C2ES Zero Emissions Credit Nuclear Power Summit

The Center for Climate and Energy Solutions held a conference on May 9 that featured conversations with utilities, federal and state policy experts, and industry analysts to discuss solutions to address the retirement of nuclear power plants.  The conference was from 9:30 am – 12:00 pm at Lerner Hall, First Floor, George Washington University, 2000 H St, NW, Washington, DC.

U.S. nuclear power plants are being retired before their operating licenses expire because of persistently low market prices for electricity, complicating efforts to achieve climate targets.

The event  also unveiled their new report, Solutions for Maintaining the Existing Nuclear Fleet, and featured a keynote from Ralph Izzo, CEO of PSEG, as well as perspectives on state policy options, environmental and economic impacts, and the federal landscape.


 Ralph Izzo

Ralph Izzo


Ralph Izzo was elected chairman and chief executive officer of Public Service Enterprise Group Incorporated (PSEG) in April 2007. He was named as the company’s president and chief operating officer and a member of the board of directors of PSEG in October 2006.

State Policies and Proposals to Support Existing Nuclear Power Plants


 Kristy Hartman

Kristy Hartman


Kristy Hartman is the energy program manager for the Environment, Energy and Transportation Program at the National Conference of State Legislatures. In this capacity, Kristy analyzes regulatory and legislative trends related to fossil fuels, energy security, grid reliability, nuclear power and alternative fuels.

 Barbara Lockwood

Barbara Lockwood


Barbara Lockwood is vice president of regulation for Arizona Public Service (APS). Based in Phoenix, APS is Arizona’s largest electric company and serves nearly 1.2 million customers around the state.

 Norris McDonald

Norris McDonald


Norris McDonald Is the founder and president of the Center for Environment, Commerce and Energy and its outreach arm, the African American Environmentalist Association (AAEA). He has been a career environmentalist for 36 years.

 Susan F. Tierney

Susan F. Tierney


Susan F. Tierney, a Senior Advisor at Analysis Group, is an expert on energy economics, regulation, and policy. She has consulted to businesses, governments, grid operators, tribes, environmental groups, foundations, and other organizations on energy markets, and economic and environmental regulation and strategy.

  Doug Vine  — Moderator

Doug Vine — Moderator


Doug Vine is a Senior Energy Fellow at the Center for Climate and Energy Solutions (C2ES). He supports the center’s work on global and domestic energy production and utilization. Additionally, he focuses on topical energy issues including electric power, natural gas, and oil market developments. 

Norris McDonald presentation at event

Federal Options to Support the U.S. Nuclear Fleet

 Kathleen L. Barrόn

Kathleen L. Barrόn


Kathleen L. Barrón is Senior Vice President, Competitive Market Policy, for Exelon Corporation. In that role, she oversees Exelon’s management of federal regulatory policies and strategies and is responsible for identifying and assessing key policy issues of interest to Exelon, crafting the company’s position on such issues, and developing strategies.

 Dean Murphyu

Dean Murphyu


Dean M. Murphy is an engineer and economist with expertise in energy, competitive and regulatory economics and finance, as well as quantitative modeling and risk analysis. His work centers on the electric industry, encompassing issues such as climate change policy and analysis, resource and investment planning (including power and fuel)

Benjamin Reinke


Dr. Benjamin T. Reinke is a professional staff member of the majority staff of the Senate Committee on Energy and Natural Resources, under the leadership of Chairman Lisa Murkowski.

 Donna Attanasio — Moderator

Donna Attanasio — Moderator


Donna Attanasio joined The George Washington University Law School in July 2013 as Senior Advisor for Energy Law Programs, where she leads the Law School’s Sustainable Energy Initiative. 

According to a new report released by the Center for Climate and Energy Solutions at the conference: 

  • The nuclear reactors that have already shut down are being replaced mostly by natural gas, “sending U.S. emissions in the wrong direction.”
  • Noting that any federal policy driving nuclear power is unlikely in the near term, the report says action by states and corporations will be key.
  • Some states are already taking action, and New York’s electric-grid operator floated a proposal last week about how it could put a price on carbon emissions within its system, which would help nuclear plants.
  • Nuclear energy’s carbon-free attribute may not be attractive enough for cities and companies without coming up with a federal answer to store spent fuel: “solving the long-term waste challenge will likely be important to win support for nuclear power from cities and businesses.”

