BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Develop
an Electricity Integrated Resource
Planning Framework and to Coordinate
and Refine Long-Term Procurement
Planning Requirements
CALIFORNIANS FOR GREEN NUCLEAR POWER, INC. REPLY
COMMENTS IN RESPONSE TO ALJ FITCH'S PROPOSED DECISION
DATED MARCH 18, 2019 RE ADOPTING PREFERRED SYSTEM
PORTFOLIO FOR 2017-2018 INTEGRATED RESOURCE PLAN
March 31, 2019
Gene Nelson, Ph.D.
Legal Assistant
Californians for Green Nuclear Power, Inc.
1375 East Grand Ave, Suite 103 #523
Arroyo Grande, CA 93420
Tel: (805) 363 - 4697
E-mail: Government@CGNP.org
E-mail: Government@CGNP.org
1
R.16-02-007
(Filed 02/11/2016)
(Filed 02/11/2016)
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Develop
an Electricity Integrated Resource
Planning Framework and to Coordinate
and Refine Long-Term Procurement
Planning Requirements
CALIFORNIANS FOR GREEN NUCLEAR POWER, INC. REPLY
COMMENTS IN RESPONSE TO ALJ FITCH'S PROPOSED DECISION
DATED MARCH 18, 2019 RE ADOPTING PREFERRED SYSTEM
PORTFOLIO FOR 2017-2018 INTEGRATED RESOURCE PLAN
I.
Independent nonprofit, Californians for Green Nuclear Power, Inc. (CGNP) respectfully
requests time to present its viewpoint at the All-Party Meeting set for April 4, 2019 from 10:00 AM to Noon at the CPUC headquarters. In order to fight climate change, PG&E should withdraw its plan to voluntarily close its Diablo Canyon Power Plant (DCPP) in 2025 as its plan is not in the public interest..
While some arguments necessarily assume massive energy storage will be available for intermittent resources within 10-20 years, this proceeding by law covers time horizons much earlier as well. There is nothing in the record or in the public domain that indicates the massive quantities of energy storage are available now or will be available shortly, to make
Independent nonprofit, Californians for Green Nuclear Power, Inc. (CGNP) respectfully
requests time to present its viewpoint at the All-Party Meeting set for April 4, 2019 from 10:00 AM to Noon at the CPUC headquarters. In order to fight climate change, PG&E should withdraw its plan to voluntarily close its Diablo Canyon Power Plant (DCPP) in 2025 as its plan is not in the public interest..
While some arguments necessarily assume massive energy storage will be available for intermittent resources within 10-20 years, this proceeding by law covers time horizons much earlier as well. There is nothing in the record or in the public domain that indicates the massive quantities of energy storage are available now or will be available shortly, to make
Introduction
2
R.16-02-007
(Filed 02/11/2016)
(Filed 02/11/2016)
an appreciable difference in the deployment of “renewables” and hence emissions. For the
next decade, the only logical thing to do is maintain extant dispatchable GHG-free power sources
online, like Diablo Canyon Power Plant (DCPP.) As the record in previous proceedings shows,
DCPP has ample useable life left to serve as the bridge technology that California needs.
CGNP submitted testimony in the Diablo Canyon Proceeding A.16-08-006 which showed that every large electric grid in the world relies upon a continuous large supply of power from baseload sources. This reliable supply must make up a substantial fraction of the total at all times in order to ensure grid stability. For the CAISO, this minimum is many times the output of Diablo Canyon. No reliable carbon free replacement for DCPP's 2,240 MW power has been identified in the IRP.
Under this IRP. the reliable supply of essential baseload power will be met by burning natural gas, more than if Diablo continued to operate, increasing CO2 emissions by 9 million tons annually. As the ALJ noted without DCPP, the set of IRPs submitted will not be adequate to meet the GHG emissions goals and could even challenge grid reliability. Further the ALJ noted that Since Diablo Canyon was a baseload resource and most renewable resources are not, if anything we are concerned that the replacement power procured mostly by CCAs will not represent as reliable and cost-effective a resource as DCPP has proven to be over the decades.
Indeed, intermittent solar and wind sources are not capable of replacing a baseload plant such as DCPP because they can never be counted upon to produce power whenever it is needed. All of the wind and solar sources in the proposed IRPs do not allow for ANY firm generating capacity to be retired. As the ALJ noted, the IRPs do not provide sufficient information on the emissions of pollutants associated with the resources they would use. Detailed analysis filed by CGNP in A.16-08-006 also shows the proposed intermittent replacements will result in much higher overall costs to ratepayers than continued operation of Diablo Canyon. For all of these reasons the IRP should provide for enabling Diablo Canyon, California's largest reliable, economical carbon free energy source, to continue operating well beyond PG&E's proposed shutdown.
CGNP submitted testimony in the Diablo Canyon Proceeding A.16-08-006 which showed that every large electric grid in the world relies upon a continuous large supply of power from baseload sources. This reliable supply must make up a substantial fraction of the total at all times in order to ensure grid stability. For the CAISO, this minimum is many times the output of Diablo Canyon. No reliable carbon free replacement for DCPP's 2,240 MW power has been identified in the IRP.
Under this IRP. the reliable supply of essential baseload power will be met by burning natural gas, more than if Diablo continued to operate, increasing CO2 emissions by 9 million tons annually. As the ALJ noted without DCPP, the set of IRPs submitted will not be adequate to meet the GHG emissions goals and could even challenge grid reliability. Further the ALJ noted that Since Diablo Canyon was a baseload resource and most renewable resources are not, if anything we are concerned that the replacement power procured mostly by CCAs will not represent as reliable and cost-effective a resource as DCPP has proven to be over the decades.
