There is no shortage of shouting and dire warnings about the state of the climate and our need to phase out fossil fuels. But there is a more silent revolution happening too – in micropower.

Small-scale electricity generation is slowly replacing big fossil-fuel driven power plants, which are currently the world’s single largest contributor to greenhouse gas emissions.

These micro-electricity producers are relatively small scale, inexpensive, and most importantly, produce little to no carbon emissions. Last year micropower contributed to around a quarter of the world’s electricity, up from 10% in 2000.

What is micropower?

Rooftop solar may be the first thing that springs to mind, but micropower is much more than just solar panels on roofs. The definition of micropower can sometimes be confusing. Amory Lovins and his coauthors discuss this in The Economist‘s 2002 book of the year Small Is Profitable and define micropower as “all renewables except big hydro“.

This definition of micropower thus includes wind farms, even though these can be quite large, because of the scalable (you can plant more or less wind turbines), rapidly deployable, and distributed nature of the individual units.

It does not, however, include hydropower plants larger than 50 megawatts or nuclear power plants, even though these are low- or no-carbon.

Most recently, the Rocky Mountain Institute has included industry sales data of cogeneration power plants in its analysis of micropower trends.

Cogeneration on the rise

In essence, cogeneration uses energy twice – once to produce electricity, and a second time as heat. It is often referred to as combined heat and power. By producing heat for buildings and houses, cogeneration is much more efficient than even thermal plants, which only generate electricity.

Cogeneration has risen dramatically in the past 15 years, but is often overlooked in estimates of energy production. It comes in a variety of forms and can even use waste gases from agriculture and industrial production.

An even more efficient process is sometimes called trigeneration, producing both heating and cooling. Have you ever seen those mysterious plumes of steam rising from manhole covers in New York, in films like Martin Scorcese’s Taxi Driver? Much of that steam comes from New York’s steam system, which is used to heat and cool buildings in Manhattan.

Trigeneration can convert as much as 93% of fuel into useful energy.

Although many cogeneration plants still rely on natural gas for power, they produces roughly 40% less greenhouse gas than a coal plant. While many environmentalists advocate an immediate switch to renewables, others argue that natural gas is providing a lower-carbon ‘bridge’ while the use of renewables can be scaled up.

Grids are going micro too

It’s not just power plants that are going micro. Micro-grids are being built all over the world, both to increase energy efficiency and to provide adaptable and resilient power in the case of major storms or natural disasters like Hurricane Sandy. This is particularly important as extreme weather events are likely to increase due to global warming.

These micro-grids, which typically incorporate renewables and cogeneration, are designed to be able to operate independently of the main power grid. If disaster strikes, they can produce islands of power to critical facilities such as police, fire services and hospitals.

While more than 260 such projects are planned or operating in the United States, Connecticut has become the first state to role out a statewide pilot. Micro-grids aren’t just helpful during natural disasters – they avoid long-distance transmission, so can reduce line energy losses which can reach as high as 20%.

Cities, and the way they are powered, will undoubtedly play a huge role in the transition to a sustainable and resilient energy future. New York has reduced its greenhouse gas emissions by 19% since 2005. This is partly from an increased use of cogeneration and natural gas, and upgraded city operations using cleaner vehicles.

In fact, while ‘going green’ often conjures up images of Arcadian off-grid living, New Yorkers have the smallest carbon footprint in America. They generate less than 30% of the average national emissions. Compact cities are more energy efficient for a host of reasons, and as many have pointed out, the way to a green future isn’t urban sprawl.

The central power plants that dominated the 20th century energy landscape are seeing their market share in energy generation fall rapidly. New power plants are becoming smaller, scale-able and more efficient, as renewables and cogeneration continue to increase their production share.

The past and future of micropower

In many ways the rapid growth of micropower is a back to the future scenario.

In 1882, Thomas Edison’s famous Pearl Street plant began generating heat and electricity for lower Manhattan. Natural Geographic has a wonderful explorable infographic about the way “power pulses, information flies, and steam flows” below the streets of New York.

Thomas Edison envisioned similar systems to provide local power and heat into the future. Power grids and centralised power plants changed all that, and the 20th century seemed to prove Edison wrong.

