsibility, then everybody can point to everyone else, right?


11:32 – Michelle Bloodworth 

And that’s the problem. Because even NERC, and they do nice job. Jim Robb’s been all over the United States. They can do reports, they can issue warnings, they can set standards, but they cannot force a utility not to retire a dispensable unit, even when they think that three quarters of the country is elevated or high risk of electricity shortages. And so that’s why, in our opinion, it’s going to take changes at the state level from The way state utility commissioners look at analysis, do reliability analysis, it’s going to take federal legislation.


12:12 – Michelle Bloodworth 

Certainly that would require federal agencies, including the EPA, to do reliability analysis before they finalize any rules. I’ve never seen the grid operators who now are engaging and providing very strong comments and trying to work with the EPA to really educate them on their concerns, whether that’s the ozone transport rule, whether that’s the carbon rule, to basically say, if you finalize these rules in the way that you’ve proposed them, we’re not going to be able to keep the lights on.


12:45 – Robert Bryce 

I think that’s where we’re getting to the nut here, I think. I’m being insistent on this idea of reliability because this fundamentally is what we’re talking about. I’m with you in terms of affordability, reliability, resilience. You filed comments with the Federal Energy Regulatory Commission last June And you quoted, right near the top of your comments, you quoted Jim Robb, James Robb, the president and CEO of North American Electric Reliability Corporation. He said, unless reliability and resilience are appropriately prioritized, this is Robb, current trends indicate the potential for more frequent and more serious long-duration reliability disruptions, including the possibility of national consequence events.


13:26 – Robert Bryce 

I mean, these are very strong terms, very strong. Well, they could be stronger. And I think James Danley last year before the Senate Energy and Natural Resources Committee, his colleague Mark Christie, the chairman of the commission, Willie Phillips, all warned about potential for catastrophic blackouts in the United States. But I’m going to read back to you, Michelle, what you’ve said is that because it’s this shared responsibility at the state level, the RTOs, the feds, actually getting this, I’ll put it this way, are we pounding the table hard enough, and I use the collective we, are you pounding the table hard enough?


14:01 – Robert Bryce 

Are the people who are on the side of the business side pounding the table hard enough? Because I just gave you the numbers, your size of your organization, all due respect, you’re a fraction of the size and have, let’s face it, coal is not fashionable, I don’t think I’m shocking you to say that, where wind and solar have budgets 13x the size of your organization. They have the media behind them. They have a whole lot of public, you know, acceptance and love that the coal industry doesn’t have.


14:29 – Robert Bryce 

You’re facing a serious uphill battle here, aren’t you? Maybe I’m just saying, Mr. Captain obvious here, but the coal fleet in the U.S. Is being decimated.


14:40 – Michelle Bloodworth 

I don’t disagree with you that we’re certainly facing an uphill battle and certainly America’s power is pounding the street. As hard as we can, and I think we’ve done that in an effective way, certainly with more resources. All organizations could do more. I think what has changed, though, is even when Senator Manchin held Senate Energy and Natural Resources Committee last year, and he had all of the four FERC commissioners, and when he asked them, is coal you know, still going to be needed in order to maintain reliability.


15:16 – Michelle Bloodworth 

And the fact that every single one of them, whether they’re Republican, independent, or a Democrat said, yes, we still need coal for the foreseeable future. And so to me, the conversation now is people accept that there’s a problem. I think where you would organizations differ and resources differ is on what is the solution now to solve the problem. But to me, until people admitted that there is a problem with the pace and the premature retirement of all of these resources, that it’s hard to bring forward the solutions and to convince people that this is an urgent problem.


15:57 – Michelle Bloodworth 

You know, when I think about, and obviously we track coal retirements very closely. So in it’s about megawatts. So over of the coal fleet has retired. But what’s more concerning is in the next five years, a third of the coal fleet remaining has publicly announced retirement. On top of that, we’re also seeing natural gas generation retire as well. And what a lot of people felt like is because obviously, when grid operators look at how dependable a resource is. One of the reasons why we need a coal fleet and why we need thermal resources is because coal provides a capacity value, which is a measure of dependability on those days of extreme weather when you really have a spike in electricity demand.


16:55 – Michelle Bloodworth 

When you look at solar, solar only is given a capacity value of about So that means coal is about more dependable than solar, and it’s about more dependable than wind. And so not only do you have to triple or add six times as many megawatts of those other resources, Now NERC and all the PJM, MISO, all the grid operators have identified reliability attributes that we’ve taken for granted. MISO’s identified six, fuel assurance, long duration energy, energy that we have hours a day, seven days a week, voltage stability.


17:39 – Michelle Bloodworth 

And that’s when you get into a lot of the complexities of the electricity grid, but there aren’t any other resources and certainly coal You know, it’s hard to beat days of stockpile of on-site coal, especially when you look at the challenges during a lot of these winter storms that natural gas faced, because natural gas is used for a lot of other things. And every coal plant that is retired obviously is putting that reliability and that fuel security greater at risk. And that’s why we’re saying we need to avoid the premature retirement of these coal plants that have a lot more life.