Indeed, intermittent solar and wind sources are not capable of replacing a baseload plant such as DCPP because they can never be counted upon to produce power whenever it is needed. All of the wind and solar sources in the proposed IRPs do not allow for ANY firm generating capacity to be retired. As the ALJ noted, the IRPs do not provide sufficient information on the emissions of pollutants associated with the resources they would use. Detailed analysis filed by CGNP in A.16-08-006 also shows the proposed intermittent replacements will result in much higher overall costs to ratepayers than continued operation of Diablo Canyon. For all of these reasons the IRP should provide for enabling Diablo Canyon, California's largest reliable, economical carbon free energy source, to continue operating well beyond PG&E's proposed shutdown.
3
II. The Proposed IRP fails to identify a reliable, economical zero-carbon emitting
replacement for DCPP.
This California net and total demand trend plot for June 14, 2018 is from the California Independent System Operator (CAISO) website. The aqua curve is total California electric power demand as a function of time. The horizontal units are hours, starting with 0 at midnight. The
curve ends 24 hours later at the next midnight. 1
The difference between the pair of curves is met by so-called "renewable" resources. The dominant intermittent generation means are solar and wind. Both of those generation resources fall to negligible values during significant intervals, with the biggest factor being night, which produces zero solar generation. CGNP carefully tabulated the CAISO generation records for the half-year ending on January 31, 2017. CGNP found that the "capacity factor" (or percentage on-time) for the
half-year for both solar and wind was only about 20%, or 1/5 of the time.2 Per the CAISO, the
1 The CAISO Net demand (demand minus solar and wind) is shown near the bottom of the page at http://www.caiso.com/TodaysOutlook/Pages/default.aspx. Unfortunately, only the previous 50 weeks of plots and spreadsheet data are visible. Thus, the above plot will only be visible at the CAISO website until the beginning of June, 2019.
2 "NECG Commentary - Diablo Canyon Retirement" by Gene Nelson, Ph.D. January 11, 2018 https://nuclear-economics.com/wp-content/uploads/2018/01/2018-01-11-DCPP-1.pdf
This California net and total demand trend plot for June 14, 2018 is from the California Independent System Operator (CAISO) website. The aqua curve is total California electric power demand as a function of time. The horizontal units are hours, starting with 0 at midnight. The
curve ends 24 hours later at the next midnight. 1
The difference between the pair of curves is met by so-called "renewable" resources. The dominant intermittent generation means are solar and wind. Both of those generation resources fall to negligible values during significant intervals, with the biggest factor being night, which produces zero solar generation. CGNP carefully tabulated the CAISO generation records for the half-year ending on January 31, 2017. CGNP found that the "capacity factor" (or percentage on-time) for the
half-year for both solar and wind was only about 20%, or 1/5 of the time.2 Per the CAISO, the
1 The CAISO Net demand (demand minus solar and wind) is shown near the bottom of the page at http://www.caiso.com/TodaysOutlook/Pages/default.aspx. Unfortunately, only the previous 50 weeks of plots and spreadsheet data are visible. Thus, the above plot will only be visible at the CAISO website until the beginning of June, 2019.
2 "NECG Commentary - Diablo Canyon Retirement" by Gene Nelson, Ph.D. January 11, 2018 https://nuclear-economics.com/wp-content/uploads/2018/01/2018-01-11-DCPP-1.pdf
4
total installed generation (nameplate) capacity for California solar and wind was about 18,000
Megawatts (MW) on that date.
The purple curve is net demand, which is met by California's dispatchable generation resources. The primary fast-acting generation resource is natural-gas-fired generation, with its attendant emissions of both carbon dioxide (CO2) from combustion and methane (CH4) from leakage during extraction and distribution.. On Thursday, June 14, 2018, natural-gas-fired generation compensated for the remaining ~ 80% of the day. Promoters of solar and wind downplay this connection, which was documented in the August 11, 2016 Washington Post article by Chris Mooney, "Turns out wind and solar have a secret friend: Natural gas." http://tinyurl.com/Natural-Gas-Secret
The vertical coordinate is MW, or Megawatts of generation. Please note the zero level falls on the second line of text below the chart, with the first entry shown at 14,000 MW. The value increases by 5,000 MW with each entry, ending with a highest value of 39,000 MW.
The natural-gas-fired "ramp" starts at about noon and ends at about 8:00 PM. The ramp height is about 16,000 MW. To give some perspective, Hoover Dam's generation capacity (nameplate) is 2,078 MW. This curve means one Hoover Dam is added in the first hour, two Hoover Dams in the second hour until eight Hoover Dams are running in the eighth hour. These generators are not zero- carbon such as Hoover Dam or DCPP - a nuclear power plant. Instead, they are natural-gas- fired
plants that are being run in an inefficient, intermittent fashion, To understand this, consider operating your vehicle in stop- and-go city driving. Emissions are higher and miles per gallon are lower than running your vehicle on the freeway at an essentially constant power level. Natural-gas-fired generators are huge machines that obey the same laws of physics. The conclusion is this stop- and-go pattern for running these
The purple curve is net demand, which is met by California's dispatchable generation resources. The primary fast-acting generation resource is natural-gas-fired generation, with its attendant emissions of both carbon dioxide (CO2) from combustion and methane (CH4) from leakage during extraction and distribution.. On Thursday, June 14, 2018, natural-gas-fired generation compensated for the remaining ~ 80% of the day. Promoters of solar and wind downplay this connection, which was documented in the August 11, 2016 Washington Post article by Chris Mooney, "Turns out wind and solar have a secret friend: Natural gas." http://tinyurl.com/Natural-Gas-Secret
The vertical coordinate is MW, or Megawatts of generation. Please note the zero level falls on the second line of text below the chart, with the first entry shown at 14,000 MW. The value increases by 5,000 MW with each entry, ending with a highest value of 39,000 MW.
