Support Nuclear This Weekend. Email the EPA by Sunday!

Analysis of Ohio Carbon Dioxide Emissions
From American Nuclear Society (ANS) Webinar
November 26, 2013

The EPA and the Carbon Rules: It Situation Is Worse Than I Thought
But You Can Do Something About It

The Situation Is Worse Than I Thought

Several months ago, the Environmental Protection Agency issued its rules for cutting down carbon emissions from the utility sector.  The rules were complex and differed wildly, state by state.  States that used a lot of coal were required to cut back their carbon emissions by relatively small amounts.  I blogged about this backwards rule-making in my post: Exporting Our Carbon Problems: The EPA Takes a Flawed, State-by-State Approach to Greenhouse Gas Policy.

But.

The situation is much worse than I thought.  Through some convoluted process, the EPA gives states with nuclear power plants credit for only 5.8% of the carbon dioxide avoided by the presence of the nuclear plants. This is true for existing nuclear plants, nuclear plants under construction, etc.  If you substitute gas-fired for coal, you get 100% credit for the avoided carbon.  If you substitute nuclear for coal, you get credit for 5.8% of the avoided carbon!  As a matter of fact, if  you substitute a gas-powered plant for a nuclear plant, your state emissions look better according to the EPA.

Ohio: The Example of the EPA Calculation

Let's look at the example above, from today's American Nuclear Society Webinar.  If we actually calculate the Ohio electricity sector carbon intensity, it is  1201 lbs CO2 per MWh. (That's the column called "100% nuclear"....that is, 100% credit for nuclear.)  If we use the EPA rule of 5.8% credit for nuclear, the carbon intensity is 1338 lbs CO2 per MWh.

Okay, now look at the last column. If Ohio's nuclear plants were closed and new gas-turbine plants erected instead, then (by EPA rules) Ohio's carbon intensity would be 1306 lbs CO2 per MWh. The new gas turbines would yield an improvement compared to the EPA's earlier calculation of 1338 lbs.  

Of course, the actual carbon intensity, without the weird EPA calculations, would go up from 1201 lbs/MWh to 1306 lbs/MWh if the nuclear plants went away.

But we're talking about a regulatory agency here, folks. The question is: Is the EPA going to keep this crazy anti-nuclear rule?

You can do something about this!  Do it!

 The comment period on this rule closes on Monday.  It is open this weekend, and many anti-nuclear groups are really hitting hard at the comments.  However, you can comment also.  You SHOULD comment also.

The American Nuclear Society has an excellent page about this rule.  Here's the link to the page, and the page includes a link to the comment page.
http://www.ans.org/epa/

Here's a direct link to the EPA instead, if you prefer

http://www2.epa.gov/carbon-pollution-standards/how-comment-clean-power-plan-proposed-rule

As the ANS page explains, comments can be very simple. The two points are just what you would expect. Encourage the EPA to:

1) Treat existing plants equally by including 100% of nuclear current output in the baseline CO2 calculation.
2) Allow states with new plants under construction to count the new clean energy generation toward their EPA emissions target.

A Note About Your Note 

The EPA will read the emails, but they pay far less attention to cookie cutter or anonymous comments.
Put your name on your comment, and make it as personal as you can.  Say why YOU think nuclear generation has to be given more credit.  Do you think it is because we need a level playing field, because your grandfather was a coal miner, because nuclear is the future, because nuclear is a very important clean air option?  Just a sentence or two, so it is not cookie-cutter.

Do it this weekend.

EPA is about to bust the best source of clean air electricity in this country.  This is more important than the doorbusters at your local mall.

Write the EPA this weekend!

Have a great happy Thanksgiving...and write the EPA!

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For those who want more information. Some blog posts:

Environmental Protection Agency's Clean Power Plan, by Nicholas Thompson at Nuclear Undone blog.  Includes quotes from NRDC (an organization opposed to nuclear energy) on how this organization shaped the new rule, working with the EPA. According to the NRDC, there was a danger (oh the horror!) that if nuclear were included, states with nuclear plants wouldn't be able to meet their targets if the nuclear plants were closed. Giving nuclear plants only 5.8% credit for their emissions reductions helped the NRDC achieve its goals.

The Details of the Clean Power Plan: So You Want to See the Numbers by Nicholas Thompson at ANS Nuclear Cafe blog.  The numbers.  A far more complete story than my explanation of Ohio emissions, but basically, the same story.

(Yes, I have already submitted a comment.  Maybe I will put it up here as a blog post later this weekend.)