Anti-Nuclear Bias in EPA Rule Could Allow Higher Emissions in Some States by Michael Shellenberger

States that close existing nuclear power plants could be allowed to increase carbon dioxide emissions under a final EPA rule regulating carbon dioxide under the Clean Air Act.

The Breakthrough: Anti-Nuclear Bias in New Climate EPA Rule Could Allow Carbon Emissions to Rise in Some States

For this and other reasons, the EPA acknowledged that its rule would likely not alter existing rates of deployment or decommissioning for either nuclear or renewables — all “will remain generally consistent with what their trends would be in the absence of this rule,” the EPA wrote (page 637).

Moreover, the EPA said, even with the new regulations, the coal-to-natural gas transition will be slower from 2015 to 2030 than it was from 2005 to 2014.

States get to choose from two ways of measuring their goal according to rate of emissions reductions and amount of emissions reductions.

While EPA declined to provide an incentive to keep nuclear power plants online, it said it would subsidize wind, solar, and energy efficiency as part of its Clean Energy Incentive Program.

The main source of bias is how the EPA sets its baseline against which states’ compliance will be measured. By not recognizing existing sources of zero-carbon power, the EPA rule is biased against nuclear, the largest source by far (two-thirds) of zero-carbon electricity generation.

The negative effect this way of measuring progress would have on nuclear was identified by a team of graduate students working under Professor Steve Stuknick at the University of Tennessee.

Last year, the New York Times reported that Natural Resources Defense Council, a  anti-nuclear environmental organization that raised over $100 million in 2013, wrote the blueprint for the EPA's rule. 

The EPA explained its differential treatment elsewhere in the rule by pointing to “growing investment" and declining costs in solar and wind.

However, the EPA did not note that growing private investment in solar and wind is largely a result of state mandates and federal incentives, not declining costs. After Congress cut off funding for wind tax subsidies, deployment declines radically, and Lawrence Berkeley Labs recently found that solar subsidies are the most important catalyst for solar’s energy’s growth.

Nor did the EPA note the growing body of research showing that the cost of solar and wind are expected to increase as they become a larger percentage of the electric grid, due to the high cost of integrating intermittent sources of energy.

An individual state can, for example, shut down a large nuclear power plant and replace it with 100 percent natural gas. Although the state’s physical carbon dioxide emissions would rise considerably, such a move would be credited as a reduction under the Plan’s rate-setting formula.

Furthermore, since this rule only covers emissions from existing generation, state utilities can build new natural gas plants to replace 100 percent of nuclear power and still show net “reductions” in carbon dioxide intensity under the formula because of how existing generation capacity is calculated.

While natural gas has significant climate benefits when it is displacing coal, replacing nuclear and hydro with gas clearly runs counter to the intended aims of the Clean Power Plan.

While an earlier version of the rule did not allow states currently building nuclear plants to count them toward future emissions reductions, the new rule allows the three states building new plants to count the electricity generated toward meeting their targets.

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Michael Shellenberger, President, Breakthrough Institute

436 14th St, Suite 820 :: Oakland, CA 94612 :: cell (best): 415-309-4200 :: office: 510.550.8800 x355 :: Skype: Shellenberger