Nuclear power screwed by new rules? EPA Public comment deadline Dec 1

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Eregos: Aug 17, 2006; A Reversal of Fortune, Perhaps?

The public comment period for new EPA rules on carbon pollution ends 11:59pm Dec 1st. I�m busy and wish I had more time to study this but wanted to bring it to public attention nonetheless since the deadline is tomorrow. You can comment here, just open the federal eRuleMaking portal in a new tab.

As discussed on: http://ansnuclearcafe.org/2014/08/20/unintend-consequences-lurking-in-epa-clean-power-plan/

Having read the entire post and the comments, I�m still unsure of how large of a problem this is. It does seem safe to urge the EPA to calculate carbon intensity treating all sources equally.

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.�

TL;DR Either this is no big deal, or a potential regulatory disaster that some natural gas lobbyist managed to slip in that will massively kill America's nuclear power industry. Last chance to comment is Dec 1.

# ? Dec 1, 2014 01:56

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# ? Apr 26, 2024 05:20

Phyzzle: Jan 26, 2008

It doesn't seem so unfair: pre-existing wind farms and solar generators count for zero percent change. The regulation would set certain pre-existing nuclear plants as counting for 5.8% change.

Those are plants that are announced as closing. So if a closing of a plant is reversed, and it's left running, is that "new" generation? 5.8% was a compromise, but it's all pretty arbitrary.

# ? Dec 1, 2014 04:47

Eregos: Aug 17, 2006; A Reversal of Fortune, Perhaps?

As I understand it that's wrong. Pre-existing solar and wind farms count for 100% of their contribution
If Remy and Justin's interpretation is correct, it is very unfair.

The problem comes when nuclear plants are looked at as part of a MIX of the current production in a state.

So if that's 30% coal, 40% nat gas, 25 % nuclear and 5% wind that means replacing a nuclear power plant with a natural gas power plant would result in the following:

COAL: 30% * 1.0 +
NATURAL GAS: 40% * -.5 +
NUCLEAR 25% * 5.8% * -1
(Replaced percent of the total MW capacity in the state)
WOULD BE GREATER THAN 100% natural gas
100% * -.5

Those aren't the exact numbers, they haven't determined them yet actually. The point is that replacing a nuclear power plant with a natural gas power plant would always make sense from an emissions standpoint as long as the current average emissions per MW is greater than that of natural gas.

Another blog post discussing the topic: http://atomicinsights.com/atomic-show-222-proposed-epa-co2-rule-rewards-states-replacing-nuclear-gas/

Eregos fucked around with this message at 00:03 on Dec 2, 2014

# ? Dec 1, 2014 23:50

Phyzzle: Jan 26, 2008

Eregos posted:

As I understand it that's wrong. Pre-existing solar and wind farms count for 100% of their contribution
If Remy and Justin's interpretation is correct, it is very unfair.

But the regulation proposal being looked at says,

quote:

1. Proposed Quantification of Renewable Energy Generation

To estimate the CO2 emission
reductions from affected EGUs
achievable based on increases in
renewable generation, the EPA has
developed a ��best practices�� scenario
for renewable energy generation based
on the RPS requirements already
established by a majority of states.

# ? Dec 2, 2014 00:39

Eregos: Aug 17, 2006; A Reversal of Fortune, Perhaps?

Yeah the concern was never about EPA's stated top-line intentions, but rather the actual calculations buried deep in other documents and implementation plans.

The comment deadline just expired. I just pray this issue not getting more attention doesn't come back to bite the nuclear power industry later.

These guys went out of their way to comment and explain this to the EPA, Hopefully if there was a mistake made that helped correct it.

# ? Dec 2, 2014 06:18

Trabisnikof: Dec 24, 2005

Eregos posted:

These guys went out of their way to comment and explain this to the EPA, Hopefully if there was a mistake made that helped correct it.

Yeah, those poor grad students filing official comments with the EPA. :rolleyes:

(That's pretty much resume building poo poo for them.)