But clearly things have changed since then, as micro-power’s market share pushes upwards. Technological innovation, changes in energy production and extraction, and public concern over climate change and natural disasters have helped power the revolution.

We certainly aren’t in the clear yet, and the world desperately needs a global climate agreement. The future may still be cloudy, despite the groundbreaking deal between the US and China.

But the micropower revolution bodes well for a resilient, secure, and low-carbon energy future. Perhaps every cloud does have a silver lining.

Morgan Saletta is a Doctoral Candidate in History and Philosophy of Science at the University of Melbourne. A trained anthropologist and historian of science, his research interests include the Neolithic transition in Europe, transnational environmental history (particularly in the Pacific and Indian Ocean worlds), as well as the many interactions between science, technology and society. He does not work for, consult to, own shares in or receive funding from any company or organisation that would benefit from this article, and has no relevant affiliations.

This article was originally published on The Conversation. Read the original article.

Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

1. Remove the preservation of existing nuclear reactors from the BSER.
2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

• Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
• Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

• New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
• Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

Since its inception, ‘conservation’ has pitted itself against tribal peoples, largely through taking their lands and forbidding their subsistence activities. This has included preventing local people hunting for food in order to conserve game for sport or trophy hunters.

Many conservation organizations now have more ‘tribal friendly’ policies on paper, but these rarely reflect the reality on the ground where conservation remains responsible for serious human rights violations.

Tribal peoples’ lives and lands are being destroyed by the conservation industry, tourism and big business. We’re fighting these abuses. We know tribal peoples are better at looking after their environment than anyone else.

What are you planning to do about it?

We are embarking on a very ambitious project, to press conservationists finally to abide by international standards on human rights and tribal peoples.

We believe that if that can be achieved, the partnerships which will result will eventually catalyze the most significant leap forward for genuine environmental protection in history. In its current form ‘conservation’ often doesn’t work: it’s failing to save many environments and it’s harming people.

The key to its failure is that the benevolent image it presents to the public in industrialized countries is far from how it’s perceived on the ground: locally, it’s often seen as just another form of colonialism, profiting from land grabs, invasive tourism (marketed with an ‘eco’ label), trophy hunting, biofuel production, and even logging and mining.

What specific areas are you looking at?

To begin with – Baka ‘Pygmies’ in Cameroon, who are routinely and seriously abused by park guards that depend on financial support from WWF; tiger reserves in India, which are used as a cover for land grabs and logging; Bushmen in Botswana who are being forced off their lands supposedly to preserve game (though a diamond mine has been built there); and, more generally, the real story of the suffering which national park creation has inflicted on tribal peoples.

Don’t you have to have conservation zones to preserve wilderness?

It’s invariably claimed that tribal peoples’ lands are wildernesses, but that’s wrong. Nearly all conservation zones are in fact the ancestral lands of tribal peoples, who have been dependent on, and shaped, managed and controlled them for millennia.

Many of the benefits of this ‘shaping’ are only now being realized: for example, the deliberate and regular burning of bush by Australian Aboriginals increased biodiversity and stopped the huge, dangerous fires which now plague that continent.

Far from being devoid of human influence, the world’s most famous ‘wildernesses’ – including Yosemite, Yellowstone, and the Serengeti – were home to tribal people, who were violently evicted when their lands were turned into national parks geared towards mass tourism and its businesses.

But at least these areas are now protected, aren’t they?

Preventing certain human activities in some areas is normal, and is likely to be supported by tribal peoples. However, in many conservation zones, the apparent ‘wilderness’ is partly a stage set, where water holes are specially dug near hotels to attract game, land is cleared to create vistas for tourists, and fences, roads, hotels, camps, airstrips, study centers, and parking zones etc. are built.

In this way, the same voices asserting that the land should remain ‘untouched’ can change it more than ever. Many national parks nowadays are not empty areas, fenced off from encroachment, they are crafted by conservationists in a particular image, and usually see far more human activity than they ever did.

But conservation has prevented species extinction, isn’t that good? Of course! The massive big game hunts pursued by the European colonists in India, and Africa are now more controlled (though hunting concessions are still regularly sold). However, the same species which were threatened a generation ago remain threatened today.