Center for Climate & Energy Solutions Nuclear Confernce


May 9, 2018 10 a.m.- Noon Lerner Hall, First Floor George Washington University 2000 H St, NW Washington, DC

Nuclear power accounts for about 20% of US electricity and more than half its zero-emission generation. On May 9, @C2ES_ org discusses state & federal options for preventing #ZeroCarbonNuclear from being replaced by fossil fuel-fired electricity. https://www.c2es.org/event/zero-carbon-power-mai

PJM Wrong on Reliability Without FirstEnergy Nuclear Plants

The PJM deactivation analysis that planned retirements of three FirstEnergy nuclear facilities in Ohio — the 896 MW Davis Besse plant, the 1,247 MW Perry plant and the 1,811 MW Beaver Creek facility do not present a reliability threat in the short term is wrong.   The PJM conclusion does not include compliance with Environmental Protection Agency Criteria Pollutants, particularly ozone attainment requirements. 

The emissions free nuclear plants offset the nitrogen (NOx) loads from coal plants that contribute to the formation of smog.  Because wind and solar do not have the capability to replace baseload electrical power, natural gas will be the replacement fuel of choice.  Thus NOx from natural gas generation will contribute to the non attainment status for ozone, which reduces reliability if the PJM expects states to comply with the Clean Air Act.

 Davis Besse

Davis Besse

PJM is also relying on speculative new transmission projects to provide reliability.  Such a dice throw is unreasonable.  Approval of proposed transmission projects are meeting significant resistance and are not getting approvals all over the country.  PJM says it can retain reliability through projects already planned in its Regional Transmission Expansion Plan. Again, such planning does not account for PJM states being in none compliance of the Clean Air Act for ozone.  Ignoring health effects is not a good reliability plan.  Another speculative conclusion by PJM is that, even with the retirements, they expect to have sufficient generation and transmission capacity to withstand two concurrent asset outages — a so-called "n-1-1" event.  "They expect?"  This should be a surety, not an expectation.  It is anything but sure.



The reliability analysis is too narrow and does not give credit for the unique attributes of theirnuclear plants, particularly the emission-free nature of this type of generation.  The PJM reliability study ignores the value that these units offer the grid in terms of fuel diversity and zero-carbon and nitrogen emissions generation. 

PJM's new fuel security initiative, which seeks to identify and reward generators with secure fuel supplies, such as onsite stockpiles or dual fuel capabilities is flawed.  "Onsite stockpiles?"  Do they expect these facilities to stockpile wind and solar?  Onsite?  That is not going to happen.  Natural gas, fuel oil and coal are left.  All nitrogen generators.  The PJM should not be promoting any strategy that adds one more pound of NOx or particulate matter (PM) to the ambient air.  

 Beaver Valley

Beaver Valley

If FirstEnregy does not receive emergency support, the Davis Besse plant will retire at the end of May 2020, while the Perry plant and one unit of Beaver Island would come offline at the end of May 2021. The final unit at Beaver is scheduled to close in October 2021. (Utility Dive, 4/30/2018) 

Report Cites Cost of Closing Beaver Valley & Three Mile Island

A new report authored by a consulting firm called The Brattle Group claims the premature retirement of both the Beaver Valley and Three Mile Island nuclear power plants could result in a $285 million increase in electricity costs for Pennsylvania consumers.  The report was commissioned on behalf of a nuclear advocacy group called Nuclear Matters.

 Beaver Valley 

Beaver Valley 

The nine-page report released Monday examined the economic and environmental impacts of the potential closure of the two Pennsylvania nuclear plants, as well as two other FirstEnergy-owned plants in Ohio.

 Three Mile Island

Three Mile Island

If the plants were to go offline, Pennsylvania and Ohio would lose the zero-emission benefits of power generation, the report said. To that end, the authors estimated an additional 21 million metric tons of carbon dioxide would be released annually by other power plants, or the equivalent of 4.5 million additional cars on area roadways.