The natural-gas-fired "ramp" starts at about noon and ends at about 8:00 PM. The ramp height is about 16,000 MW. To give some perspective, Hoover Dam's generation capacity (nameplate) is 2,078 MW. This curve means one Hoover Dam is added in the first hour, two Hoover Dams in the second hour until eight Hoover Dams are running in the eighth hour. These generators are not zero- carbon such as Hoover Dam or DCPP - a nuclear power plant. Instead, they are natural-gas- fired
plants that are being run in an inefficient, intermittent fashion, To understand this, consider operating your vehicle in stop- and-go city driving. Emissions are higher and miles per gallon are lower than running your vehicle on the freeway at an essentially constant power level. Natural-gas-fired generators are huge machines that obey the same laws of physics. The conclusion is this stop- and-go pattern for running these
5
natural-gas-fired generators yields higher natural gas consumption (good news for a natural-gas
vendor) and higher emissions (bad news for the environment.) Any environmental benefit from the
zero-carbon solar generation or wind generation is questionable. Results from both France and
south Australia show emissions have increased as more solar and wind are added. Adding more
solar or wind only exacerbates these intermittency problems. California's energy storage
systems (Helms and Castaic) are used to prevent supply reliability and instability problems caused
by intermittent solar and wind.
"Always On" zero-carbon DCPP does not suffer from any intermittency problems. It runs for years at a time with a self-contained energy source. Any "extra" nuclear power could be used to charge electric vehicles or desalinate water close to its point of use.
III: The impossibility of replacing zero-carbon DCPP with solar and wind
The previous section explained the reasons for this impossibility In 2017-2018, CGNP submitted written testimony and appeared before several California Assembly and California Senate standing committees advocating for preserving the environmental and ratepayer benefits of the continued safe operation of DCPP. Many times, CGNP reiterated the statement
... In an 11 April 2018 conversation with CGNP's Dr. Nelson, EQC 3 consultant Dr. David Garcia agreed, based on Dr. Nelson's analysis, that replacing Diablo Canyon with other carbon-free energy would be "impossible". Indeed, it is scientifically impossible....
Solar and wind advocates incorrectly point to "energy storage" as a means to mitigate the above intermittency challenges. California's two large energy storage projects, built in the 1980s demonstrate the negligible benefit of storage ( which is not an energy source. A power source charges storage.) Castaic Pumped Storage (Castaic) is in southern California and PG&E's Helms Pumped Storage (Helms,) is about 50 miles east of Fresno in the Sierra foothills. The modest annual production curves of Castaic and Helms are contrasted with the abundant output of DCPP in reference 2, above. The likely reason is "Ancillary Services" - which are required when large amounts of intermittent generation are attached to the California power grid - are given much
3 EQC = Senate Standing Committee on Environmental Quality https://senv.senate.ca.gov/
"Always On" zero-carbon DCPP does not suffer from any intermittency problems. It runs for years at a time with a self-contained energy source. Any "extra" nuclear power could be used to charge electric vehicles or desalinate water close to its point of use.
III: The impossibility of replacing zero-carbon DCPP with solar and wind
The previous section explained the reasons for this impossibility In 2017-2018, CGNP submitted written testimony and appeared before several California Assembly and California Senate standing committees advocating for preserving the environmental and ratepayer benefits of the continued safe operation of DCPP. Many times, CGNP reiterated the statement
... In an 11 April 2018 conversation with CGNP's Dr. Nelson, EQC 3 consultant Dr. David Garcia agreed, based on Dr. Nelson's analysis, that replacing Diablo Canyon with other carbon-free energy would be "impossible". Indeed, it is scientifically impossible....
Solar and wind advocates incorrectly point to "energy storage" as a means to mitigate the above intermittency challenges. California's two large energy storage projects, built in the 1980s demonstrate the negligible benefit of storage ( which is not an energy source. A power source charges storage.) Castaic Pumped Storage (Castaic) is in southern California and PG&E's Helms Pumped Storage (Helms,) is about 50 miles east of Fresno in the Sierra foothills. The modest annual production curves of Castaic and Helms are contrasted with the abundant output of DCPP in reference 2, above. The likely reason is "Ancillary Services" - which are required when large amounts of intermittent generation are attached to the California power grid - are given much
3 EQC = Senate Standing Committee on Environmental Quality https://senv.senate.ca.gov/
6
higher market rewards than bulk energy storage. To prevent equipment damage, voltage and
frequency stability must be maintained, despite solar and wind's well-documented grid
destabilization effects. Furthermore, Battery Electric Storage (BES) is not cost effective. 4
Furthermore, baseload generation is a requirement of California's power grid. When asked, “Are you aware of any large electric grid, anywhere in the world that operates without a substantial continual supply of electricity from base-load sources?” PG&E witness Frazier-Hampton, who performed their needs analysis, was unable to identify such a grid anywhere. 5
A similar problem is faced by a RV owner who wishes to run large loads such as an air conditioner or refrigerator. The owner needs a large fossil-fired generator to insure that starting large loads does not overload their generator, causing it to fail or open the main output breaker. Running those big loads with either solar or wind generation would be impossibly expensive and complicated. Solar or wind are only practical to power the owner's laptop computer.
The California Energy Commission (CEC) requested from the California Council on Science and Technology (CCST) an analysis of the most cost-effective pathway to achieve California's legislatively-mandated emissions reductions. Consistent with CGNP's advocacy, the highly- qualified CCST scientists and engineers indicated in a pair of 2011 reports the only path forward: Expand nuclear power.6
4 "The $2.5 trillion reason we can’t rely on batteries to clean up the grid - Fluctuating solar and wind power require lots of energy storage, and lithium-ion batteries seem like the obvious choice—but they are far too expensive to play a major role."
by James Temple, MIT Technology Review, July 27, 2018 (Retrieved the day of publication) https://www.technologyreview.com/s/611683/the-25-trillion-reason-we-cant-rely-on-batteries-to-clean-up-the- grid/
5 A.16-08-006 Oral Evidentiary Hearing Transcript, April 26, 2017, PG&E, Frazier-Hampton, pp. 946, line 6. Additional details are found in the Appendix, "CGNP's Summary Responses to other Parties" Dec. 7, 2018.