18:19 – Michelle Bloodworth 

And we need this administration and the EPA, obviously, to look at all the impact of these six environmental regulations, many of them which we think need to be revised and withdrawn, including the carbon. So you said that by the EPA, well, you mentioned the US had gigawatts.


18:40 – Robert Bryce 

I think you said megawatts, but anyway, gigawatts, megawatts of installed coal capacity. You said it was gigawatts. But by the EPA is projecting that it could be as low as gigawatts. I mean, that’s a quarter of the current size, roughly. And would that be because of the carbon rule that you mentioned?


19:10 – Michelle Bloodworth 

So in looking at the carbon rule, And just to be clear, if people don’t understand this, so this was a proposed rule that was issued last May by the Environmental Protection Agency that would affect nearly all of the coal-fired


19:25 – Robert Bryce 

power plants in America and most of the, well, all of the coal plants and most of the gas plants, ultimately affecting something like of all the coal and gas-fired generation in America. It’s a draconian approach that would require massive decreases in CO2 emissions from that fleet. The solutions they propose are carbon capture and sequestration and hydrogen. Have I summarized that pretty well, Michelle? You know these regs better than I do, but that’s how I would read it back.


19:53 – Robert Bryce 



19:54 – Michelle Bloodworth 

According to EPA’s own analysis on the impact of the carbon rule, they are basically projecting by we’d have a decline, meaning retirement of coal generation, and they’re virtually showing in we would have virtually no coal. And I’m sorry, the projection of, and this is the EPA saying this? This is the EPA’s own projection and own analysis. And so when I testified at the recent FERC conference on the carbon rule, you know, both Commissioner Danley and others and Commissioner Christie said, well, that certainly doesn’t sound like an orderly retirement.


20:36 – Michelle Bloodworth 

You know, Jim Robb keeps saying we cannot have a disorderly retirement of this generation until we have technology, we have steel in the ground. It has whatever’s replacing it, has the same capacity value and has the same reliability attributes. And obviously, we’re all seeing the challenges as it relates to permitting, transmission and technology. The other certainly flaws because to me the Clean Power Plan is significantly worse than the Clean Power Plan And so this carbon rule, which requires obviously the coal fleet to meet certain amounts of carbon reduction.


21:21 – Michelle Bloodworth 

If you just look at the timelines, so EPA is going to do everything they can to finalize this rule in probably April of this year because they want to make sure that a new administration could not use the Congressional Review Act to roll that regulation back. Right. All right. States have two years in order to comply and put together state implementation plans, which EPA can decide to approve or disapprove. So since this regulation requires, if you wanna operate your coal plant, we have many owners who have put a lot of money into their coal plants, they have a lot more years of life.


21:59 – Michelle Bloodworth 

If you wanna operate it beyond then you have to install carbon capture and achieve carbon reduction in less than three years. I have five members who have been pursuing some of those for the past nine or years, who also say it is not physically and feasibly possible for us to have all of the infrastructure. You know, not every coal plant even has the geography or the physical capability of installing carbon capture. We have investors who are pulling away from projects.


22:38 – Robert Bryce 

I’m sorry to interrupt, but I just want to make sure I’m understanding what you’re saying, that under the proposed rule now, which EPA has fast-tracked, and I know they reopened some part of it for some additional comment, but you’re saying that to comply with the rule as written now, all of the coal-fired power plants in the United States would have to buy, within the next three years, implement carbon capture systems and have them in place? Well, they would have to have them in place by but no one is going to start construction until the EPA approves your state implementation plan.


23:18 – Michelle Bloodworth 

You’re not going to spend a billion and a half dollars. And so I see, okay, so given the timeline, so under the timeline, the state say I’m in Texas, they would have to supply, they would have to have their SIP, their SIP approved by EPA, which would take two years,


23:33 – Multiple Speakers 

that would give that takes two years away from the five, let’s call it, then that gets approved, then they would only have three years to install this massive amount of infrastructure, including equipment that would have a parasitic load of


23:46 – Robert Bryce 

to percent on their power plants, then have a way to inject all of the CO2 that they’re collecting somewhere underground, somewhere somehow at massive cost, otherwise they shut down. Correct. I mean, many states don’t even have that simple little thing that I get this all pretty simple.


24:06 – Multiple Speakers 

And then on top of that, you know, if you agree, because obviously it’s got force mandate retirement dates.


24:13 – Michelle Bloodworth 

And so if you agree, the incentive is if you agree to retire earlier, then EPA is either going to require you if you’re a coal plant to co-fire with natural gas. Many of these coal plants are not near natural gas pipelines. We already have a very taxed natural gas system. And if you’re a coal plant, has to burn natural gas, the economics are probably gonna cause you to retire at any way, or you have to reduce your capacity factor to Right. That was the other part of the equation here, is how the capacity factor figures into how this carbon rule is applied.