That’s not to mention that the four power plants directly employ more than 3,000 people, as well as hundreds of contractors who perform maintenance and security work for the plants. Most, if not all, of those jobs would disappear if the plants close, which would result in the loss of hundreds of millions of dollars in state and local tax revenues.

In August of 2013, the Vermont Yankee Nuclear Power Plant closed prematurely, which resulted in drastic loss of local tax revenues and increases in carbon emissions.

If these plants close, the livelihoods of thousands of Ohio and Pennsylvania residents will disappear. The over 3,000 highly skilled individuals directly employed by these sites will leave to seek employment at other facilities still operating around the country.  (The Times Online, 4/16/2018)

Arizona Palo Verde Nuclear Plant Ballot Threat

Arizona’s Palo Verde Nuclear Generating Station could be forced to close in six years, instead of twenty-seven, if voters in the November 2018 election approve a renewable-energy ballot measure, according to plant owner Arizona Public Service Company (APS).  Palo Verde Nuclear Generating Station in Arizona produces the most electricity of any power plant in America, over 30 billion kWhs per year, and is also the largest single producer of low-carbon electricity.

 Palo Verde/Paul Escen/APS

Palo Verde/Paul Escen/APS

The Clean Energy for a Healthy Arizona, HCR 2017, would amend the state constitution to require utilities to get half their electricity from renewable sources such as solar and wind by 2030, up from the present mandate of 15% by 2025.

Few, if any, governments have that high a mandate by 2030, which is only 12 years away. Even at double the 2012-2017 build rate for renewables, 12 years is not enough time to replace Arizona’s coal plants, let alone coal plus nuclear.

APS officials believe the measure would force so much solar and wind development that there would be too much energy on the grid during half the year when Arizonans are not cranking up their air conditioners.  Such oversupply forces the shutdown of baseload power plants, particularly nuclear, which just provides electricity constantly. Varying their output for no good reason wastes money and fuel.  This is exactly what California is struggling with – too much solar when it’s not needed and not enough solar when it is. But they use the surrounding states to buffer that problem. They even use Palo Verde for this assist.

Nuclear from the state’s one nuclear power plant provides 36% of all of Arizona’s electricity, hydroelectric about 6%, solar and wind about 4%.



Tom Steyer, the former California hedge fund billionaire turned political activist, is pushing this Arizona ballot initiative. He wants to replace Palo Verde with natural gas and renewables, although it would mainly be natural gas. Normally serious about addressing climate change, Steyer doesn’t seem to understand that renewables are supposed to replace fossil fuel, especially coal, not other low carbon sources like nuclear or hydro.

The three nuclear power reactors at Palo Verde produce about 36% of Arizona’s electricity, which is almost 80% of the state’s emission-free electricity (see figures). Palo Verde Nuclear Generating Station also uses 100% recycled water, and maintains a ‘Zero Discharge’ status – no water is discharged to rivers, streams or oceans.

Palo Verde is the biggest power plant in America, producing more energy than Grand Coulee Dam, which has the biggest nameplate capacity but only half the capacity factor of Palo Verde.

Nuclear from the state’s one nuclear power plant provides 79% of Arizona’s clean electricity, hydroelectric about 13%, solar and wind about 8%.

 EIA/Environmental Progress

EIA/Environmental Progress

Palo Verde produces enough energy to power 4 million people, over half of Arizona’s 7 million population, although some of it is exported out of state. In contrast, non-hydro renewables in Arizona, dominated by solar, generate about 4% of the state’s electricity. Coal produces about 25% and natural gas about 30%. So the clean energy produced in the state is overwhelmingly nuclear.

Palo Verde Nuclear Station                  32,800,000,000 kWhs/year

Arizona hydro power                               5,300,000,000 kWhs/year

Arizona non-hydro renewables             2,100,000,000 kWhs/year

Failure to reach this level of renewables by 2024, just as Palo Verde would be closing, ends up increasing natural gas dramatically. This also means solar would only be replacing another low-carbon energy source, nuclear, and would make no dent in replacing coal, let alone gas or oil.