WWF says that Earth has lost half its wildlife in the last 50 years. Conservation simply isn’t working, and that’s partly because it alienates local people. It won’t work until it brings them on its side, and it can’t do that if it continues to be responsible for abusing them.

What do tribal people think of conservation?

Survival does not claim to represent tribal peoples, but it’s clear that some now view it as one of the biggest problems they face. Some are employed by it, usually at the lowest level – putting on shows for tourists, working as servants in tourist camps and hotels and so on. Some are intimidated by it, and a few profit from it.

What’s the evidence that conservation organizations are involved in trophy hunting?

The evolution of conservation ideas in the 19th and early 20th centuries was inextricably linked to trophy hunting. Conservation still routinely profits from it. WWF calls it a ‘legitimate tool’, a conservation ‘incentive’, even the best available option in certain situations. It has supported zoning in Cameroon which includes hunting concessions.

The International Union for the Conservation of Nature (IUCN), the world’s largest environmental organization, supported an auction to hunt rhino, asserting, “trophy hunting is a fundamental pillar of Namibia’s conservation approach and instrumental in its success.”

Several conservation leaders, such as the former King of Spain (ex-president, WWF Spain), the Duke of Edinburgh (ex-president, WWF International), and his grandson, Prince Harry (ambassador, United for Wildlife), have themselves been trophy hunting.

The view that such hunters make the best conservationists has long been widely held. Meanwhile, tribal hunters are accused of ‘poaching’ because they hunt their food. And they face arrest and beatings, torture and death, while fee-paying big game hunters are encouraged.

Aren’t some tribespeople guilty of illegal poaching or helping ‘organized’ poachers?

Perhaps, in some places, but it’s important to grasp the background. The first illegal act is that of governments and conservation organizations which steal tribal lands and prohibit their subsistence activities. The second is the persecution of tribes by those determined to keep them out.

With their means of survival eroded, it’s not surprising desperate tribespeople can be recruited by ‘organized’ poachers. However, it’s also true that this can be a fabricated accusation, used by governments and environmentalists to justify their own illegal acts (as is clear in Botswana).

Wouldn’t it be complex and costly to involve tribal peoples properly and fairly in conservation projects on their lands?

There are hundreds, perhaps thousands, of organizations which claim to work for the environment. Every 24 hours, Conservation International receives $290,000, the IUCN pulls in over $320,000, WWF $2 million, and The Nature Conservancy $2.6 million: there is hardly a shortage of resources.

Were such funds to be deployed appropriately, in real and equal partnerships with tribal peoples, the latter are likely to prove far more efficient and better custodians of their own lands than anyone else.

The evidence shows that the most economical way, by far, to protect environments is to ensure tribal peoples control their own lands, the territories they have infinitely more expertise about than anyone else.

Aren’t you ignoring the complex realities of the power imbalances and racism working against tribal peoples in conservation zones?

No, we fully recognize them: we’re trying to change them. All too often the conservation organizations accept – even reinforce – them, or devise ineffectual projects to do no more than try and mitigate their effects.

Your criticisms of conservation have been denounced as a fundraising gimmick. Is this true?

No, probably most of our supporters see themselves as natural conservationists. By exposing the flaws in conservation we are prepared to lose support, and to be fiercely attacked by very powerful conservation organizations and their business partners.

The former include some of the world’s most trusted ‘brands’, and we know it will be difficult to persuade the public that they need to change.

In addition, criticisms of such organizations – which often litigate when they feel threatened – are rarely covered by the media. We are setting ourselves a difficult, but absolutely vital, task.

How can you claim tribal peoples are the best conservationists?

Survival has been very careful to make the claim after careful consideration of the evidence, much of which has only recently become available.

This includes: satellite imagery of Amazonia and other areas, which clearly shows how the Indian areas remain the most forested; game populations in the Kalahari, which prove that the Bushmen don’t overhunt as claimed; studies of the effects of regular indigenous undergrowth firing, swidden agriculture, and hunter-gatherer activities which increase biodiversity; studies of the destructive impact of invasive species, which can increase when tribal peoples are evicted; research on Rapa Nui (Easter Island) which shows that earlier ideas about deforestation are probably wrong; tiger populations, which can be denser when tribal peoples have not been evicted; and countless testimonials of indigenous people themselves.