6 "California’s Energy Future: The View to 2050" Release Date: May 24, 2011 | Last Updated Date: February 19, 2015 https://ccst.us/reports/californias-energy-future-the-view-to-2050/
... Nuclear power can provide constant, reliable emission-free energy with a much lower and more easily met requirement for load balancing. Roughly 30 new nuclear power plants could provide two-thirds of California’s electric power in 2050. However, nuclear waste storage remains a significant problem with existing reactor
Furthermore, baseload generation is a requirement of California's power grid. When asked, “Are you aware of any large electric grid, anywhere in the world that operates without a substantial continual supply of electricity from base-load sources?” PG&E witness Frazier-Hampton, who performed their needs analysis, was unable to identify such a grid anywhere. 5
A similar problem is faced by a RV owner who wishes to run large loads such as an air conditioner or refrigerator. The owner needs a large fossil-fired generator to insure that starting large loads does not overload their generator, causing it to fail or open the main output breaker. Running those big loads with either solar or wind generation would be impossibly expensive and complicated. Solar or wind are only practical to power the owner's laptop computer.
The California Energy Commission (CEC) requested from the California Council on Science and Technology (CCST) an analysis of the most cost-effective pathway to achieve California's legislatively-mandated emissions reductions. Consistent with CGNP's advocacy, the highly- qualified CCST scientists and engineers indicated in a pair of 2011 reports the only path forward: Expand nuclear power.6
4 "The $2.5 trillion reason we can’t rely on batteries to clean up the grid - Fluctuating solar and wind power require lots of energy storage, and lithium-ion batteries seem like the obvious choice—but they are far too expensive to play a major role."
by James Temple, MIT Technology Review, July 27, 2018 (Retrieved the day of publication) https://www.technologyreview.com/s/611683/the-25-trillion-reason-we-cant-rely-on-batteries-to-clean-up-the- grid/
5 A.16-08-006 Oral Evidentiary Hearing Transcript, April 26, 2017, PG&E, Frazier-Hampton, pp. 946, line 6. Additional details are found in the Appendix, "CGNP's Summary Responses to other Parties" Dec. 7, 2018.
6 "California’s Energy Future: The View to 2050" Release Date: May 24, 2011 | Last Updated Date: February 19, 2015 https://ccst.us/reports/californias-energy-future-the-view-to-2050/
... Nuclear power can provide constant, reliable emission-free energy with a much lower and more easily met requirement for load balancing. Roughly 30 new nuclear power plants could provide two-thirds of California’s electric power in 2050. However, nuclear waste storage remains a significant problem with existing reactor
7
Consider also the March 26, 2019 advocacy of PG&E's former CEO Geisha Williams for keeping
the U.S. nuclear power fleet operating as a critical means to fight climate change. 7 The Law 360 article also notes PG&E's potential liability of $10.5 billion for the lethal Camp Fire in November, 2018..
IV. Closing a zero-emissions nuclear power plant increases natural-gas-fired generation, hence increases emissions - contrary to California statutes.
California's San Onofre Nuclear Generating Station (SONGS) was closed in January, 2012 as a consequence of the plant owners mis-managing a routine service operation (steam generator replacement.) Nuclear generation, unlike solar generation and wind generation is safe and dispatchable, available to meet demand 24/7, 365 days a year. Thus, when dispatchable SONGS ceased generation, the replacement generation needed to be dispatchable, namely natural-gas-fired generation. This graphic clearly shows this concept. Zero-carbon SONGS prevented about 9 million metric tons (MMT) of emissions in 2011. Note how Combined-Cycle generation soared
technology, not to mention public concern, especially in the wake of Japan’s recent earthquake and tsunami disaster....
"California’s Energy Future – Powering California with Nuclear Energy" Release Date: July 1, 2011 | Last Updated Date: February 19, 2015 https://ccst.us/reports/californias-energy-future-powering-california-with- nuclear-energy/
... Jane C.S. Long, associate director at large for Lawrence Livermore National Laboratory and co-chair of the California’s Energy Future study. Population growth and energy demand will eventually force a decision on California’s energy strategy, especially with the requirement for drastic reduction in emissions. “By 2050, California’s population is expected to rise to 55 million people. That increase, accompanied by economic growth, will likely require a doubling in electricity production, but with virtually no emissions, to meet state goals,” says Jane Long. “That is why nuclear power could prove one important option for meeting those strict and necessary standards.”...
7 "Climate Change Must Guide Utility Plans, Ex-PG&E Boss Says" By Keith Goldberg Law360 (March 26, 2019, 3:55 PM EDT) -- https://www.law360.com/bankruptcy/articles/1142924/climate-change-must-guide- utility-plans-ex-pg-e-boss-says retrieved March 27, 2019 "States have an important role in setting an emissions target. Setting wide and aggressive goals is appropriate," Williams said. "I think how to get there should be left to system operators ... and not necessarily by a prescriptive mandate that says you must purchase this percentage of electricity from certain technologies." In making that point, Williams put in a plug for keeping existing U.S. nuclear power plants and their carbon-free emissions up and running for as long as possible.
"I think that greenhouse gas is the enemy, and we need to decide how we reduce that in the most cost-effective manner," Williams said. "To cast that aside would be pretty irresponsible."
the U.S. nuclear power fleet operating as a critical means to fight climate change. 7 The Law 360 article also notes PG&E's potential liability of $10.5 billion for the lethal Camp Fire in November, 2018..
