Saturday, November 29, 2014

Update! Send Your Comment to the EPA! Here's Mine.

UPDATE:  Today, December 1, you can still comment on the  EPA rule which gives nuclear power credit for only 6% of the carbon that a nuclear plant mitigates.  

Here's my blog post on the rule: Support Nuclear This Weekend

But more important, here's the link to the American Nuclear Society page about the rule. This page includes explanations and a link to the EPA comment page.
Here's a direct link to the EPA instead, if you prefer

Below is the comment I sent in.  It's not a perfect comment, but I will say that it meets some of the criteria for a good comment: it includes my name and address, and it is unique to my situation.  Looking at it today, however, it seems a bit wordy.

Write your own comment!  Make it briefer than mine!

My name is Meredith Joan Angwin. I live in Wilder Vermont. I blog at Yes Vermont Yankee and I am a member the American Nuclear Society.

I want to say that the way the carbon pollution regulations are written now, when Vermont Yankee closes, IF it were to be replaced with gas from Canada supplying a natural-gas fired unit....the rules would say that the carbon dioxide emissions from Vermont would go DOWN, when the actual emissions would go UP.

Now, I am well aware the Vermont doesn't fall under these rules, because we basically only have Vermont Yankee, some hydro and some biomass in-state. So we didn't have to come up with a mitigation plan. However, these rules are backwards. You give nuclear (either existing or being built) credit for about 6% of its emissions reductions. However, any plant (coal or nuclear) that is replaced with a natural gas plant is part of the state's mitigation strategy.

Replacing coal with gas lowers the state's greenhouse gas emissions, replacing nuclear with gas raises the emissions, but it's all the same to the rules as they are formulated now.

I know that people love natural gas plants. "Clean natural gas, lower carbon than coal." But I am on the Coordinating Committee for the ISO-NE (grid operator) Consumer Liaison group, supposed to be the "voice of the consumer" advising the grid operator. I want you to know that consumers suffer when the grid does not have a diversity of supply. In the Northeast, massive price rises of electricity (25%, 40%) are happening this winter, because there's a winter supply crunch on natural gas.

The grid needs diversity so that the lights will stay on even if one type of fuel is unavailable. Yet your current rules would force the grid into renewables-with-natural-gas-backup. Even with different types of renewables, that is NOT diversity. Are you aware that the capacity value for wind in the Northeast is only about 13%? (I've heard lower values at seminars, but I'm going with a EIA report here. The capacity factor for wind in the Northeast is about 25%--that is, the wind blows enough to turn the turbines about 25% of the time. But the grid operators must look at whether the wind will be available when it is needed. That's the capacity value.

Basically, if you don't give nuclear more credit, the grid will inevitably go to renewables for reducing greenhouse gas emissions (but they will have with low capacity values). Then natural gas, with greenhouse gas emissions, will make the inevitable difference. In other words, there will be a nationwide grid that, like the Northeast, is overly dependent on natural gas, with all the price and supply problems that entails.

Originally, I worked in renewables. I was a project manager at the Electric Power Research Institute and I wanted renewables to do it all. Then, painfully, I realized they couldn't. Since I had already worked on the extremely difficult problem of lowering NOx emissions from fossil fuels, I gradually came to realize the virtues of nuclear power. Now I am devoted to it as a substitute for coal. Nuclear power PLUS renewables PLUS some natural gas will help with climate change. But if you don't give nuclear more credit in your calculations, the entire U S grid will be in the same shape as the Northeast grid. Overdependent on natural gas.

And that's not good. Give nuclear plants 100% of the credit for the greenhouse emissions they avoid. It's only fair, after all. I don't know how you got this 6% solution for nuclear, but its wrong. Luckily, there is still time to fix the problem!

Meredith Angwin


Carl said...

Nuclear generated electricity - Unfairly treated

We have evaluated the Clean Power Plan Proposed RULE. We find an unjustifiable and technologically unbalanced treatment of carbon-free electricity sources.

We object.

Respectfully submitted:
Carl Holder, Chair
Eastern Washington Section-American Nuclear Society

Meredith Angwin said...

Comment from Dr. Robert Hargraves, as sent to EPA

A clean power plan is an admirable goal. Your proposed rule is too complex and subject to too much political negotiation. You should not “adjust” CO2 emission by arbitrary factors like credit for only 5.8% of the carbon dioxide avoided by the presence of the nuclear plants. You abandon science and substitute political science. Regulate only physically measurable quantities. Treat all nonCO2-emitting power sources alike.

