quote:

“Since current nuclear generation is only valued at 5.8 percent of its energy generation, the loss of one plant in a state has only a marginal effect on a state being able to achieve its goal under this standard. If this rule is intended to be a carbon regulation, then all energy sources should be valued based on their emissions and no technology should be given preference over another. Renewables, coal, natural gas, and others are given credit for 100 percent of their current capacity; nuclear energy should be no different.

We must insist that the EPA considers the total generation from all energy sources in calculating carbon emissions intensity. If the EPA gives nuclear energy its full due, then every reactor in the nation must keep running or be replaced with other clean energy sources for a state to meet its goals, making currently operating nuclear units all the more valuable to states. We can make this happen, but only if the nuclear community rises to this urgent challenge, rallying together to push for a fairer, more effective rule that credits current nuclear generation at 100 percent of its current capacity in state-level emissions goals.

In all states that do not have plants under construction, the amount of nuclear generation considered towards state emissions goals is 5.8%. For under construction plants, 100% of their expected production is considered. This makes a state like Georgia appear to have more nuclear energy than a state like Illinois; which of course is not true.
With this in mind, you should see that a nuclear plant will have minimal effect on a state’s emissions “rate”. If the denominator (MWh) of an annual emissions rate changes by only 5.8% of the removed capacity, then it has minimal effect on the final goal.
Mathematically speaking, this incentivizes natural gas because each installation has a larger effect on bringing a states emissions rate downward. This is because most states have an average emissions rate greater than that of a natural gas plant. Therefore, the shutdown of a nuclear plant will take the emissions rate upward only slightly, while replacement of generation with NGCC will bring emissions rates down considerably.
Of course, all of these issues could be averted if the EPA only allows the option to consider emissions on a mass basis. With that said, if the EPA still wishes to calculate state emissions “rates” then they must consider all energy generation in the denominator.”

I would ask the EPA to do a straight forward calculation of carbon intensity using ALL sources. The rest of their plan would still work except there would be no gaming. Also nuclear is a cost effective means of producing electricity and should be used to replace coal and natural gas and not the other way around.”