IV. Closing a zero-emissions nuclear power plant increases natural-gas-fired generation, hence increases emissions - contrary to California statutes.
California's San Onofre Nuclear Generating Station (SONGS) was closed in January, 2012 as a consequence of the plant owners mis-managing a routine service operation (steam generator replacement.) Nuclear generation, unlike solar generation and wind generation is safe and dispatchable, available to meet demand 24/7, 365 days a year. Thus, when dispatchable SONGS ceased generation, the replacement generation needed to be dispatchable, namely natural-gas-fired generation. This graphic clearly shows this concept. Zero-carbon SONGS prevented about 9 million metric tons (MMT) of emissions in 2011. Note how Combined-Cycle generation soared
technology, not to mention public concern, especially in the wake of Japan’s recent earthquake and tsunami disaster....
"California’s Energy Future – Powering California with Nuclear Energy" Release Date: July 1, 2011 | Last Updated Date: February 19, 2015 https://ccst.us/reports/californias-energy-future-powering-california-with- nuclear-energy/
... Jane C.S. Long, associate director at large for Lawrence Livermore National Laboratory and co-chair of the California’s Energy Future study. Population growth and energy demand will eventually force a decision on California’s energy strategy, especially with the requirement for drastic reduction in emissions. “By 2050, California’s population is expected to rise to 55 million people. That increase, accompanied by economic growth, will likely require a doubling in electricity production, but with virtually no emissions, to meet state goals,” says Jane Long. “That is why nuclear power could prove one important option for meeting those strict and necessary standards.”...
7 "Climate Change Must Guide Utility Plans, Ex-PG&E Boss Says" By Keith Goldberg Law360 (March 26, 2019, 3:55 PM EDT) -- https://www.law360.com/bankruptcy/articles/1142924/climate-change-must-guide- utility-plans-ex-pg-e-boss-says retrieved March 27, 2019 "States have an important role in setting an emissions target. Setting wide and aggressive goals is appropriate," Williams said. "I think how to get there should be left to system operators ... and not necessarily by a prescriptive mandate that says you must purchase this percentage of electricity from certain technologies." In making that point, Williams put in a plug for keeping existing U.S. nuclear power plants and their carbon-free emissions up and running for as long as possible.
"I think that greenhouse gas is the enemy, and we need to decide how we reduce that in the most cost-effective manner," Williams said. "To cast that aside would be pretty irresponsible."
8
when SONGS closed in 2012. "Wet" years from 2016 to present allowed large hydro to displace
some of this gas-fired generation. However, drought inevitably returns to California. "Peakers" are
mandatory when there are large amounts of intermittent generation. This is shown by the lower red
curve. More of the challenges of "peakers" follow.
If PG&E follows through with its proposal to voluntarily close DCPP in 2025, the inevitable result is an increase in fossil-fired emissions, likely from a combination of in-state and out-of- state fossil-fired generators. CGNP joined a coalition of environmental and labor organizations to defeat AB 813 in 2018. AB 813 would have terminated the operations of the CAISO and substituted a multi-state board, much more friendly to coal-fired generation. The likely beneficiary of AB 813 was to be the Berkshire Hathaway energy company PacifiCorp. PacifiCorp lobbied extensively for AB813. PacifiCorp currently owns 6,000 MW of dirty coal-fired generation, mostly in coal-friendly Wyoming. Contrary to legislative intent, replacing zero-carbon DCPP by outsourcing California's fossil-fired generation to out-of-state generators would cause multistate harms and increase California ratepayer burdens. See also this important March 25, 2019 article showing coal emissions continued to grow in 2018. 8
8 "In blow to climate, coal plants emitted more than ever in 2018," by Chris Mooney and Bradley Dennis, March 25, 2019, The Washington Post http://tinyurl.com/Coal-Emissions-Grow-In-2018
If PG&E follows through with its proposal to voluntarily close DCPP in 2025, the inevitable result is an increase in fossil-fired emissions, likely from a combination of in-state and out-of- state fossil-fired generators. CGNP joined a coalition of environmental and labor organizations to defeat AB 813 in 2018. AB 813 would have terminated the operations of the CAISO and substituted a multi-state board, much more friendly to coal-fired generation. The likely beneficiary of AB 813 was to be the Berkshire Hathaway energy company PacifiCorp. PacifiCorp lobbied extensively for AB813. PacifiCorp currently owns 6,000 MW of dirty coal-fired generation, mostly in coal-friendly Wyoming. Contrary to legislative intent, replacing zero-carbon DCPP by outsourcing California's fossil-fired generation to out-of-state generators would cause multistate harms and increase California ratepayer burdens. See also this important March 25, 2019 article showing coal emissions continued to grow in 2018. 8
8 "In blow to climate, coal plants emitted more than ever in 2018," by Chris Mooney and Bradley Dennis, March 25, 2019, The Washington Post http://tinyurl.com/Coal-Emissions-Grow-In-2018
9
V. Another imposed cost of "renewables" - substantial stranded assets
California ratepayers annually pay the investor-owned utilities (IOUs) shareholders large sums via the obscure "Capital Cost Recovery" or "Cost of Capital" mechanism. IOU shareholders are awarded the product of the annual allowed depreciation of the IOU's generation and transmission assets and a percentage, currently in the range of 10% to 11% - far in excess of the current Federal Funds Rate of 2.5%. Ratepayers are ultimately responsible for paying this high interest rate as a component of their energy bills.