The push to close Palo Verde assumes APS would end up with enough solar capacity to produce about 28 billion kWhs assuming a generous overall capacity factor of 30% for solar, although rooftop systems are less than 20%.

All of this is coming at the same time some states are looking to protect existing nuclear from these warped market forces. New Jersey, Connecticut and Minnesota are the latest states trying to prevent the premature closing of their nuclear power plants.

If Steyer’s initiative succeeds, Palo Verde will close in 2024, twenty years ahead of schedule. Palo Verde just got a 20-year extension from the U.S. Nuclear Regulatory Commission to run until 2045, so closing it early will throw away at least 700 billion kWhs of clean electricity, and would nullify the benefits of all renewable sources in Arizona.

If closed 5,000 jobs would be lost in Arizona and the largest single tax revenue for the locals and the state.

The Palo Verde reactors are actually good for over 80 years, as designed, especially as they are so well-maintained. The initial license period of 40 years, and relicensing every 20 years thereafter, were just arbitrary numbers decided upon by the original Atomic Energy Agency in the 1950s to make sure power plants would stay in compliance as regulations changed. Many nuclear plants have already applied for their second re-licensing, for a total of 80 years.  (Forbes, 4/18/2018)

Arizona, Ohio, Pennsylvania, New York & New Jersey Nuclear Power Crises

Eight nuclear power plants in five states are facing closure.  This represents an extreme emergency in terms of electricity production and clean air protection.


An Arizona ballot initiative could prematurely close the state’s sole nuclear plant, Palo Verde.   If the ballot initiative succeeds in the November 2018 election, Palo Verde will close in 2024 instead of in 2044, according to its operator, Arizona Public Service (APS).   The initiative would require 50 percent of Arizona’s electricity to come from renewable sources like solar and wind.  The initiative excludes nuclear from the clean energy mandate.  In order to accommodate such a large increase in intermittent energy from solar and wind, APS believes it would need to close Palo Verde and replace it with natural gas.  The Palo Verde Generating Station is the largest power plant in the United States by net generation

Nuclear’s importance is especially acute in the Pennsylvania, New Jersey and Maryland (PJM) Interconnection system, America’s largest competitive power market, spanning 13 states.

Ohio's FirstEnergy plans to close three of its nuclear plants in Ohio and Pennsylvania.  The three nuclear plants that FirstEnergy plans to shut down by 2021, plus Exelon’s Three Mile Island nuclear plant, which is scheduled to close next year, produced more energy than all of the wind and solar generation combined in PJM.

Illinois moved to compensate nuclear plants for their zero-carbon value.  New York has implemented a similar program.  Both states have adopted zero-carbon energy credits, in which the state issues credits to nuclear plants for generating carbon-free power, which they can sell on the open market to raise revenue.  Unfortunately, Indian Point nuclear power plant was left out of the New York program.  When it closes, replacement power will come from inner city plants, which will increase negative health effects in those communities.

New Jersey is proposing a zero carbon program similar to the Illinois and New York models.  EHJ's AAEA has testified at hearings in support of the legislation.  

Ohio considered a similar proposal, but it failed to advance, and no such mechanism exists in Pennsylvania, the two states where FirstEnergy’s closing plants operate.  Pennsylvania appears to be constrained by political considerations.  The election in November could be leaving legislators squeamish about advancing controversial energy legislation.  (Environmental ProgressWashington Examiner, 4/10/2018)

New Jersey Nuclear Power Support Legislation - S2313 & A3724


A3724 is the identical bill in the Assembly


This bill directs the Board of Public Utilities (board) to establish a Zero Emission Certificate (ZEC) program. Under the bill, a ZEC is a certificate, issued by the board or its designee, representing the fuel diversity, air quality, and other environmental attributes of one megawatt-hour of electricity generated by an eligible nuclear power plant selected by the board to participate in the ZEC program.