The Brookings Institute reads the potential rule the other way, benefiting nuclear:

quote:

The EPA estimates that 5.8% of the current nuclear power fleet is �at risk� of being retired between now and 2030. To encourage states not to close these plants, EPA includes this 5.8% as part of the denominator of the formula, allowing states that choose to keep nuclear plants open to be credited for maintaining this zero-emissions power source. That means that states with nuclear plants but no plans to retire them are essentially treated as already having made progress. The EPA adds megawatt hours reflecting 5.8% of a state�s nuclear fleet, along with any megawatt hours for under construction nuclear plants, to the denominator of the formula, resulting in the following version of the formula, where the subscript AR means nuclear generation at risk and UC means nuclear generation under construction.

(http://www.brookings.edu/~/media/blogs/fixgov/2014/07/epa%20clean%20power%20plan_appendix.pdf)

Remember, new nuclear power plants still count 100% so can't have a negative impact on building new plants.

# ? Dec 2, 2014 07:50

Main Paineframe: Oct 27, 2010

Keeping open nuclear plants that were already scheduled to close sounds like bad policy to me, anyway. Sure, nuclear is good, but context is important. Most plants in the US are forty-plus years old; their designs are terribly outdated and many of them have been operating longer than they were originally designed to be able to. As we bring new capacity online with safer and hardier modern designs, we really should be retiring some of the older plants. Although NIMBYism does influence nuclear plant closures, odds are good that at least some of those plants up for closing really ought to be put to rest.

# ? Dec 2, 2014 16:43

CommieGIR: Aug 22, 2006; The blue glow is a feature, not a bug; Pillbug

Main Paineframe posted:

Keeping open nuclear plants that were already scheduled to close sounds like bad policy to me, anyway. Sure, nuclear is good, but context is important. Most plants in the US are forty-plus years old; their designs are terribly outdated and many of them have been operating longer than they were originally designed to be able to. As we bring new capacity online with safer and hardier modern designs, we really should be retiring some of the older plants. Although NIMBYism does influence nuclear plant closures, odds are good that at least some of those plants up for closing really ought to be put to rest.

The problem being that cheap solutions such as natural gas are offsetting any desire to build new Gen III plants outside of the one TVA is building, and Fukushima induced fear mongering is taking care of the rest.

Yes, we need new plants, but nobody has any reason to build them if there are cheaper (and dirtier) alternatives.

# ? Dec 2, 2014 16:45

Trabisnikof: Dec 24, 2005

CommieGIR posted:

The problem being that cheap solutions such as natural gas are offsetting any desire to build new Gen III plants outside of the one TVA is building, and Fukushima induced fear mongering is taking care of the rest.

Yes, we need new plants, but nobody has any reason to build them if there are cheaper (and dirtier) alternatives.

If you take a look at the EPA's documents you'll find that even the 2030 target goals on a co2/kwh basis are above the average emissions of a new combined cycle gas plant, coal sucks that bad.

You're correct there is only 1 Gen III plant under construction but there are also 4 Gen III+ plants (AP1000) under construction in the US too.

# ? Dec 2, 2014 18:55

Elotana: Dec 12, 2003; and i'm putting it all on the goddamn expense account

Trabisnikof posted:

The EPA adds megawatt hours reflecting 5.8% of a state�s nuclear fleet, along with any megawatt hours for under construction nuclear plants, to the denominator of the formula, resulting in the following version of the formula, where the subscript AR means nuclear generation at risk and UC means nuclear generation under construction.

This makes no sense. If you're predicting 5.8% of the nuclear fleet to be "at risk" of retirement, then surely the correct coefficient for the denominator is 94.2%. MWh not at risk it should be treated the same as the under-construction plants.

# ? Dec 2, 2014 19:18

CommieGIR: Aug 22, 2006; The blue glow is a feature, not a bug; Pillbug

Trabisnikof posted:

You're correct there is only 1 Gen III plant under construction but there are also 4 Gen III+ plants (AP1000) under construction in the US too.