Nuclear power is a safe, clean, source of electric power. Your proposed rule betrays the power of elitist political goals over the good of the people.

Robert Hargraves
AB Dartmouth College mathematics and physics
PhD Brown University physics
Author THORIUM: energy cheaper than coal

Hanover, NH

Timothy Wyant said...

My name is Timothy Wyant. I am a MAJ in the United States Army, currently stationed at West Point, NY as an instructor in the United States Military Academy Department of Physics, and a member of the American Nuclear Society.

I am commenting on the Clean Power Plan (CPP) because of the failure of the CPP to 1) treat nuclear energy as the important CO2 mitigating energy source that it is and 2) the CPP rules place an "accounting" of CO2 emissions before an "actual" decrease in CO2. Currently, nuclear energy produces over 60% of the CO2 free electricity in the United States. As such, it is imperative that the US not only work diligently to preserve the nuclear capacity that it already has, but do everything it can to encourage states to build out nuclear capacity to provide emissions free power well into the future. In counting only 5.8% of the power output of existing and under construction nuclear, the CPP does little to encourage existing nuclear to be retained and little to create value for nuclear to be developed in the future. The most glaring example of how little the CPP values nuclear is to look at what happens when a nuclear plant is shut down and its output replaced with natural gas. In this scenario, a number of states will find that according to the EPA rules, their CO2 emissions rate will decrease! This scenario shows that the method of “accounting” for CO2 release under the CPP is fundamentally flawed and does not reflect reality. The climate does not care what the emissions rate of Georgia or North Dakota is, the only thing that matters is the level of CO2 in the air that will trap solar energy and warm the planet.

It is imperative that the CPP be changed in the following ways:
1) Count 100% of existing nuclear power in formulating the EPA rules.
2) Count 100% of the power to be produced by reactors(using average capacity factors for the relevant technologies) currently under construction in Georgia, South Carolina, Tennessee, and elsewhere where reactors will be built before the CPP takes effect.
3) Recalculate the current emissions rates and the goals of all states to better reflect the “actual” CO2 emissions of each state.
4) Write the rules in such a way that all zero emitting sources are counted equal. Let the market and the states decide which technologies work best for them. Nuclear, Solar, and wind all have their value and their appropriate applications. Let the market choose winners and losers, not the EPA

Mary Gerdt said...

Thanks Meredith, for your guidance. All my years in bureaucracy, I could not grasp the EPA 17 page spreadsheet how to comment...So I read yours, then winged it. Have a great week! Mary My Comment:Comment:
My name is Mary E. Gerdt. I am a 56 year old disabled RN now on a fixed income. I and my family consume power in Monkton,Vermont. I write as a consumer concerned about power costs, availability, and political manipulation of Vermont's fragile power grid. I have watched powerlessly while the Government has allowed Canadian Gaz Metro to buy Vermont utilities like Vermont Gas and Green Mountain Power. The current administration has effectively closed VT Yankee by hook or crook. This disappoints me. I studied nuclear energy in college and it's safety can be superior to the so called "natural" (or fracked) gas. Then Canadians have threatened my US neighbors with land condemnation to run a pipeline Through Monkton, Vermont. Lake Champlain is undoubtedly as precious as the Connecticut River. Lake Champlain is likewise planned to house cables, pipelines UNDER the lake to transport power. Nowhere is the end game revealed. No where can common people like me find out Gaz Metro's history of rate hikes. I don't even understand the monopoly power of the power corporations remaining. For the record, I believe VT Yankee should have remained open or modify, upgrade. Stand down the expensive attorney threats that raise all of our energy costs. I believe the Pipeline from Alberta, CA to Ticonderoga, NY should be scrapped. This gaz could be transported by rail. Our local environment would suffer with a pipeline. The plan to extend the pipeline to Addison County is putting local seniors and vulnerable citizens at risk. Yes, this all ties together. What happens when a pipeline is put where a politician says, not planning around safety? Freezing, thawing, rocks, erosion, 5 feet of ice on the Lake. New York State refused. So we are all being threatened with being "NIMBY", as we live in the idyllic countryside. I feel like the closing of Yankee, and Gaz Metro's acquisitions of power control dovetail to crimp Vermonters into wanting a pipeline. Pipelines have been shown to increase methane with those pesky leaks. Some of the gas will be from fracking which has been outlawed here. Once again, private citizens having to lawyer up singly while the government entities act and wait for backlash, then ignore. I believe we need to rethink pipelines. Please do not plan on replacing coal generation with "natural" gas generation or use gas lines to transport electricity as I have read about. Keep the power lines out of Lake Champlain. Pardon any procedural lacking on my part. I am a citizen. My GMP power bill is $160 a month. Doubled past 10 years with less use. If a pipeline comes to Monkton, Vermont, less than a mile from my house, I could not get gas but would have to pay municipal taxes for fire and rescue departments that would have to respond to leaks as first responders. I feel as a citizen, that it appears political people may have taken donations for elections or other considerations with expectations about closing nuclear or facilitating Canadians to condemn beautiful homesteads in Rural Vermont: clearly not the most direct route from Alberta, CA to Ticonderoga, NY. Not scientific argument, just common sense logic. Thank you for your consideration of my comments.