What do other organizations think?

Even reports from organizations which have been responsible for the removal of tribal peoples actually support this view. The World Bank has been one of the most destructive forces over the last generation, yet one of its studies shows less deforestation where tribal peoples live; WWF asserts that 80% of the richest ‘ecoregions’ are home to tribal peoples which “testifies to the efficacy of indigenous resource management systems.”

Isn’t all this just more of the romantic ‘noble savage’?

No, it’s what the evidence shows. There is no doubt that tribal peoples have a profounder connection to ‘nature’ than industrialized society.

Their surrounding environment is not just a home but provides building materials, food, medicine, clothing, and all that is necessary for their families to thrive. They live largely self-sufficient ways of life, and depend upon their land for everything: it is their shelter, their supermarket, their temple, and their hospital.

More than anyone, their health, prosperity and survival depend on their environment, which makes them the best conservationists and guardians of the natural world. These are the facts which industrialized society has spent generations belittling with cries of ‘noble savage’

Stephen Corry (b. 1951, Malaya) was projects director of Survival International from 1972, and has been its director general since 1984. He has worked with tribal peoples in the Indian subcontinent, Africa and, particularly, western South America, mainly Amazonia. In the 1970s, he promoted ‘self-determination’ in the debate about indigenous peoples which was then largely polarised around the poles of ‘assimilation’ or ‘preservation’. 

In the 1980s, he pushed to popularize tribal peoples’ issues. In the 1990s, he led the opposition to ideas such as the ‘rainforest harvest’, which threatened to confuse economic issues with human rights. He was involved in the campaign to defend the land rights of the ‘Bushmen’ of Botswana, a country where he has been (wrongly) described as ‘public enemy number one’.

His work now is centred around building a groundswell of support for tribal peoples, significant enough both to endure for decades and permanently change the false and harmful assertion that they are backward remnants, destined to disappear.

Stephen Corry is the author of ‘Tribal Peoples for tomorrow’s world’, Freeman Press, 2011.

More information: survivalinternational.org/parks.

Alice Bayer is the Press Officer at Survival International, the global movement for tribal peoples’ rights, where she has worked since 2009.

Alice studied Economics and Politics at Bristol University and has a Masters in Development Studies from SOAS, University of London, where she focused on indigenous-led approaches to development in Mexico. She has visited tribal communities in India facing eviction from their lands.

Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

1. Remove the preservation of existing nuclear reactors from the BSER.
2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

• Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
• Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

• New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
• Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

1. Remove the preservation of existing nuclear reactors from the BSER.
2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

• Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
• Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

• New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
• Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

1. Remove the preservation of existing nuclear reactors from the BSER.
2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

• Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
• Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

• New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
• Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

1. Remove the preservation of existing nuclear reactors from the BSER.
2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

• Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
• Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

• New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
• Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

The Financial Conduct Authority (FCA) has been giving the UK’s small but fast-growing community energy sector a serious headache.

For years a cooperative ownership structure had proved highly popular for small scale, community based renewable energy projects, and a valuable alternative to standard companies limited by shares.

But last summer the Financial Conduct Authority suddenly – and without warning or prior consultation – ceased to register new energy coops.

The surprise move appeared to be no change of government policy, but rather the financial regulator itself applying existing rules more strictly than it had before.

Not surprisingly the move created significant political controversy, and before long Labour’s energy minister Tom Greatrex stepped into the fray with a letter to the FCA complaining that “future energy co-ops are being put at risk” by the change of approach.

“This sudden change threatens a model that combines the twin goods of decarbonisation and community involvement in energy”, he continued. “The FCA must urgently reconsider their approach – and Ed Davey needs to wake up and get a grip to prevent lasting damage to the prospects of more community energy projects in the UK.”

Consultation launched

The upshot was that the FCA launched a consultation on the topic – and tomorrow, 28th November, is the deadline for putting in comments. So please try to get your comments in!

Energy4All – a ‘co-operative of co-operatives’ in the renewable energy sector (and my employer) – also launched a 38 degrees petition aimed at the FCA: “Allow the creation of Renewable Energy Co-op’s with the Financial Conduct Authority.”