24:52 – Robert Bryce 

Right. But is it fair to say it’s a Well, and the other part of this that just sticks in my craw, and now I’m going to opine a little bit or add a little editorial here, is this is coming out of the administrative state. Again, this isn’t Congress passing this. So, back up for just a minute. I don’t know if you’re a lawyer or what your background is, but the Chevron doctrine is now pending before the Supreme Court. I thought some of this was resolved in the West Virginia versus EPA case, but now this is a big issue in front of the Supreme Court.


25:21 – Robert Bryce 

If the Supreme Court rules that the administrative state broadly, right, the issue is the administrative state. How much is Congress ceding their power to the bureaucracy? If the Supreme Court comes out with a strong ruling on the Chevron doctrine, could this neuter or slow down or stop the EPA’s actions on these things? Then where the industry could just say, well, Chevron doctrine, you know, meet to see in court. How might that affect this? I know that’s a lot of conjecture to be made here, but this is all about the administrative state’s power to impose these incredibly costly mandates on all parts of the economy, but particularly in this case, the electric sector, how do you see it?


26:03 – Robert Bryce 

Well, I’m not an attorney. I’m an engineer.


26:06 – Michelle Bloodworth 

But there are attorneys who certainly think that there are many legal flaws in the carbon rule. One of those is certainly in the Chevron doctrine, which is the major questions doctrine. And also where, you know, this rule is really causing fuel switching, obviously in the West Virginia versus EPA, the Supreme Court very loudly said that is not acceptable. You know, most of these rules, unfortunately, unless the EPA provides more flexibility, they’re going to end up in the courts, certainly the ozone transport rule.


26:45 – Michelle Bloodworth 

Which right now affects states. EPA recently added five more. It also, NERC highlighted that single rule, basically saying that the ozone transport rule, the way that it was proposed is a reliability risk. They also highlighted in their recent long-term reliability assessment, the first time I’ve seen, that federal policies are heightening the risk because they’re not flexible. There’s no off-ramps, there’s no tools to make sure that if we need those resources that we can keep them on.


27:19 – Michelle Bloodworth 

As it relates to the ozone transport rule affecting those states, that rule alone would cause the retirement of a third of the coal fleet. That rule right now is in litigation. There have been federal circuit courts, some of those liberal courts, who have granted motions to stay when EPA basically fipped and disapproved their state implementation plans. On February the 21st, industry, we are one of the litigants, one of the parties, the Supreme Court, which is pretty unusual.


27:54 – Michelle Bloodworth 

I think it’s only happened one other time because of the cost and because of the reliability implications, has agreed to consider a motion to stay on the ozone transport rule. So we will be finding out fairly soon. You said you’re an engineer. What kind of engineer are you? So I’m a mechanical engineer, and ironically, my first job out of college, War Eagle, I went to Auburn, was designing a coal-fired power plant for Alabama Power. It was Miller Steam Plant.


28:29 – Robert Bryce 

I know more women are getting into engineering now, and you were an Auburn grad. In your engineering class, in mechanical engineering, how many women were there? Oh, there was probably less than I would say now that number is probably like There are a lot of women who are going into the engineering fields.


28:50 – Michelle Bloodworth 



28:50 – Multiple Speakers 

Well, in the utility sector, I guess in the energy sector as a whole, right? Far more, you know, it’s a bunch of old white dudes, right?


28:56 – Robert Bryce 

You know, generally speaking, but I am seeing more women, particularly young women coming into the industry. But how does that make you, I guess we talk about this a lot. I’ve talked about it a lot in my presentations about policy and that the policy that’s being promulgated that affects the energy and power sectors is being made by lawyers and not by engineers. And i’ve had in my head for a long time an essay about the two cultures right and cp snow wrote about this in about the humanities versus the sciences, but I see it as in the in policy as the the legal bureaucrats against the engineers Is that is it is it simple enough to think about the this policy divide, this view of the grid, this view of the future as one where you have a lot of non-technical people making rules that involve a very technical business, but they don’t know what the hell they’re talking about.


29:52 – Robert Bryce 

I mean, I’m asking you this as an engineer. How do you see it, the culture here? Let’s put aside all these things we’ve talked about.


29:59 – Michelle Bloodworth 

There’s the dollars, there’s this, there’s that.


30:01 – Robert Bryce 

But as a cultural issue, as a trained engineer, as a woman who’s an engineer, how do you see the cultural breakdown here? Should it be part of this broader discussion? No, it absolutely should. And let me give you a good example.


30:16 – Michelle Bloodworth 

So, you know, we found that there’s been little coordination between the EPA and the grid operators. They certainly are electricity experts. Got tons of engineers. I worked for one and that’s what they do every day. And to have the electricity grid operators, because EPA is not an expert on certainly electric reliability. Right. And, you know, we certainly brought up in our comments, so did the grid operators, that there was not proper reliability analysis done. So basically, when EPA looked at resource advocacy, do we have enough capacity based on the impact that this rule is going to have on the retirement of other resources?


