ANS Request for Comments on EPA's "Clean Power Plan Rule"

ANS needs your help with a response to the Environmental Protection Agency's (EPA) proposed "Clean Power Plan Rule," which seeks to achieve a 30% reduction in carbon emissions from the U.S. electricity sector by 2030.   By any objective measure, this should be good for nuclear.  However, the rule as it is currently structured would almost entirely discount the clean energy contributions of our current nuclear energy facilities and effectively penalize states that have new plants under construction.   Here's why:  The EPA's proposal is based on state-specific carbon limits, and its formula for calculating the "baseline" emissions profile of each state specifically excludes current nuclear plants.  The EPA language allows an arbitrary 5.8% credit toward compliance for maintaining current nuclear generating capacity.  This means individual states that may choose to close existing nuclear plants need only replace 5.8% of the energy generated with clean sources to maintain the same level of compliance.  The other 94.2% can be replaced with sources producing more GHG than nuclear with no impact. By comparison, 100 percent of current renewable energy generation (wind and solar) is counted in EPA's baseline!   The EPA's treatment of nuclear plants under construction is also unacceptable.  Rather than rewarding states for their proactive efforts to decarbonize with new nuclear, the EPA includes the Vogtle, V.C. Summer and Watts Bar 2 projects in their respective states' baseline calculation, thus requiring them to take additional measures to comply with the regulation.   The ANS Policy Statement on climate change (ANS-44-2013) states that " ANS supports policies designed to address carbon emission reductions that are performance-based and technology neutral."  The current EPA proposal clearly fails that test.   It's time for America's nuclear professionals to join the fight. We are not asking for handouts or subsidies, just a level playing field on which to compete.   The EPA is seeking comments on the proposed rule until December 1.  I strongly urge you to CLICK HERE immediately and make your voice heard.  We only have a short window to respond, and the more ANS members weigh in, the louder our voices are, the more likely we will be successful in changing this unfair rule.   More information is available on the ANS website at ans.org/epa. Thank you for taking a few moments to join ANS in this united effort.   Regards, Dr. Michaele (Mikey) Brady Raap ANS President