A generating or transmission asset that is not in use most of the time is a "stranded asset" that provides little ratepayer benefit. As noted above, Helms Pumped Storage (HPS) is apparently used primarily to compensate for the intermittencies of solar and wind generation. Based on statistics from the U.S. Energy Information Administration (USEIA) this expensive asset is barely used. The greatest use of HPS between 2003 and 2018 was in 2016, with an average use of about 67 minutes per day during that year. The lowest use was an average of 12 minutes per day in 2005. In proceeding A.16-08-006, CGNP filed a data request with PG&E, the owner of HPS to learn why this resource with a nameplate capacity of 1,212 MW was used so sparingly. CGNP's data request was rebuffed by PG&E. See the Appendix for details regarding the roughly 0.6 TWh of curtailed California solar and wind generation between November, 2017 and February, 2019 - another example of a "stranded asset." "Peakers" are another example of a "stranded asset." See the summary chart on the next page..
California ratepayers annually pay the investor-owned utilities (IOUs) shareholders large sums via the obscure "Capital Cost Recovery" or "Cost of Capital" mechanism. IOU shareholders are awarded the product of the annual allowed depreciation of the IOU's generation and transmission assets and a percentage, currently in the range of 10% to 11% - far in excess of the current Federal Funds Rate of 2.5%. Ratepayers are ultimately responsible for paying this high interest rate as a component of their energy bills.
A generating or transmission asset that is not in use most of the time is a "stranded asset" that provides little ratepayer benefit. As noted above, Helms Pumped Storage (HPS) is apparently used primarily to compensate for the intermittencies of solar and wind generation. Based on statistics from the U.S. Energy Information Administration (USEIA) this expensive asset is barely used. The greatest use of HPS between 2003 and 2018 was in 2016, with an average use of about 67 minutes per day during that year. The lowest use was an average of 12 minutes per day in 2005. In proceeding A.16-08-006, CGNP filed a data request with PG&E, the owner of HPS to learn why this resource with a nameplate capacity of 1,212 MW was used so sparingly. CGNP's data request was rebuffed by PG&E. See the Appendix for details regarding the roughly 0.6 TWh of curtailed California solar and wind generation between November, 2017 and February, 2019 - another example of a "stranded asset." "Peakers" are another example of a "stranded asset." See the summary chart on the next page..
10
Here's DCPP performance information, which is highly regarded throughout the U.S. nuclear
power industry. DCPP's 2018 capacity factor (percentage "ON" time) is 92.75%, with a high of
96.231% in 2016.
Here's a comparison of four California power plants. Details are found in the Appendix.
PG&E wants to voluntarily close California's biggest, most reliable and most efficient generator by far - which is also truly zero-carbon - in 2025. The plan is to burn more fossil fuel, and as is demonstrated above, use that fossil fuel less and less efficiently as greater and greater amounts of intermittent solar generation and intermittent wind generation are planned to be deployed in California. California's already-excessive power rates will climb even higher. Clearly, this plan is not in the interests of ratepayers or the environment.
PG&E wants to voluntarily close California's biggest, most reliable and most efficient generator by far - which is also truly zero-carbon - in 2025. The plan is to burn more fossil fuel, and as is demonstrated above, use that fossil fuel less and less efficiently as greater and greater amounts of intermittent solar generation and intermittent wind generation are planned to be deployed in California. California's already-excessive power rates will climb even higher. Clearly, this plan is not in the interests of ratepayers or the environment.
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This harmful PG&E plan should be stopped dead in its tracks. Now.
VI. Fossil-fuel interest lobbying is likely the root cause of these poor policy choices.
Since before 2010, there has been a steady stream of news reports regarding the large annual amounts that fossil-
fuel interests expend on lobbying decisionmakers. CGNP believes the bloated amount being spent is acting as a barrier to implementing sound evidence-based energy policies. A pair of recent articles 9 highlighted PG&E's lobbying, a
corporation with billions of dollars in annual fossil fuel sales (natural gas.)
9 "Embattled California utility spent most for 2018 lobbying" KATHLEEN RONAYNE Associated Press The Chicago Tribune February 4, 2019 11:00 AM Sacramento, CA http://www.chicagotribune.com/business/sns-bc-us--california-utility-lobbying-20190201-story.html
(This AP article appeared in the print edition of the San Luis Obispo, California Tribune on page 1B of the Saturday, February 2, 2019 edition with the headline "Embattled PG&E spent most on lobbying in California last year.") Pacific Gas & Electric Corp. spent nearly $10 million on California lobbying efforts in the year before the utility giant declared bankruptcy, spending more than any other entity seeking to influence California government in 2018....
"PG&E Topples Western States Petroleum Association in California Lobbying Spending in 2018" by Dan Bacher IndyBay Tuesday Feb 5th, 2019 10:03 PM https://www.indybay.org/newsitems/2019/02/05/18820999.php
Two days before the filing of lobbying expenses by PG&E, Consumer Watchdog called for the ouster of the California Public Utilities Commission over its decision to extend a $6 billion credit line to Pacific Gas & Electric in what the group called “an unneeded emergency process that allowed no time for scrutiny....”
VI. Fossil-fuel interest lobbying is likely the root cause of these poor policy choices.
Since before 2010, there has been a steady stream of news reports regarding the large annual amounts that fossil-
fuel interests expend on lobbying decisionmakers. CGNP believes the bloated amount being spent is acting as a barrier to implementing sound evidence-based energy policies. A pair of recent articles 9 highlighted PG&E's lobbying, a
corporation with billions of dollars in annual fossil fuel sales (natural gas.)
9 "Embattled California utility spent most for 2018 lobbying" KATHLEEN RONAYNE Associated Press The Chicago Tribune February 4, 2019 11:00 AM Sacramento, CA http://www.chicagotribune.com/business/sns-bc-us--california-utility-lobbying-20190201-story.html
(This AP article appeared in the print edition of the San Luis Obispo, California Tribune on page 1B of the Saturday, February 2, 2019 edition with the headline "Embattled PG&E spent most on lobbying in California last year.") Pacific Gas & Electric Corp. spent nearly $10 million on California lobbying efforts in the year before the utility giant declared bankruptcy, spending more than any other entity seeking to influence California government in 2018....