31:02 – Michelle Bloodworth 

Their model will never show a shortfall. So it just assumes we’ll have enough transmission, whether that’s nuclear is going to replace it, whatever that, you know, whatever megawatt of coal goes away, then we’re going to assume that it’s going to be replaced. But they never looked at operations reliability. You know, what happens during periods of extreme weather? Are we losing critical reliability attributes, voltage stability, inertia, all those things that are complicated and some people don’t really understand.


31:31 – Michelle Bloodworth 

And so what we in our comments and certainly have told the EPA is that they need to work with these electricity grid operators before they finalize and promulgate their rules. Because the electricity grid operators in their comments on the carbon rule, they brought up five different areas. No proper reliability analysis. We’re losing reliability attributes. Issues with resource adequacy. Technology that has not been commercially demonstrated. We don’t have one coal plant in the United States that can achieve carbon capture, but yet they’re saying that’s widely demonstrated.


32:15 – Michelle Bloodworth 

And also that, you know, they also encouraged, as it relates to technology, they basically in their comments said, hope is not a good strategy. You know, same thing what we’ve been telling FERC is that they also need to be certainly working, even though they’re not the environmental regulator. Obviously, they are responsible for the reliability of the bulk power system. And there’s lots of things that they can do as well. And I certainly, you know, was appreciative of Chairman Phillips holding that conference.


32:48 – Michelle Bloodworth 

I think they need to hold more as it relates to these environmental regulations.


32:54 – Robert Bryce 

But isn’t it so I I agree with it’s interesting how you know that your response because I think you know there’s the cultural difference right but it’s the policymakers dictating policy to the operators right without really understanding what the operators are doing or how things work. I want to talk about inertia, but the broader point, it seems to me, and I talk to a lot of rural cooperatives. I’m happy to travel to rural America. This is part of my job and one that I really enjoy.


33:23 – Robert Bryce 

I’ve been to Kearney, Nebraska. I’ve been to Bismarck. I go to these small municipalities and talk to local people about what’s going on. But it seems to me the broader impact or the bigger danger of of this skein of rules, whether it’s the ozone transport rule or the greenhouse gas rule or what have you, is that it creates uncertainty for the utility sector, right? And that there’s no ability, because these are long-lived assets that are incredibly expensive, that the cooperatives, the generation transmission guys, the local, you know, the public power entities in small towns across Kansas, they don’t know where to put their money because there’s so much uncertainty on the technical and legal side.


34:09 – Robert Bryce 

Is that contributing to the problem or how do you see that uncertainty playing out in terms of the investment side? Yes, certainly the policies coming from this administration are creating tons of financial uncertainty.


34:24 – Michelle Bloodworth 

I agree with you. A lot of our members are public power and co-ops who serve rural America. These assets are long lived. We have members who have coal plants who are years old.


34:34 – Robert Bryce 

They put a lot more money in them, new steam turbines.


34:38 – Michelle Bloodworth 

And it’s very difficult for them because they’re looking at, okay, let’s say I’m going to comply with the ozone transport rule, and I’m going to put in an SCR or scrubber. That’s about 150- SDR, forgive me, what? Collective catalytic reduction. SCR, okay.


34:55 – Multiple Speakers 

SCR. Thank you.


34:57 – Michelle Bloodworth 

And that may require an investment if that plant does not already have SCR of about million. And they may decide, I’m going to go ahead and make that investment. But then they’re over there looking in at the carbon rule, that if it’s not overturned in the courts, which we suspect it will be, then they may decide to go ahead and retire that unit earlier, which is not incorporated into many of the projections by EPA.


35:30 – Robert Bryce 

And it certainly is very difficult for them to make a decision, even if you’re thinking, OK, I’m going to build a new combined cycle plant.


35:37 – Michelle Bloodworth 

But then I’m looking at the carbon rule, and I’m thinking, well, look how expensive hydrogen is. It’s not even commercially viable right now. I don’t have all the infrastructure in place. And so what we are seeing, though, is we’ve seen about states who have rolled back and delayed retirements, about megawatts. A lot of those are in the Midwest because of these warnings by MISO, by the Southwest Power Pool. I think one of the best examples, and certainly I live in Virginia, is when you look at certainly demand center, AI, electricity demand growth.


36:23 – Michelle Bloodworth 

And so you’ve got a grid operator, PJM, who basically sent a letter to Talon, which owns a large coal plant in Maryland. Well, because the state put so much pressure on the closure of that plant. It’s one of the largest coal plants in Maryland and even in PJM. It serves the Baltimore area, growing demand area. And I’m glad you brought this up. It’s called Brandon Shores. Brandon Shores.