To participate in the ZEC program, a nuclear power plant is required to:  (1) be licensed to operate by the United States Nuclear Regulatory Commission by the date of enactment of this bill and through 2030 or later; (2) demonstrate to the satisfaction of the board that it makes a significant and material contribution to the air quality in the State by minimizing emissions that result from electricity consumed in New Jersey; (3) provide financial information to the board demonstrating that the plant will cease operations unless the nuclear power plant experiences a material financial change; (4) certify annually to the board that the nuclear power plant does not receive any direct or indirect payment or credit under a law of this State, or any other state, or a federal law, or a regional compact, that would eliminate the need for the nuclear power plant to retire prematurely, despite its reasonable best efforts to obtain any such payment or credit; and (5) submit an application fee to the board in an amount to be determined by the board, but which is not to exceed $250,000, to be used to defray the costs incurred by the board to administer the ZEC program.

The board is to determine the price of a ZEC each energy year under the formula provided in the bill.  Within 90 days after the conclusion of an energy year, each electric public utility (utility) in the State is required to pay each nuclear power plant that received ZECs for that prior energy year for the total number of ZECs received by the nuclear power plant multiplied by the percentage of electricity the utility distributed in the State as compared to other utilities in the State.

The board is to order the full recovery of all costs associated with the utility’s procurement of ZECs through a non-bypassable, irrevocable charge imposed on the retail distribution customers of the utility in the amount of $0.004 per kilowatt-hour.  This charge may be reduced by the board if certain conditions are met as specified in the bill.  Excess monies collected by utilities through the charge are to be refunded to their customers.

A nuclear power plant selected by the board to participate in the program is to initially receive ZECs through the end of the first energy year in which the plant was selected, plus an additional three energy years thereafter, and then is subject to review by the board triennially for renewed eligibility for additional, three energy year periods.

     A nuclear power plant selected by the board to participate in the program may suspend or cease operations under certain circumstances, including circumstances in which events prevent the selected nuclear power plant from continuing operations despite the plant’s reasonable efforts to continue operations.  If a selected nuclear power plant ceases operations during an eligibility period for any reason other than those specified in the bill, the plant is to pay a charge to the utilities that purchased ZECs from the selected nuclear power plant in an amount equal to the compensation received for the sale of ZECs since the board’s last determination of the selected nuclear power plant’s eligibility to receive ZECs.  A selected nuclear power plant would not be authorized to lay off personnel except for employee misconduct or underperformance issues.  Finally, the bill requires the board to conduct a study to evaluate the program within 10 years. 

First Energy To Close Nuclear Plants

FirstEnergy says it is getting out of the nuclear power business within the next three years. The company's power plant subsidiaries FirstEnergy Solutions and the FirstEnergy Nuclear Operating Co. late Wednesday informed the Nuclear Regulatory Commission and regional grid manager PJM Interconnection that it will close its nuclear power plants within three years.  The companies plan to close the Davis-Besse nuclear power plant near Toledo in 2020, and both the Perry nuclear plant in Lake County as well as the two-reactor Beaver Valley nuclear plant near Pittsburgh in 2021.

The companies made no mention of filing for bankruptcy.  Closing the nuclear plants years from today does nothing to alleviate the heavy debt FirstEnergy Solutions has amassed -- more than $2.8 billion to creditors and another $1.7 billion to the parent company FirstEnergy Corp.  FirstEnergy Solutions has a $100 million debt payment due in the first week of April.

The companies are still looking for a way to avoid an immediate bankruptcy if it can secure extra funding for its nuclear plants from Ohio and Pennsylvania. So far, lawmakers have ignored FirstEnergy's pleas for special nuclear subsidies.

With a total generating capacity of more than 4,000 megawatts, the three power plants in 2017 generated about two-thirds of the electricity that the companies produced. They also contributed more than $540 million in local taxes and provided jobs for about 2,300 people.

In 2016 the company began circulating a pamphlet among Ohio lawmakers proposing its nuclear plants get extra funding from customers -- $300 million extra annually -- because they don't produce any carbon dioxide. The "zero emission credits" were modeled on similar programs in Illinois and New York for certain nuclear plants.

