Provisional Withdrawal of Previous Support for EPA Clean Power Plan

Provisional Withdrawal of Previous Support for EPA Clean Power Plan

Denver 30 November 2014

Posted by Ed Leaver 1 December 2014

In the months since the public in-person opportunity to comment at EPA’s Clean Power Plan hearings this past July, it has become apparent that, as it is currently written, the Clean Power Plan will fulfill the expectations neither of EPA Administrators past or present, nor of environmentally concerned scientists, engineers, economists,and commentators who have realistically analyzed the nature of the climate catastrophe now upon us, and the enormity of the tasks involved in its mitigation.

My purpose here is to explain why I feel compelled to equivocate my previously unequivocable support, and to suggest ways in which EPA’s Clean Power Plan might be improved such as to further its original intent and aspirations.

My original support for EPA’s Clean Power Plan Rule was predicated in part upon statements EPA Administrator Gina McCarthy made in EPA: Carbon rules could ensure nuclear power’s survival, where she warned that if nuclear capacity goes away, “it’s a lot of carbon reduction that needs to be made up for a long period of time.”

Since my previous testimony in July, it has come to light that 94.2% of the carbon emissions avoided by nuclear power plants is discounted in the Clean Power Plan Rule, as it is currently worded. This effectively means that some states with high existing nuclear penetration, for instance Illinois, may meet their Clean Power Plan obligations by closing economically marginal nuclear plants and replacing them with natural gas. In other words, satisfy their emissions reduction obligation by substantially increasing their emissions.

In their Renewable Energy Futures 2012 study (Table C-3) the National Renewable Energy Laboratory estimated the emission density in tCO2e/GWh of various generation sources:

Other sources place hydro around 26 tCO2e/GWh. Emissions from all so-called “green” technologies (save Biomass, which arguably isn’t green at all) are front-loaded: the greenhouse gasses are emitted primarily during construction, for instance in concrete and steel. Once constructed, it makes no sense from an emissions perspective to close any of them before the end of their natural life. Carefully maintained (for which there is cost), most nuclear plants can safely operate for 60 to 80 years. The emissions associated with uranium mining and fuel fabrication are quite low.

For a real-world example where a license-extension upgrade to an existing nuclear plant could become uncompetitive with new gas generation under the proposed Clean Power Plan, see Xcel Monticello defends expensive nuclear upgrade.

Climate change, and the CO2 emissions that drive it, are a global problem. The global atmosphere is currently about 400 ppmv CO2, and rapidly heading north. Mankind will be lucky if we can halt the rise before 550 ppm. Meantime, climate scientists estimate 350 ppm to be the safe sustainable upper limit. Beyond that – and we are already well beyond that – climatic tipping points become inevitable. One ppm CO2 is about 2.13 Gt atmospheric carbon. 50 ppm is 106 Gt, 200 ppm, 425 Gt – a 4 followed by eleven zeros. That’s a lot of toothpaste to put back in the tube.

We aren’t going to put that toothpaste back in the tube by squeezing more out. Natural gas, and whatever intermittent power generation that depends upon gas for reliability, may at best be viewed as bridge technologies that must go away within the next fifty or so years. Locking the nation’s electric power infrastructure into such relatively high emission technologies when the goal must be zero emissions is shortsighted, counterproductive, and while an improvement over coal, will not save the planet.

Nuclear power might. Perhaps not by itself, but in conjunction with wind, solar, and storage, nuclear will (and must) play a large role, particularly in meeting baseload. Nuclear is an inherently reliable, low carbon power source. But nuclear deployment has a long lead time. If we are to plan for large nuclear deployments, we must plan well in advance. Long-term market signals must be established that encourage that deployment. As currently worded, EPA’s Clean Power Plan Rule establishes the opposite signal.

Therefore, I must withdraw my support until the Clean Power Plan Rule is amended to give full credit for emissions avoided by nuclear generation. Otherwise, the proposed Rule effectively puts the very-low emissions nuclear industry in the position of subsidising high-emission natural gas. I hope that was not its intent.


  1. Unintended Anti-Nuclear Consequences Lurking in the EPA Clean Power Plan
  2. The Details of the Clean Power Plan (So You Want to See the Numbers)

Edward W. Leaver
1 December 2014

Addenda: Additional Notes not part of EPA Public Comment