At the heart of the issue is the question of whether energy co-operative members participate enough in the co-op. To register a co-op, FCA rules require it to “show participation” by “buying from or selling to the society”, “using the services or amenities provided by it” and “supplying services to carry out its business”.

But unlike a co-op shop, which can sell direct to its members, energy co-ops are too small to apply for the public energy supply licenses that would allow them to sell electricity from their solar panels or wind turbines direct to members. Instead, they tend to sell their power into the local power network. Profits are divided among co-op members based on the size of their investment.

And there is no requirement in the ‘seven principles‘ of the International Co-operative Alliance that co-ops have to trade with their members. We believe the FCA should register any co-op that complies with the international principles without imposing additional constraints.

Co-ops have the potential to become a significant alternative to the big energy companies, but the growth of the sector – which is Government policy and backed by all parties – is at risk unless the FCA backs down.

What’s so good about co-ops?

Co-ops are open democratic structures (one member, one vote) with a social rather than a commercial ethos and would appear to be the natural way for like minded people to come together to make a renewable energy project work. The ‘seven principles’ are, in full:

1. Voluntary and Open Membership – there is usually a public share offer to raise funds to build the project;
2. Democratic Member Control – each member will have one vote no matter how much they have contributed to the capital of the co-op;
3. Member Economic Participation – the members contribute equitably to and democratically control the capital of their co-operative;
4. Autonomy and Independence – renewable energy co-ops are self help organisations controlled by their members;
5. Education, Training and Information – renewable energy co-ops provide education and training for their members, and inform the public about the benefits of co-operation and of renewable energy;
6. Co-operation among Co-operatives – renewable energy co-ops help other co-ops;
7. Concern for Community – renewable energy co-ops spend part of their profits on community projects, especially those related to energy efficiency and education.

It’s not hard to see how an organisation set up and operated on these principles is not the same as any old limited company or PLC, and makes an ideal vehicle for locally-based energy projects for the mutual benefit of members and the wider community.

FCA proposal not good enough

The FCA says that using a Society for the Benefit of the Community (a ‘BenCom’) is more appropriate for community energy. However the consultation looks at making the raising of capital by a BenCom very restrictive. The result is that larger projects, the ones that generate most power per pound of investment, will be more difficult to finance.

It does seem odd that an individual can take advantage of the Feed in Tariff by putting solar panels on their roof, whereas other less fortunate people – say those with less cash, living in flats, or just with wrongly positioned roofs – are not to be allowed to come together in a co-operative which can often achieve a better result in terms of renewable energy output and social benefits.

Most people think renewable energy co-ops are a force for good and should be encouraged. Elswhere in Europe the co-operative is the main form for community energy ownership, and in countries where community ownership is much more established than in the UK, such as Denmark, co-ops have been instrumental in driving the expansion of the sector.

Wider use of the co-operative model in the UK can make an important contribution to changes in energy production and consumption which will help democratise the ownership of energy, reduce energy prices, support communities and increase the production of renewable energy which is such a vital tool in the fight against climate change.

It seems a pity that the UK, where the co-op was invented in the 19th century, cannot see its way to permitting its wider usage.

Would the Rochdale Pioneers have used a co-op to generate energy if they could? Surely the answer is a resounding ‘YES!’ Co-operative enterprise has a long and proud history and we must, in the spirit of the early co-operative pioneers, oppose needless restrictions on the sector.

Petition: “Allow the creation of Renewable Energy Co-op’s with the Financial Conduct Authority.”

Consultation document: CP14/22 Guidance on the FCA’s registration function under the Co-operative and Community Benefit Societies Act 2014. The consultation closes tomorrow,
Friday 28 November 2014.

If you want to see more renewable energy co-operatives running community projects in the UK please participate in this consultation and make sure your views are heard!

Energy4All was formed in 2002 to expand community ownership of renewable energy. We now have 15 projects in the Energy4All family with 10,000+ members, £37m capital raised – enabling many more communities to benefit from renewable energy. We are ourselves a co-operative, owned by the co-ops that we serve.

Tammy Calvert is office manager at Energy4All.