Jeff Miller
Member
Correct, but they are not just tightly ring-fencing coal and natural gas. The renewables, apart from hydro are part of this mix, to encourage rotation into them. So, going to wind or solar panels is ok, but not nuclear, since the vast majority (94%) of its MWh are deducted from the rate-based denominator. I followed up on page 41, of 645, and note EPA intends to keep control of the "state specific rate-based goal set by the EPA". So, not sure state plans even get the option of adding nuclear back. Comments are the only means, it seems.
Yes, they say all kinds of pleasant things, but in the end, do you agree they took 94% out? EIA has TWH data, for reference. It's pretty easy to tell EPA's TWH values are very short.
After reading your remarks, I went back and looked more carefully at the EPA proposal. It is a long repetitive, somewhat confusing document, but I believe it boils down to the following.
First, it's important to distinguish two things: how the EPA comes up with their goal for each state, and how each state can achieve their goal.
1. How the EPA comes up with the goal.
In a nutshell, I think they do this:
a) add up all the CO2 emissions in pounds from the electrical sector in each state
b) add up all fossil fuel generated electrical energy from the state
c) take the ratio of a) to b)
That's the starting point.
They then do the following calculation to determine what each state's goal should be.
a) assume that the existing coal plants in the state are made ~5% more efficient (reduces the numerator)
b) assume that existing natural gas combined cycle plants are used at a much higher rate (~70%) than they are now in lieu of coal (reduces the numerator)
c) assume that the 6% of nukes that the EPA figures are due to be retired are not retired. Assume the 5 new nukes that are being built now are finished. Both these energy generation terms are added to the denominator. Assume that new renewables - wind and solar - are built each each from 2020 to 2030 at a rate which the EPA thinks is feasible and add the energy generated from these to the denominator.
d) assume the state implements an energy efficiency program and add the cumulative energy savings (1.5% per year) to the denominator.
The ratio calculated in this way is the goal expressed in terms of CO2 intensity - lbs/MWH.
The state then has a choice of trying to meet the intensity (lbs/MWH) goal, or the equivalent goal of a fixed emission in pounds.
2. How the state achieves its goal. The document repeatedly emphasizes that the EPA is not dictating to the states how they should meet the goal. All they care about is that the state has a credible, enforceable plan which meets the goal. So if a state comes back and says they are going to meet their goal by in part building new nukes, the EPA would be fine with that. They say this very explicitly on page 39:
"States may also identify technologies or strategies that are not explicitly mentioned in any of the four building blocks [basically points a,b,c,d above] and may use those technologies or strategies as part of their overall plans (e.g., market based trading programs or construction of new natural [gas] combined cycle units or nuclear plants).
The concern here, is carbon dioxide. If you are the Carolina's, not looking at wind, finding the $2 solar costs these other guys are using (presumably w/o land costs) too expensive, not able to tap hydro, etc., you actually have an incentive to stay within the calculation fence, and use natural gas. So long as you have some coal, its bound to help and would come at cheapest cost. But it increases CO2.
Yes. The EPA document says that in 2030 they still expect more than 30% of the total electrical generation will come from coal and more than 30% from gas. That is to say, the EPA's goal is extremely unambitious. Maybe it's all they can do politically, but objectively it is weak.
Lines were drawn deep in the nuclear / environmental debate long ago. The staffs of those drawing policy like this have old axes to grind. Young ones don't want new enemies. In the analysis above, the 3.2 trillion for solar, again without paying for 5,000 square miles of land, could be beat by the 2.3 trillion that scaling up the 15bb/2.2GW GA plants would yield. I'm not here to say nuclear is safe, but it is a debate over the extra decade, or so, we could buy before reaching whatever the 1,000Gt target might do. The conclusions on that figure are fluid, but things like water vapor feedbacks, etc. need more time before we know what wrenches they will throw us.
Indeed. I believe a serious plan would pull out all the stops and have us build not just enough nukes to satisfy our current electrical needs (400 more nukes), but also enough to satisfy the bulk of our transport and heating needs. I'd do this in conjunction with aggressive energy efficiency and renewable programs. Economies of scale would drive construction costs way down. Implemented world wide, such a plan largely solve our energy and carbon problems.
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