Most of the construction permits are being dragged out to ensure that they never happen.

quote:

In August 2012, the US Court of Appeals for the District of Columbia found that the NRC's rules for the temporary storage and permanent disposal of nuclear waste stood in violation of the National Environmental Policy Act, rendering the NRC legally unable to grant final licenses for any further new nuclear power plants.[171] This ruling was based on the fact that the Yucca Mountain waste repository had never received a license due to its license application being withdrawn by the DOE nor had any viable alternative waste repository been proposed. So long as this ruling stands and this impasse on waste disposal exists, no additional nuclear plants can ever be licensed for operation in the United States.

We're still stuck here.

CommieGIR fucked around with this message at 19:42 on Dec 2, 2014

# ? Dec 2, 2014 19:25

Trabisnikof: Dec 24, 2005

Elotana posted:

This makes no sense. If you're predicting 5.8% of the nuclear fleet to be "at risk" of retirement, then surely the correct coefficient for the denominator is 94.2%. MWh not at risk it should be treated the same as the under-construction plants.

The goal is reducing emissions so getting credit for existing nuclear plants is a bonus to keep them online. How do existing nuclear plants help reduce emissions from the status quo in the same way as a new plant would?

CommieGIR posted:

Most of the construction permits are being dragged out to ensure that they never happen.

Not for those 5 plants under construction:

Watts Bar 2: on schedule as of Nov 2014 (http://www.tva.gov/power/nuclear/pdf/wb2_9th-q_summary_nov2014.pdf)

Vogtle 3 & 4: under construction, building main containment building as of Nov 2014 (http://www.southerncompany.com/what-doing/energy-innovation/nuclear-energy/gallery/new/)

V.C. Summers 1 & 2: under construction, delayed 1-2 years due to fabrication issues (http://www.scana.com/NR/rdonlyres/CC6965BC-FFE3-4080-914C-1BFFE858EFE7/0/BLRA3Q2014.pdf)

You might be confusing the proposed plants with these 5 that actually are being built.

# ? Dec 2, 2014 19:44

CommieGIR: Aug 22, 2006; The blue glow is a feature, not a bug; Pillbug

Trabisnikof posted:

Not for those 5 plants under construction:

Watts Bar 2: on schedule as of Nov 2014 (http://www.tva.gov/power/nuclear/pdf/wb2_9th-q_summary_nov2014.pdf)

Vogtle 3 & 4: under construction, building main containment building as of Nov 2014 (http://www.southerncompany.com/what-doing/energy-innovation/nuclear-energy/gallery/new/)

V.C. Summers 1 & 2: under construction, delayed 1-2 years due to fabrication issues (http://www.scana.com/NR/rdonlyres/CC6965BC-FFE3-4080-914C-1BFFE858EFE7/0/BLRA3Q2014.pdf)

You might be confusing the proposed plants with these 5 that actually are being built.

Possibly, but I knew me and my Physics professor were looking over the proposals that are currently stuck in court.

# ? Dec 2, 2014 19:45

Trabisnikof: Dec 24, 2005

CommieGIR posted:

Possibly, but I knew me and my Physics professor were looking over the proposals that are currently stuck in court.

Agreed that there are more far more proposals than the 5 under construction, but there are 5 under construction.

Also, to the issue of storage, the NRC just finalized the rule-making response to the court case, which will remove that specific blocking point: http://public-blog.nrc-gateway.gov/2014/07/24/waste-confidence-final-rule-now-before-the-commission/

If you want the finalized rule it is here:

http://www.nrc.gov/waste/spent-fuel-storage/wcd/documents.html

Surprisingly wikipedia isn't up to date.

# ? Dec 2, 2014 19:49

CommieGIR: Aug 22, 2006; The blue glow is a feature, not a bug; Pillbug

Trabisnikof posted:

Agreed that there are more far more proposals than the 5 under construction, but there are 5 under construction.

Also, to the issue of storage, the NRC just finalized the rule-making response to the court case, which will remove that specific blocking point: http://public-blog.nrc-gateway.gov/2014/07/24/waste-confidence-final-rule-now-before-the-commission/

If you want the finalized rule it is here:

http://www.nrc.gov/waste/spent-fuel-storage/wcd/documents.html

Surprisingly wikipedia isn't up to date.

Finally! Thanks for the link, I'll share that with him.