36:50 – Robert Bryce 

It’s in Maryland and PJM warned about the closure of this plant because of reliability and specifically grid voltage, if I’m remembering correctly. And we talked about that inertia, but I’m interrupting, but I just wanted to make sure people understand which one we’re talking about.


37:06 – Michelle Bloodworth 

So PJM basically, you know, Talon, when a unit wants to deactivate, when they want to retire their unit, you know, they submit a request to PJM and PJM does analysis. And just like you said, PJM found like reliability violations, a lot of those related to voltage stability, and basically said, you know, Talon, we need you to enter into a reliability must run a contract that would guarantee their return and return on investment, and certainly they’re operating in fixed costs. But Talon has, and they said, we need, you know, we can’t refigure the grid to add additional transmission.


37:47 – Michelle Bloodworth 

It’s probably going to take us until And it’s going to have a price tag of close to a billion dollars. To supplant, to replace that generation power.


38:00 – Multiple Speakers 

It’s owned by Talen Energy, T-A-L-E-N, based out of Houston, I believe is the background on that.


38:06 – Unidentified Speaker 

It is.


38:08 – Robert Bryce 

But Talen was motivated to close it because here’s the key part, right? By litigation that was filed by the Sierra Club, right?


38:15 – Michelle Bloodworth 

This was a deal that Talon cut with the Sierra Club.


38:19 – Multiple Speakers 

I’m a longtime critic of the Sierra Club. I don’t like them. I’m sure they don’t like me back. But this was some deal that they cut because Sierra Club was suing them.


38:26 – Robert Bryce 

So they said, well, we’re going to announce it. But now PJM, the regional transmission operator, is saying, you shouldn’t close that plant. But does PJM have the authority to prevent them from closing? They do not. And so bad reliability, the buck doesn’t stop anywhere. No one owns the reliability chore. No. So, so talent is, well, basically talent is saying, okay, unless this year cub lets me out of this environmental liability.


38:54 – Michelle Bloodworth 

And unless the state is more flexible on my air permit, you know, I want to enter into reliability must run, but no, I’m not going to do it. PJM has asked the Sierra Club basically to negotiate work with Talon and the state to ensure that they don’t have rolling blackouts because they don’t have any power transmission necessary. And what is the Sierra Club saying? Right now, they’re not letting them out of the agreement.


39:22 – Multiple Speakers 

And so it’s unclear what’s going to happen.


39:24 – Michelle Bloodworth 

I mean, I didn’t know about the Sierra Club part of this, but somehow that they have such so much power in this negotiation that they can effectively force this closure of a power plant this large, this important, this critical


39:38 – Robert Bryce 

to reliability. They don’t have to deliver any power. They don’t have to deliver any molecules, right? They can sue them until the cows come home.


39:47 – Michelle Bloodworth 

Now I’m getting a little hot under the collar.


39:52 – Robert Bryce 

I may come over there and join your outfit, but never. And PJM is telling the Sierra Club, please work it out.


39:59 – Multiple Speakers 

We don’t have any other alternatives.


40:03 – Michelle Bloodworth 

And it’s not just, Talon owns another plant called Wagner. They’ve just gotten another letter from PJM. It’s also coal and oil plants telling them that we also need those plants until And it’s the same, it’s the same situation. So, so right now there’s no definitive answer and no PJM, you know, they can, ask somebody, but they can’t force anybody. If they ask nicely, maybe they’ll get their way or say, we’ll give you cookies at the end of the day. A quick station break. My guest is Michelle Bloodworth, and we’re talking about the crisis in reliability, which is not my line.


40:43 – Robert Bryce 

It is what James Danley, former FERC Commissioner James Danley, has testified to. Michelle is the President and CEO of America’s Power, which is a trade association that represents the companies that supply fuel to and operate coal-fired power plants in America. You can find more at americaspower.org. Did I get that commercial right there, Michelle? Is that good enough? So this Brandon Shores was an issue that I think was one when I had down here to talk about, but this seems to me to be one of the most very clearest examples, most lucid examples of what is happening and how there’s no broader consideration at either the regional level or the national level of the importance of thermal generation in the power fleet in America.


41:35 – Robert Bryce 

Besides the Sierra Club, who do you identify as the entities that are pushing this agenda? If you’re going to tell me who the key obstacles or the key foes are that are facing the reliability of the problems, from where are they coming besides examples like this with the Sierra Club? Well, certainly it’s no secret that the NGOs are certainly very supportive.


41:59 – Michelle Bloodworth 

You’ve certainly seen Gina McCarthy, who worked for the NRDC, who’s very supportive of these overly aggressive decarbonization goals to basically eliminate, in my opinion, all fossil fuels. When you talked about, obviously, the American Clean Power Association, Certainly the NRDC and the Sierra Club’s revenues are over million. Doesn’t mean all those monies are going to obviously oppose and attack coal plants. But certainly some of it is. You’ve got the Sierra Club’s Beyond Coal campaign, certainly which was not putting, in my opinion, reliability first.