"PG&E Topples Western States Petroleum Association in California Lobbying Spending in 2018" by Dan Bacher IndyBay Tuesday Feb 5th, 2019 10:03 PM https://www.indybay.org/newsitems/2019/02/05/18820999.php
Two days before the filing of lobbying expenses by PG&E, Consumer Watchdog called for the ouster of the California Public Utilities Commission over its decision to extend a $6 billion credit line to Pacific Gas & Electric in what the group called “an unneeded emergency process that allowed no time for scrutiny....”
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CGNP reviewed PG&E's recent lobbying expenditures directed towards the CPUC. The chart on
the previous page provides a summary. CGNP believes the red bar is a significant outlier. In the
third quarter of 2016, PG&E filed its application A.16-08-006 with the CPUC on August 11, 2016.
PG&E expended almost a quarter of a million dollars lobbying the CPUC during the 3rd
quarter of 2016. 10 At that time, PG&E's concerns about wildfire-related liabilities were not
significant, as the Wine Country Fires did not occur until about a year later. So why was PG&E
expending so much on CPUC lobbying that quarter? The likely answer was that PG&E desired
to increase its post-2025 profits by voluntarily closing DCPP in 2025. The amounts PG&E
spent lobbying the CPUC during that quarter clearly showed its desire to prevail in matters before
the CPUC. The bar to ex-parte communications was not imposed until Q4, on October 6, 2016 at
the prehearing conference (PHC.) The CCR mechanism, highlighted above, could be employed by
PG&E to construct a very large amount of unneeded generation and transmission assets. CGNP's
adverse testimony in A.16-08-006, which drew heavily on PG&E's sworn statements in A.10-01-
022, clearly established that DCPP had many more decades of useful life beyond 2025. The
CPUC chose to ignore CGNP's technical and legal arguments in approving A.16-08-006 on
January 11, 2018. CGNP timely filed its legal objections to the CPUC via an Application for
Rehearing (AFR) that was denied on September 27, 2018. CGNP further pursued California
Appellate Court review in B293420 before the 2nd District, Division 6. However, review was
declined without prejudice. California law does not offer a right of appellate court review of a
CPUC decision that a party objects to. Appellate court review is discretionary.
PG&E's lobbying for a California fossil-fueled future is a small component in a larger fossil-fuel interest campaign that has expended roughly a billion dollars since 2015 lobbying and using public relations tools to prevent meaningful action regarding climate change. 11
10 PG&E's Quarterly Form 635 lobbying disclosures with the California Secretary of State. The $222,908.11 PG&E spent lobbying the CPUC was almost one quarter of the $1,057,644.97 that PG&E spent lobbying the CPUC between the 4th quarter of 2015 and the 4th quarter of 2018.
11 "How Big Oil Continues to Oppoose the Paris Agreement" March 22, 2019 InfluenceMap, London, UKhttps://influencemap.org/report/How-Big-Oil-Continues-to-Oppose-the-Paris-Agreement- 38212275958aa21196dae3b76220bddc 12 instances of "California."
3 instances of "Western States Petroleum Association." "The Dirty Secret Of 'Renewables' Advocates Is That They Protect Fossil Fuel Interests, Not The Climate" by Michael Shellenberger Forbes blog, March 29,
PG&E's lobbying for a California fossil-fueled future is a small component in a larger fossil-fuel interest campaign that has expended roughly a billion dollars since 2015 lobbying and using public relations tools to prevent meaningful action regarding climate change. 11
10 PG&E's Quarterly Form 635 lobbying disclosures with the California Secretary of State. The $222,908.11 PG&E spent lobbying the CPUC was almost one quarter of the $1,057,644.97 that PG&E spent lobbying the CPUC between the 4th quarter of 2015 and the 4th quarter of 2018.
11 "How Big Oil Continues to Oppoose the Paris Agreement" March 22, 2019 InfluenceMap, London, UKhttps://influencemap.org/report/How-Big-Oil-Continues-to-Oppose-the-Paris-Agreement- 38212275958aa21196dae3b76220bddc 12 instances of "California."
3 instances of "Western States Petroleum Association." "The Dirty Secret Of 'Renewables' Advocates Is That They Protect Fossil Fuel Interests, Not The Climate" by Michael Shellenberger Forbes blog, March 29,
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VII. The public safety harms of natural gas.
These reply comments have already supplied information regarding natural gas emissions - which are tightly interwoven with intermittent solar and intermittent wind generation. The public safety problem can be summarized in two words, "San Bruno." A summary of the trail of carnage related to the natural gas status quo in California and elsewhere is contained in the Appendix. The transmission and storage infrastructure is aging, with most assets 50-60 years old. These should be compelling reasons to expand the use of safe nuclear power. However, entrenched business interests have marshaled legions of public relations professionals to deflect away public concerns and regulatory agency concerns regarding inherently dangerous natural gas.