Legislation creating the "ZECs" for FirstEnergy's plants has languished in House and Senate committees for more than a year. And Jones has said he thought bankruptcy would be unavoidable, though he has stressed such a decision would be up to FirstEnergy Solutions, and not the parent company.  (Cleveland.com, 3/28/2018)

Vermont Yankee Sale

Entergy, NorthStar Reach Settlement Agreement with State of Vermont and Other Parties on Terms for the Approval of the Sale of Vermont Yankee

Entergy Corporation and NorthStar Group Services Inc. announced today they have signed a settlement agreement and Memorandum of Understanding (MOU) with State of Vermont agencies and other interested parties on terms for approval of the proposed sale this year of Entergy Nuclear Vermont Yankee, the entity that owns the Vermont Yankee Nuclear Power Station located in Vernon, Vermont.

The agreement and MOU are significant milestones in the approval of the proposed transaction. If the transaction is approved by the Vermont Public Utility Commission (PUC), it will accelerate the decommissioning of Vermont Yankee by decades and facilitate the eventual economic redevelopment of the site. 

The Vermont agencies signing the agreement, in whole or in part, are: the Department of Public Service (DPS), the Agency of Natural Resources (ANR), the Department of Health, and the Attorney General’s Office.  The following parties have also signed the agreement: the Town of Vernon Planning and Economic Development Commission, the Windham Regional Commission, the Abenaki Nation of Missisquoi and the Elnu Abenaki Tribe, and the New England Coalition on Nuclear Pollution (NEC). The parties have submitted an MOU to the PUC based on the settlement agreement that reflects: (1) increased financial assurances beyond those included in the original proposal filed by Entergy and NorthStar with the PUC in December 2016 and (2) the establishment of site restoration standards to which NorthStar will adhere as it completes the decommissioning of the site. 

 Vermont Yankee

Vermont Yankee

Under Entergy’s original schedule, as outlined in its Post Shutdown Decommissioning Activities Report filed with the NRC in December 2014, Entergy expected to initiate decontamination and dismantlement of the Vermont Yankee site in 2068, with projected completion of both decommissioning and site restoration by 2075.  Under the proposed transaction, NorthStar has committed to initiate decontamination and dismantlement by 2021 (and potentially as early as 2019) and to complete decommissioning and restoration of the Vermont Yankee site, with the exception of the ISFSI and other structures identified above, by 2030 (and potentially as early as 2026).  (Entergy Press Release, 3/2/2018)

2-Year Budget Bill Extends Nuclear Production Tax Credit

The 2-year budget bill passed last night extends the Nuclear Production Tax Credit.

The 2005 Energy Policy Act provided a tax credit of 1.8 cents per kilowatt-hour for electricity produced from new reactors, but set a deadline of 2020 for the plants to be in service. The new bill removes that deadline, which would ensure that the two Westinghouse AP1000 reactors being built at Southern Nuclear Operating Company's Vogtle site in Georgia could benefit from the credit. 

 EHJ President Norris McDonald at signing of Energy Policy Act of 2005

EHJ President Norris McDonald at signing of Energy Policy Act of 2005

[Note: The Center worked diligently for the passage of the Energy Policy Act of 2005, and particularly for the inclusion of the Nuclear Production Tax Crecit, and was invited to attend the signing of the legislation as a Special Guest of The White House in Albuquerque, New Mexico].

Unforeseen events—the Chapter 11 filing by Westinghouse, regulatory delays associated with first-of-a-kind engineering projects, and Fukushima—will result in the units coming online after 2020, therefore missing the opportunity to receive the PTC.

The tax credit is applicable to the first 6,000 megawatts of new nuclear capacity that come online. The completion of Vogtle 3 and 4 will leave a significant amount of remaining capacity that future small modular or advanced reactor projects will be able to access.

The small modular reactor design closest to construction is from NuScale Power LLC, which in January became the first to submit a design certification application to the U.S. Nuclear Regulatory Commission. NuScale plans to build a first commercial power plant at the U.S. Department of Energy’s Idaho National Laboratory, owned by Utah Associated Municipal Power Systems and operated by Washington state-based utility Energy Northwest. It is expected to begin commercial operations by 2026.  (NEI, 11/2/2017, Background/NEI, Greentech Media, 2/9/2018)