42:39 – Michelle Bloodworth 

And again, I’m not opposed to wind and solar. We need them all, given that we’re trying to electrify and grow this economy. Now you’ve got Michael Bloomberg, you know, and his million campaign beyond carbon, which is also focused on natural gas. Certainly, it’s not my prerogative to tell Michael Bloomberg, you know, whether or not he can, where he can spend his million. But when you look at the Inflation Reduction Act, which certainly has a tremendous amount of incentives for wind and solar, putting wind and solar on steroids before these electricity grids can really handle that amount.


43:17 – Michelle Bloodworth 

That billion, that’s being paid by the taxpayers. In my opinion, there needs to be a lot more education and people who support a genuine all of the above energy strategy. Which states if just give me the scenario here I was I mentioned I was in bismarck north dakota a couple weeks ago uh glad to be there was I apparently missed the really cold weather but uh it was cold


43:45 – Robert Bryce 

enough when I was there um of the electricity in uh north dakota is generated from coal most most of that is lignite which states are the most reliant on coal if give me the scenario how this plays out if The carbon rule from the EPA goes forward, the Beyond Carbon campaign that they get their way, and Michael Bloomberg has said he wants to shut every coal plant in America down.


44:12 – Michelle Bloodworth 

The burden here is not evenly distributed geographically.


44:17 – Robert Bryce 

Which states are going to be hurt the most if this war on coal is successful?


44:22 – Michelle Bloodworth 

So certainly, West Virginia, Kentucky, North Dakota, Wisconsin, Missouri, Utah, Wyoming, there’s over states who receive more than of their electricity generation comes from coal, but states use some type of electricity generated from coal, but there are about- Oh, I’m sorry, states get or more of their power from coal? Yes.


44:55 – Robert Bryce 

And I think, so certainly some states will be hit more.


44:59 – Michelle Bloodworth 

Obviously, you’ve seen a lot of attorney generals.


45:02 – Robert Bryce 

That’s why, as it relates to those on transport rule, the carbon rule are getting involved in litigation.


45:09 – Michelle Bloodworth 

It’s going to drive up electricity prices. It certainly will affect economic development within their states. For those states that certainly rely heavily upon coal. We are seeing, though, some states back to, you know, solutions. Kentucky passed some legislation called SB4 that would require before any coal plant could be retired, that proper reliability analysis needs to be done. Replacement capacity needs to be still in the ground. We are seeing, though, although these wholesale markets are very complex, We are seeing wholesale electricity grid operators bring forward market reforms.


45:50 – Michelle Bloodworth 

To me, that would send signals to delay the retirement of coal. Some of it is to send signals to build new thermal generation, but those same price signals, because the analysis that both PJM and MISO have done that house the largest majority of the coal fleet are both showing capacity shortfalls. MISO next year, PJM’s recent analysis has showed And so to me, it’s going to take a combination of federal legislation. We certainly are supporting Senator Barrasso’s got a spur at permitting reform that has two components of it that would require that EPA does proper reliability analysis before they can promulgate these rules.


46:40 – Michelle Bloodworth 

They work with the electricity grid operators. Another component would require that FERC to make sure that within a year, these different reliability attributes that we’re losing at a pretty fast pace are properly valued, which certainly will send better price signals for those generators to be able to make the necessary investments. And then certainly we think that the EPA should withdraw and start over as it relates to the greenhouse gas rule, or we’re certainly going to be putting ourselves straight into a reliability crisis, stifling investment.


47:20 – Michelle Bloodworth 

A lot of people aren’t going to want to make investment in their coal, natural gas plants, obviously with the uncertainty of that rule. I was impressed.


47:31 – Robert Bryce 

I think it was PJM, MISO, ERCOT, and SPP all sending joint comments, a joint letter to the EPA saying, you need to start over again. I’m paraphrasing here, but that’s the way I read it. National Rural Electric Cooperative Association filed very strong comments as well. But it’s not only, so you mentioned the greenhouse gas rule, the carbon rule, you mentioned the ozone transport rule, but there are other issues. And so if I was going to look, here’s my view, and I’m, you know, put my cards on the table.


48:06 – Robert Bryce 

I’ve never been ashamed or bashful about expressing my opinion. I think we need to keep all of our coal plants open in America, right? Until we can clearly show that we don’t, you know, that the reliability problem is going away, keep all of them open, right? So first quick question, say we have, I doubt Joe Biden if he’s reelected would do this, but maybe it’s possible, but the new president, whoever it is in early could they issue an executive rule, an executive order saying we are facing a reliability crisis, all coal plants in America must stay open until I decide otherwise, or until we show some other reason that they can be closed.


48:41 – Robert Bryce 

Could the president act unilaterally in that case? I mean, there’d be litigation, of course, but could could have, you know, whether Trump is in jail or not, I mean, we don’t know who, a Republican, it would be likely be a Republican that would be so inclined to do this. Could that happen? Would it, I mean, would it make a difference? Yes, I think it certainly would make a difference, certainly whether that’s an executive order or changes to the Federal Power Act.