# ? Dec 2, 2014 19:50

Elotana: Dec 12, 2003; and i'm putting it all on the goddamn expense account

Trabisnikof posted:

The goal is reducing emissions so getting credit for existing nuclear plants is a bonus to keep them online. How do existing nuclear plants help reduce emissions from the status quo in the same way as a new plant would?

Either I'm missing something here or you are. The Brookings Institute says that the purpose of the coefficient is to give them extra credit, but that's not what I see when I do the math. The goals are calculated using current emissions mixes as a baseline. Coal and natgas are in the denominator of the goal mix at 100% (+/- the redispatch coefficient, but that will skew things even farther towards natgas). Nuclear is the only technology given special treatment in the denominator.

Let's take the state of Freedonia as an example. Freedonia produces 20 TWh of power, 9 TWh from coal, 9 TWh from installed nuclear, 1 TWh from natgas, and 1 TWh from renewables. To make a further simplifying assumption, we'll say that Freedonia's natgas plants are already running at 70% capacity to avoid calculating redispatch, and that Freedonia is in the North Central US, so their renewables growth potential is 6% compounded 13 years.

According to page 4, their emissions goal is going to be something like this

code:

      (2,120 * 9,000,000) + (810 * 1,000,000)
-------------------------------------------------------
9,000,000 + 1,000,000 + 522,000 + 2,133,000 + 2,000,000

Where the 522 GWh is 5.8% of nuclear, the 2.133 TWh is their compounded renewable growth goal, and the last 2 TWh is the energy efficiency denomination of 10% of capacity. This yields a goal of 1,357 lbs/MWh.

Now let's say Freedonia's energy consumption grows to 22TWh of power. They do absolutely nothing except rip up their existing nuclear and replace it with natgas, and meet all new demand with natgas. Freedonia now has 9TWh from coal, 12 TWh from natgas, and 1 TWh from renewables.

code:

(2,120 * 9,000,000) + (810 * 12,000,000)
----------------------------------------
  9,000,000 + 12,000,000 + 1,000,000

1,309 lbs/MWh! Congratulations, Freedonia!

If you put nuclear in the goal denominator at only 5.8%, it means any state with large amounts of coal and nuclear but not a lot of natgas can get massive emissions reductions on paper because natgas, while still emitting, has a lower emissions profile than coal and gets full credit in the denominator. While I grossly simplified for the purposes of the example, Freedonia is basically Illinois (one of the states cited by the nuke bloggers as victims of this calculation).

Elotana fucked around with this message at 21:03 on Dec 2, 2014

# ? Dec 2, 2014 20:58

Trabisnikof: Dec 24, 2005

Elotana posted:

Either I'm missing something here or you are. The Brookings Institute says that the purpose of the coefficient is to give them extra credit, but that's not what I see when I do the math. The goals are calculated using current emissions mixes as a baseline. Coal and natgas are in the denominator of the goal mix at 100% (+/- the redispatch coefficient, but that will skew things even farther towards natgas). Nuclear is the only technology given special treatment in the denominator.

I think you're missing the point of this whole formula, which is to calculate the emissions level not to evaluate it. This forumula is how the EPA decides what emissions reductions are possible, not how they evaluate future emissions.

Here's another report from Brattle consulting that goes into the details of the process here:

quote:

The EPA uses a formulaic approach to estimate the emission reduction achievable by each state from the four building blocks. In Figure 2, we illustrate the formula for calculating the emissions standard and the relative impact of the building blocks on an aggregate national basis.6 The starting point for the calculation is the average 2012 emissions rate of all fossil-fired EGUs, expressed as their aggregate CO2 output divided by their aggregate generation in MWh. We then apply EPA�s assumed impact of each of the building blocks sequentially to arrive at the national proposed EGU CO2 emissions standard for 2030. The first two building blocks, improving coal plant efficiency and re-dispatching away from coal toward gas, reduce the emissions rate by reducing the quantity of CO2 in the rate numerator.

