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. http://www.eia.gov/todayinenergy/detail.cfm?id=1370.) 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!