49:07 – Michelle Bloodworth 

There are a lot of things that a new administration could do in order to deem coal plants as critical infrastructure, certainly thermal generation. There’s a lot of things that they could require FERC to do. It’s also responsible for a facet of the reliability of the bulk power system. Certainly as it relates to a lot of incentives and a lot of these subsidies, which totally distort the wholesale electricity markets.


49:31 – Multiple Speakers 

There are a lot of things that a new administration and certainly a new Congress could do.


49:37 – Michelle Bloodworth 

I just hope that everybody has a sense of urgency because we don’t have a lot of time as owners of these plants are making decisions about the retirement. You know, when I think about, you know, certainly all these, you know, winter events, you know, whether it was the polar vortex, we like to name them, the bomb cyclone, you know, look at winter storm Elliott, you know, coal provided of the incremental electricity demand in PJM, in MISO, in SPP. When you look at the storm on January the 17th, You know, certainly when the weather was the coldest and peaked, fossil fuels provided of the generation.


50:21 – Michelle Bloodworth 

You know, at a.m. And a.m., solar contributed virtually none. Yes, it was windier, but I certainly don’t want to depend on my lights continuing to be kept on, having to pray that we have a windier winter if we don’t have these fossil fuels. I’ve laid my cards on the table. I think we should keep all of our coal plants open. I think that right now, especially given what’s happening globally, let me ask the question about China first.


50:52 – Robert Bryce 

So step back, and I know you’re paid to advocate for coal. I get that, right? Let’s be clear. But does it make any sense for the U.S. To be trying to outlaw or these entities in the U.S. Effectively declaring war on coal when China permitted two new coal plants per week last year in Well, I guess it would be that coal that China, India, Indonesia in particular, are building massive amounts of new coal fired power. I mean, is this just some kind of hubris in the U.S.? Is this a political play, a power play?


51:25 – Robert Bryce 

I mean, does it in the broad sense, if you step back, and I know I’m not asking you to be objective, you can’t, but how does this, how meaningful is this in the global sense, the actions, the efforts that are being, the waging of the war on coal in America, how effective is it going to be ultimately in the global scheme of things?


51:46 – Multiple Speakers 

I mean, certainly you only have to look to Europe to see what happens when you lose energy independence.


51:52 – Michelle Bloodworth 

This country has certainly a massive amount of coal and natural gas reserves. When you lose energy security, But I continue to tell my friends and other NGOs that, you know, in this administration, you could retire every coal plant in the United States. It is not going to make a dent in greenhouse gas emissions. China’s coal fleet is million megawatts. That’s almost the size of the entire electricity supply. Right. In the entire installed generation capacity in the US is about terawatts.


52:30 – Multiple Speakers 

And China has about terawatts of installed coal capacity by itself, right? I think that’s a really important comparison.


52:39 – Robert Bryce 

And China is adding, currently adding megawatts. That’s twice the size of the existing US only.


52:49 – Michelle Bloodworth 

But they have determined if they want affordable And certainly they have a lot of poverty within their state. And if they want to be an economic driver, that’s why they have said, we’re going to continue to build coal, natural gas, nuclear. But they’re building about six times more coal-fired capacity than they are nuclear.


53:07 – Robert Bryce 

So let me ask one, and this isn’t a devil’s advocate question, but as if I look at the coal sector and I look at it as objectively as I can, and I’ve been in coal mines, underground mines, above, you know, open cast mines, the ash issue is a problem. I mean, as I look at it, right, and you’ve had the ash ponds that have burst, we know, and devastated rivers, I think in Tennessee, I think it is. What are the regulations facing coal ash, or they call them coal residuals? I forgot what the term of art is.


53:42 – Robert Bryce 

You said there were six rules. That one to me seems the one that is from a physical standpoint, is a difficult one to manage. What are the federal regulations facing coal ash right now? And how does the industry do better on that part of it? Because that, to me, from a physics standpoint, from just a physical world standpoint, is a real problem, or a real challenge, rather. Right. So the two coal ash rules are the affluent limitation guidelines, which I would call liquid ash.


54:15 – Michelle Bloodworth 

And then there is also coal combustion residuals, which is more dry ash and residuals. But even during the Trump administration, those rules were certainly revamped and they were also made more stringent, but certainly more flexible. So coal plant owners right now, there are who want to comply with the coal combustion residual rule. And they’ve certainly invested a lot of money to convert these unlined surface impoundments to lined surface impoundments. And so the problem with the changes and the implementation of that rule with this administration is there are coal plants who have basically asked EPA for more time, you know, in order for us to find alternative waste sites.


55:05 – Michelle Bloodworth 

Because again, we still need the power to keep the lights on. And the EPA has been slow to respond back. They denied three of the coal plant owners because it could basically force those plants to either idle within a short amount of time or basically retire. And that’s why PJM is also working with the EPA to basically say, you know, hey, we’ve got to do these over several years. Because we can’t just take plants off in a peak summer period when we still obviously need the power from those units.