Then, we apply the EPA�s estimated impacts from nuclear, renewables, and hydro generation capacity in the proposed BSER, which complicates the �emissions rate� because some of these resources are treated as zero-emissions supply that reduce the rate by increasing the denominator, while other zero-emitting supplies are excluded from the formula. The existing and potential new zero-emitting resources considered in the rate calculation include: (a) all nuclear currently under construction, as well as an assumed 5.8% of all existing nuclear considered �at risk� for retirement (applied uniformly to all states, rather than specifying which existing plants are deemed at risk), but excluding the remaining 94.2% of existing nuclear; (b) existing renewables (with the exception of existing hydro), new renewables, and new hydro, with the existing renewables qualified in order to give credit to early adopters of renewable generation; and (c) future energy efficiency savings, based on an analysis of the current load reduction rates achieved by the 12 leading states deploying EE programs.

(http://www.brattle.com/system/publi....pdf?1403791723)

The baseline is fossil fuel emissions currently, which nuclear is credited as reducing by 5.8% of total generation just because they could turn off the borderline nukes and we'd have to replace them with fossil fuels. Nuclear power plants aren't actually reducing current fossil fuel emissions at all of course, but they get a credit because keeping boardline plants on would prevent the need for more fossil fuel use.

If a state offlined nukes and onlined fossil fuel plants to replace them, they'd still have to meet the baseline of current fossil fuel emissions not a baseline based on future emissions.

Trabisnikof fucked around with this message at 21:31 on Dec 2, 2014

# ? Dec 2, 2014 21:22

Elotana: Dec 12, 2003; and i'm putting it all on the goddamn expense account

Trabisnikof posted:

I think you're missing the point of this whole formula, which is to calculate the emissions level not to evaluate it. This forumula is how the EPA decides what emissions reductions are possible, not how they evaluate future emissions.

That's why I used the emissions rate formula from page 1 of the Brookings report to calculate the actual future mix, not the goal formula.

Trabisnikof posted:

If a state offlined nukes and onlined fossil fuel plants to replace them, they'd still have to meet the baseline of current fossil fuel emissions not a baseline based on future emissions.

And since the baseline is lbs/MWh rather than just lbs, a state with a currently high mix of coal can do just that by replacing the nuclear with natgas.

Elotana fucked around with this message at 21:32 on Dec 2, 2014

# ? Dec 2, 2014 21:26

Trabisnikof: Dec 24, 2005

Elotana posted:

And since the baseline is lbs/MWh rather than just lbs, a state with a currently high mix of coal can do just that by replacing the nuclear with natgas.

uh no, they can't?

Replacing nuclear with natgas would increase lbs/MWh of fossil fuel emissions and they'd have to makeup the increased emissions from the natgas elsewhere.

Replacing coal with natgas works perfectly fine to meet these goals however.

Edit: Even the Nuclear Energy Institute doesn't think the rule will do what this thread is about, instead they just think the rule doesn't help nuclear enough: http://www.nei.org/News-Media/News/News-Archives/Despite-Intent,-EPA-Climate-Rule-Methodology-Wrong

I do get the complaint about the at-risk % not being calculated at a state level and also the complaint about under-construction counting at all although I still think this is much ado about nothing from the nuclear industry.

Trabisnikof fucked around with this message at 21:41 on Dec 2, 2014

# ? Dec 2, 2014 21:34

Elotana: Dec 12, 2003; and i'm putting it all on the goddamn expense account

Trabisnikof posted:

Replacing nuclear with natgas would increase lbs/MWh of fossil fuel emissions

No, it would increase lbs/MWh of overall emissions. The fossil fuel emissions would go down in terms of lbs/MWh. And neither are being calculated by this goal formula, per your own second source:

quote:

The 2030 emissions standard formula in Figure 2 differs from typical measures of emissions rates; it represents neither the fossil fleet emissions rate (emissions divided by generation from the fossil fleet) nor the emissions rate of the entire generation fleet (emissions divided by all power generation regardless of source fuel). Instead, the EGU CO2 emissions standard is calculated as the ratio of expected future emissions after implementing the assumed building blocks, divided by the sum of fossil, renewables, and new or �at-risk� nuclear generation (excluding existing hydro and the majority of nuclear) plus generation avoided through energy efficiency.