Eric Schmitz said...

I managed to get a comment in under the wire. Being a "lay nukie", I probably don't have an entirely accurate understanding of the matter, but for what it's worth, here's what I left as a comment:

As an engineer (BSEE, University of Kansas, 1988), I generally support the proposed new EPA regulations on carbon pollution for electrical power generation, with the exception of the rules concerning the contribution of nuclear-powered generation. In particular, the accounting of nuclear power in the calculations of CO2 output, as proposed, makes no sense to me, from a scientific, engineering, or mathematical standpoint.

The contribution of existing nuclear-powered electricity to our supply should be treated equally, by including 100% of its output in baseline CO2 generation calculations -- no more, no less.

States in which new nuclear plants are being constructed should not have those plants included in existing production calculations, but rather those plants should be included in calculations of CO2 reduction targets. Those calculations should include 100% of that new production -- no more, no less.

A production facility that generates electrical power with a low carbon footprint by using nuclear power should be treated the same as a facility that does the same via solar, wind, hydro, efficiency programs, or any other means.

Low-carbon is low-carbon. The objective of the EPA carbon-reduction rules should not be to favor one technology over another for any other reason than their comparative abilities to accomplish the specific goal of reducing such emissions.

-Eric Schmitz
Bloomington, Indiana

trag said...

I hope I called things by the correct names. Here's what I sent via email to with the alphabet soup in the subject line:

The rule should be amended to credit at least 100% of nuclear electricity generation to states as clean energy CO2 free). The rule should also be amended to credit generation by renewables" (wind, solar, biofuels) with far less than 100% of the electricity generated.

As currently written, the proposed rules only credits states with 5.8% of the clean energy actually generated by existing nuclear electricity generators. This rule creates a perverse incentive to close down clean nuclear power plants and replace them with CO2 emitting natural gas power plants. This is a terrible result.

In the real world, comparisons of relative carbon emission intensities between Germany, Denmark, France, Ontario, and South Carolina show that entities which get a large percentage of their electricity from nuclear generation (France ~80g/KWHr, Ontario ~120 g/KWHr, South Carolina ~150 g/KWhr) have much lower carbon emission intensities (grams CO2 per KWHr generated) than entities which try to rely on so-called renewables such as wind, solar and biofuels, Germany 450+ g/KWHr, Denmark ~450 g/KWHr.

If anything, this rule should either credit nuclear generation of electricity at greater than 100% or it should credit "renewables" at far less than 100%. Multiple studies have demonstrated that "renewables" do not reduce carbon emissions in any substantial way, because of the requirement for fossil fueled backup at constant readiness, for when "renewable" generation falters.

This fossil fueled backup of renewables" means that fossil fuels will beburned, as a necessary expedient to make "renewables" sufficiently reliable, but will not generate any countable electricity, much of the time. How do you propose to count the emissions from fossil fuels burned to keep boilers warm, while not generating any electricity, becasue the boilers must be kept in constant readiness to jump in when "renewables" falter?

Thank you for your time and attention,

Jeff Walther
Electrical Engineer
Aerospace Engineer
Attorney at Law (State of Texas)

Tom Clegg said...

Here is an article that describes what our energy future looks like. Welcome to the making of a third world country!