55:44 – Michelle Bloodworth 

There are a lot of coal plant owners. I don’t know if you’ve talked to many cement manufacturers who are also being impacted by the retirement because they use a lot of coal ash. There’s a lot of different products for coal ash that utilities are looking at coal ash more as a commodity. We have a lot of members who certainly are like everybody else, want to be environmentally responsible, but they’ve spent a lot of money on coal ash to basically ensure not only that they’re complying with the regulations, but they don’t have any other environmental harm.


56:21 – Michelle Bloodworth 

Right. So it’s the two coal ash rules, the ozone transport rule, the carbon rule. You said there were six of them. Is that four of the six?


56:31 – Robert Bryce 

Yeah, there’s also the MATS rule. So EPA has recently finalized a more stringent mercury and air toxics rule.


56:39 – Michelle Bloodworth 

And then there’s also a regional HAYS rule, which deals with national parks. And EPA has been slow in implementing that rule, but we certainly expect all six of them to be finalized before probably June of this year. And that is a way then that the Biden administration can get those rules in place and prevent whatever next administration might be, if it was a Republican or conservative administration, from going back and changing them?


57:11 – Robert Bryce 

Is that what you were saying before? Yes. So Congress would not be able to use the Congressional Review Act, which would allow them to make changes or basically revise or withdraw those rules.


57:27 – Michelle Bloodworth 

I see. Okay. And that’s six months. So it would have to be June. It couldn’t be August because that would be within six months of the new Congress coming into power then.


57:37 – Robert Bryce 

All right. Okay. Got it. So we’ve been talking for about an hour, Michelle, and you know, if you’ve listened to the podcast, I always, I ask guests to introduce themselves.


57:48 – Michelle Bloodworth 

And at the end, I ask what they’re reading and what gives them hope.


57:51 – Robert Bryce 

So I know you’re busy. You have an enormous amount of challenge, an enormous number of challenges from your professional job. But when you’re reading, when you have time to do reading, what, what are you, what’s on your top of your book list? Top of my book list? Oh, you’re going to laugh. Like Cindy Sheldon.


58:11 – Michelle Bloodworth 

I read so many engineering and technical things, sometimes it’s just nice to read something that’s positive and happy and has a happy ending. And I’m sorry, is Sydney Sheldon? I don’t know what that is. Forgive me. Oh, I’m sorry. It’s just a woman writer. Writes a lot of romances and stories.


58:34 – Robert Bryce 

No judgment. I’m pro-reading.


58:35 – Michelle Bloodworth 

I write books. I’m happy when people read. I’m not going to make fun of what you’re doing. I read a lot.


58:43 – Multiple Speakers 

I read technical stuff, but when I want to relax, I want to relax.


58:48 – Robert Bryce 

So final question, Michelle, what gives you hope? I think what gives me hope, certainly as I’ve represented the coal industry or the coal fleet for about six years, is, you know, it’s finally that it’s not just America’s power expressing concern.


59:08 – Michelle Bloodworth 

You know, I would say three, four years ago, electricity grid operators were not concerned. You know, you didn’t really hear them talking about coal retirements or their concern. And now we have electricity experts, whether that’s FERC, whether that’s Jim Robb, whether that’s reliability organizations, state utility commissioners who have been testifying, you know, in these oversight hearings, who have really expressed their concern and the need to ensure that we maintain these dispatchable resources.


59:37 – Michelle Bloodworth 

And we’ve never seen electricity demand growth like we’re seeing it now. And I think people are beginning to realize It’s just some of the solutions are very hard and difficult, and we’ve got to work with a sense of urgency, but we are seeing some of those reforms, state legislation and others, being moved forward. We just also needed administration that appreciates the need to put reliability first. Well, that’s a good place to stop. My guest has been Michelle Bloodworth.


1:00:10 – Michelle Bloodworth 

She’s the president and CEO of America’s Power. You can find out more about her at americaspower.org.


1:00:16 – Robert Bryce 

Michelle, it took us a while to get you on the show, but we finally made it happen. And I’m glad we did. I, like you, I’m concerned about reliability and the reliability, affordability, resilience are all issues that are front and center for me. So I wish you luck in your job. You have plenty of things on your plate. Well, you’ve made a huge difference, and I can’t thank you enough. I know you have a huge following.


1:00:40 – Michelle Bloodworth 

I read your information every day, and I listen to your podcast, and we just need more people like you, so thank you for what you do. Well, my kids think one of me is enough, so I will leave it there, but thank you. That’s very kind. And thanks to all of you out there in podcast land for tuning into this episode of the Power Hungry podcast.


1:00:58 – Robert Bryce 

If you have a time and are so inclined, give us a positive review, stars, whatever you can do on your local podcast rating thing. And until next time, see ya. 



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