Why is only nuclear reduced by "new or at-risk?" The denominator only counts MWh from new nuke plants or plants unexpectedly kept online. That is, if a nuke plant already exists, and we expect it to still exist in 2030, it doesn't get counted. But it counts every MWh for fossils, and for non-hydro renewables. If a wind farm exists, and we expect it to still exist in 2030, why does it get credit in the denominator but a nuke plant doesn't?

Elotana fucked around with this message at 21:58 on Dec 2, 2014

# ? Dec 2, 2014 21:56

Trabisnikof: Dec 24, 2005

Elotana posted:

No, it would increase lbs/MWh of overall emissions. The fossil fuel emissions would go down in terms of lbs/MWh. And neither are being calculated by this goal formula, per your own second source:

Ah I think I've determined the disconnect. The calculation is for [lbs of emissions from fossil fuels]/[total MWh]. It is a wonky measure to be sure but is why you can't just replace nuclear plants with natgas plants and have the formula work.

Elotana posted:

Why is only nuclear reduced by "new or at-risk?" The denominator only counts MWh from new nuke plants or plants unexpectedly kept online. That is, if a nuke plant already exists, and we expect it to still exist in 2030, it doesn't get counted. But it counts every MWh for fossils, and for non-hydro renewables. If a wind farm exists, and we expect it to still exist in 2030, why does it get credit in the denominator but a nuke plant doesn't?

Check out that Brattle chart it helps explain the difference in the way fossil fuels and everything else is being calculated. Fossil fuels are in the denominator as a positive while at-risk current nuclear, current non-hydro renewables, etc are negatives. Since current nuclear isn't actually reducing future fossil fuel use the at risk nuclear plants are factored in as a potential future need for fossil fuels that can be avoided.

Notice that the NEI didn't argue that the % should be increased to 100%, instead they argued that the EPA should convince/force states to agree to keep plants online. The 5.8% is actually a boon to nuclear operators, even if it isn't everything they wanted.

# ? Dec 2, 2014 22:13

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# ? Apr 26, 2024 05:20

Elotana: Dec 12, 2003; and i'm putting it all on the goddamn expense account

Trabisnikof posted:

Ah I think I've determined the disconnect. The calculation is for [lbs of emissions from fossil fuels]/[total MWh]. It is a wonky measure to be sure but is why you can't just replace nuclear plants with natgas plants and have the formula work.

No, that's not the calculation. If [total MWh] were the denominator then existing nuclear and hydro wouldn't be excluded from the denominator.

Here's the EPA's own explanation: http://www2.epa.gov/sites/production/files/2014-06/documents/20140602tsd-goal-computation.pdf

Look at Appendix 5. There is a column for total fossil, and there is a column for total fossil + renewables + new/at-risk nuclear. There is no column that includes installed nuclear or hydro in the denominator. And they are the only technologies treated this way in the goal formula. Renewables are not discounted in the denominator. Coal and natgas are not discounted in the denominator. What is the rationale for this? If you are claiming goals shouldn't "credit" nuclear that's already installed then why are they crediting non-hydro renewables already installed? Why are they not crediting hydro at all? Why treat any of these three things differently, from an emissions standpoint?

quote:

Check out that Brattle chart it helps explain the difference in the way fossil fuels and everything else is being calculated. Fossil fuels are in the denominator as a positive while at-risk current nuclear, current non-hydro renewables, etc are negatives.

They aren't treated this way in either the Brookings or the EPA sample calculations (done for MI and OH, respectively).

EDIT: Also it would make no sense to have them as negative in the denominator, because then any state with a majority of nuclear + renewables would have a negative emissions target. :v:

If your argument is going to come down to repeatedly gesturing at the Brattle chart and insisting that it must work the way they graphed it because surely they did the math and didn't take the EPA at their word, then just go ahead and say so.

Elotana fucked around with this message at 00:33 on Dec 3, 2014

# ? Dec 3, 2014 00:22

The Something Awful Forums > Discussion > Debate & Discussion > Nuclear power screwed by new rules? EPA Public comment deadline Dec 1