James Greenidge

Queens NY

“Justin, Remy,

Looking again (more carefully) at their Ohio example,…” I agree the whole methodology appears flawed, however in the Ohio example the spreadsheet has Davis Besse “current capacity” listed at 925.2 MW. This was the plant original nameplate capacity rating. The current nameplate capacity rating is listed at 889MW (Wikipedia). I doubt there is a power plant, of any type, in the country still rated at the original nameplate capacity. I don’t know how this affects all these calcs, but in the real world of CO2 production by power plants, the actual current plant ratings should be used for the baselines, not outdated original plant ratings. Most nukes have been uprated from original nameplate rating. Yes in forecasting future generation numbers average historic capacity factors have to be applied. However you should start with the current plant rating, which is the number the Utilities give to the various rate commissions to determine the “rate base.” If this is not an isolated example not only the methodology is bogus, but all the actual calcs may be bogus.

]]>Looking again (more carefully) at their Ohio example, do I understand correctly that they are only including 5.8% of the state’s nuclear generation in the denominator, i.e., what they call the state’s overall power generation level (in MW-hrs)?! Do I also understand that this is only done to nuclear (i.e., that the entire amount of coal, gas and renewable generation is included in the computed total MW-hrs)?!

In other words, when they refer to a requirement that the tons of CO2 per MW-hr generated be reduced by a certain percentage, they’re actually not referring to the actual, tons/MW-hr of the state’s (entire) power generation fleet? That is, what any reasonable person would assume they meant?

Sorry, but this borders on being illegal, especially given the level of deception and the clear arbitrariness of it (where nuclear, specifically, is treated diferently than all other sources). This is clearly capricious and arbitrary, and completely against the spirit of emissions reduction (especially considering your replacing nuclear with gas example). Why would they go to the trouble of making something complicated and convoluted instead of simple, i.e., determining the emissions intensity by simply dividing overall CO2 emissions by overall power generation. There are no non-nefarious explanations.

I mean it. Unless things are changed, the nuclear industry should sue EPA over this. Hell, the coal industry does it (sues) all the time, even over regulations that are completely justified and desperately needed.

]]>The EPA sets state goals using MWh/year of generation as they should. What’s weird is that you get different answers for actual generation if you use the 5.8% value versus calculating from capacity factor. This may be due to the fact that 2012 is the base year and some units had outages. Also San Onofre wasn’t operating at all in 2012 though it’s listed as an operating plant. To be consistent, we scaled nuclear generation from the original spreadsheets except for the states that have under construction units. The EPA assumes a 90% capacity factor for these sites and we had to assume the same for the operating units to get the generation for those states.

]]>Thank you both very much for your work in exposing this buried treasure aimed directly at increasing revenues for the natural gas industry – aka “Big Oil.”

Before I delve into your spreadsheets, can you answer one more question? Several times in your original post and in explanatory comments you used the word “generation” and then “capacity” interchangeably.

For the average nuclear plant, there is only a 10% difference in value between its annual generation and its nameplate capacity.

However, all other generation sources have more substantial differences between the amount of electricity that they generate over time and the amount of power they can produce when running at their physical design limit.

Does the EPA formula use “capacity” or “generation” by applying some kind of average CF to each technology? If the former, there is an even larger problem than you describe.

]]>Thank you for your comments and support.

Here are the links to Google Docs that have our analysis and data.

State Goal Data Calculations:

https://docs.google.com/spreadsheets/d/1CAdDiE3beafN6sU0_iiw0gdGOHWbTC7OavHGrpdDp2A/edit?usp=sharing_eid

Plant Level Data Calculations:

https://docs.google.com/spreadsheets/d/1k2MSzvGbQDRAVeISPuX1rZczBxSc1UiH0lmWqQYOy2s/edit?usp=sharing_eid

These documents can be edited so you can view the equations. If you see any errors in the analysis please say so.

The State Goal Data has our analysis of the plan. The first three sheets have the exact same format and formulas for calculating a state’s emissions rate goal. The first sheet is just a copy and paste of what the EPA had on there site using 5.8% of current generation and 100% of under construction nuclear generation. The second sheet adds 100% of nuclear generation to NGCC. The third sheet credits 100% of nuclear generation into a states emissions goal.The last sheet details the results.

To note we did our analysis correctly, the total carbon emissions of the US for sheets 1 and 3 are the same. Also, the total electricity generation is the same for sheets 2 and 3. These values can be found in the results sheet.

The amount of annual nuclear generation was calculated from the Plant Level Data document. This spreadsheet lists all generating units for each state and we simply summed the capacity of nuclear plants.

Our idea was to use exactly what the EPA had in their state emissions goal calculation. To do this we had to paste values for the redispatched OG/Coal/Other columns because their value depended on what was in redispatched NGCC. Otherwise the data and formulas are exactly the same.

Hopefully this data will convince anyone who is still skeptical. Thanks for reading.

]]>Another route might be to require utilities to publish their CIPK. I would suggest a 2060 CIPK goal of 91 grams, which I believe works out to 200 Lbs per MWh. Have utilities publish this number monthly (or more often), and rate-payers will wonder why the Province of Ontario and the utility Energy Northwest (in Wash state) keep their rates in-line while producing even less CO2 than this marginal goal. ]]>

Thanks for your question. I thought that I would take a hack at it, and hopefully can provide you the answers you’re looking for.

The reason for this is due to the way EPA calculates state-wide emissions “rates”. Your assumption stating that all existing nuclear generation is used in determining state emissions reduction goals is incorrect. To see this for yourself, I would recommend going to the technical documents (the “data provided by the EPA” link) supplied by the EPA for this plan. In the Goal Computation TSD and two supporting Excel files provided, you can find the total energy produced by nuclear in a state and compare it to the value that they use in calculating a state’s goal.

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.

To answer your first question, Dr. Skutnik, Remy, and I are currently working on making our calculations publicly available.

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