VIII. The path to CPUC Reform
Enlightened California leaders recognize the CPUC is failing at its statutory duties to provide safe, reliable public utilities at a reasonable cost. Special interests lobby to drive up the cost of California's essential electric power and water, which serves to drive employers to locate to other states, further harming California's economy, currently the fifth largest in the world. Do we want a return to ENRON's brownouts and blackouts? CGNP respectfully suggests California's leaders to use a pair of agencies as templates to drive CPUC reform. The professional expertise of the small staff of the Diablo Canyon Independent Safety Committee (DCISC) provides another layer of assurance that DCPP maintains its exemplary safety record. CPUC's technical expertise should be organized and funded as a separate body akin to the DCISC to minimize the influence of entrenched special interests on CPUC's technical decisions. The CPUC's Office of Ratepayer Advocates (Public Advocates Office) is financially dependent on the CPUC and rarely advances meaningful ratepayer advocacy. Instead, a Citizen's Utility Board (CUB) patterned after the Wisconsin CUB should be implemented. Note the cell phone number of Wisconsin's CUB Executive Director is public information, in marked contrast to the insular nature of the CPUC. Details are found in the Appendix. CGNP's Lead Counsel, Mike Gatto made CPUC regulatory
2019. https://www.forbes.com/sites/michaelshellenberger/2019/03/28/the-dirty-secret-of-renewables- advocates-is-that-they-protect-fossil-fuel-interests-not-the-climate/
See also Michael Shellenberger's recent YouTube video from TEDx Danubia https://www.youtube.com/watch?v=N-yALPEpV4w At 9:11, he shows two wind turbine workers who died as a consequence of a 2013 wind turbine fire in the Netherlands. No workers nor anyone in the general public have died as a consequence of radiation from a U.S. commercial nuclear power plant.
These reply comments have already supplied information regarding natural gas emissions - which are tightly interwoven with intermittent solar and intermittent wind generation. The public safety problem can be summarized in two words, "San Bruno." A summary of the trail of carnage related to the natural gas status quo in California and elsewhere is contained in the Appendix. The transmission and storage infrastructure is aging, with most assets 50-60 years old. These should be compelling reasons to expand the use of safe nuclear power. However, entrenched business interests have marshaled legions of public relations professionals to deflect away public concerns and regulatory agency concerns regarding inherently dangerous natural gas.
VIII. The path to CPUC Reform
Enlightened California leaders recognize the CPUC is failing at its statutory duties to provide safe, reliable public utilities at a reasonable cost. Special interests lobby to drive up the cost of California's essential electric power and water, which serves to drive employers to locate to other states, further harming California's economy, currently the fifth largest in the world. Do we want a return to ENRON's brownouts and blackouts? CGNP respectfully suggests California's leaders to use a pair of agencies as templates to drive CPUC reform. The professional expertise of the small staff of the Diablo Canyon Independent Safety Committee (DCISC) provides another layer of assurance that DCPP maintains its exemplary safety record. CPUC's technical expertise should be organized and funded as a separate body akin to the DCISC to minimize the influence of entrenched special interests on CPUC's technical decisions. The CPUC's Office of Ratepayer Advocates (Public Advocates Office) is financially dependent on the CPUC and rarely advances meaningful ratepayer advocacy. Instead, a Citizen's Utility Board (CUB) patterned after the Wisconsin CUB should be implemented. Note the cell phone number of Wisconsin's CUB Executive Director is public information, in marked contrast to the insular nature of the CPUC. Details are found in the Appendix. CGNP's Lead Counsel, Mike Gatto made CPUC regulatory
2019. https://www.forbes.com/sites/michaelshellenberger/2019/03/28/the-dirty-secret-of-renewables- advocates-is-that-they-protect-fossil-fuel-interests-not-the-climate/
See also Michael Shellenberger's recent YouTube video from TEDx Danubia https://www.youtube.com/watch?v=N-yALPEpV4w At 9:11, he shows two wind turbine workers who died as a consequence of a 2013 wind turbine fire in the Netherlands. No workers nor anyone in the general public have died as a consequence of radiation from a U.S. commercial nuclear power plant.
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reform the centerpiece of his 4 terms of service before the California Assembly. Please contact
him for additional details.
IX. Conclusion
In sworn 2010 CPUC filings, PG&E made a clear case for operation through 2045 as the most cost-effective among 18 detailed scenarios. CGNP’s analysis, based largely upon PG&E’s figures, confirmed this. DCPP deserves a zero-carbon credit (ZCC), such as awarded to nuclear plants in Illinois, New York and New Jersey, as its continued operation through 2045 would avoid the generation of well over 100 million tons of greenhouse gas emissions. A ZCC credit would appropriately recognize DCPP is California’s largest reliable and dispatchable carbon-free energy source, for which no reliable carbon-free replacement has been identified. It would create a level playing field ensuring DCPP is fully competitive. As a first step, CGNP advocates the proposed IRP should be modified to reflect the continued safe operation of DCPP well beyond 2025.
Dated: March 31, 2019 Respectfully submitted,
/s/ Gene A. Nelson, Ph.D.
Gene Nelson, Ph.D., Legal Assistant Californians for Green Nuclear Power, Inc. 1375 East Grand Ave, Suite 103 #523 Arroyo Grande, CA 93420
Tel: (805) 363 - 4697
E-mail: Government@CGNP.org
IX. Conclusion
In sworn 2010 CPUC filings, PG&E made a clear case for operation through 2045 as the most cost-effective among 18 detailed scenarios. CGNP’s analysis, based largely upon PG&E’s figures, confirmed this. DCPP deserves a zero-carbon credit (ZCC), such as awarded to nuclear plants in Illinois, New York and New Jersey, as its continued operation through 2045 would avoid the generation of well over 100 million tons of greenhouse gas emissions. A ZCC credit would appropriately recognize DCPP is California’s largest reliable and dispatchable carbon-free energy source, for which no reliable carbon-free replacement has been identified. It would create a level playing field ensuring DCPP is fully competitive. As a first step, CGNP advocates the proposed IRP should be modified to reflect the continued safe operation of DCPP well beyond 2025.
Dated: March 31, 2019 Respectfully submitted,
/s/ Gene A. Nelson, Ph.D.
Gene Nelson, Ph.D., Legal Assistant Californians for Green Nuclear Power, Inc. 1375 East Grand Ave, Suite 103 #523 Arroyo Grande, CA 93420
Tel: (805) 363 - 4697
E-mail: Government@CGNP.org
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