Tag Archives: clean

Confronting industrialism: if you can’t clean it up, don’t make it! Updated for 2026





Some of the most important questions confronting us are: what should we do about this culture’s industrial wastes, from greenhouse gases to pesticides to ocean microplastics?

Can the capitalists clean up the messes they create? Or is the whole industrial system beyond reform? The answers become clear with a little context.

Let’s start the discussion of context with two riddles that aren’t very funny.

Q: What do you get when a cross a long drug habit, a quick temper, and a gun?
A: Two life terms for murder, with earliest release date 2026.

And,

Q: What do you get when you cross a large corporation, two nation states, 40 tons of poison, and at least 8,000 dead human beings?
A: Retirement with full pay and benefits. Warren Anderson, CEO of Union Carbide. Bhopal.

The point of these riddles is not merely that when it comes to murder and many other atrocities, different rules apply to the poor than to the rich. And it’s not merely that ‘economic production’ is a get-out-of-jail free card for whatever atrocities the ‘producers’ commit, whether it’s genocide, gynocide, ecocide, slaving, mass murder, mass poisoning, and so on.

Do we even care? We already know they don’t …

The point here is that this culture is clearly not particularly interested in cleaning up its toxic messes. Obviously, or it wouldn’t keep making them. It wouldn’t allow those who make these messes to do so with impunity. It certainly wouldn’t socially reward those who make them.

This may or may not be the appropriate time to mention that this culture has created, for example, 14 quadrillion (yes, quadrillion) lethal doses of Plutonium 239, which has a half-life of over 24,000 years, which means that in a mere 100,000 years that number will be all the way down to only about 3.5 quadrillion lethal doses: Yay!

And socially reward them it does. I could have used a whole host of examples other than Warren Anderson, who was playing on the back nine long after he should have been hanging by the neck (he was sentenced to death in absentia, but the US refused to extradite him).

There’s Tony Hayward, who oversaw BP’s devastation of the Gulf of Mexico and who was ‘punished’ for this with a severance package worth well over $30 million. Or we could throw another couple of riddles at you, which are really the same riddles:

Q: What do you call someone who puts poison in the subways of Tokyo?
A: A terrorist.

Q: What do you call someone who puts poison (cyanide) into groundwater?
A: A capitalist: CEO of a gold mining corporation.

We could talk about frackers, who make money as they poison groundwater. We could talk about anyone associated with Monsanto. You can add your own examples. I’d say you can ‘choose your poison’ but of course you can’t. Those are chosen for you by those doing the poisoning.

Civilization’s ability to overcome our native common sense

I keep thinking about one of the most fundamentally sound (and fundamentally disregarded) statements I’ve ever read. After Bhopal, one of the doctors trying to help survivors stated that corporations (and by extension, all organizations and individuals) “shouldn’t be permitted to make poison for which there is no antidote.”

Please note, by the way, that far from having antidotes, nine out of ten chemicals used in pesticides in the US haven’t even been thoroughly tested for (human) toxicity.

Isn’t that something we were all supposed to learn by the time we were three? Isn’t it one of the first lessons our parents are supposed to teach us? Don’t make a mess you can’t clean up!

Yet that is precisely the foundational motivator of this culture. Sure, we can use fancy phrases to describe the processes of creating messes we have no intention of cleaning up, and in many cases cannot clean up.

And so we get phrases like ‘developing natural resources’, or ‘sustainable development’, or ‘technological progress’ (like the invention and production of plastics, the bathing of the world in endocrine disruptors, and so on), or ‘mining’, or ‘agriculture’, or ‘the Green Revolution’, or ‘fueling growth’, or ‘creating jobs’, or ‘building empire’, or ‘global trade’.

But physical reality is always more important than what we call it or how we rationalize it. And the truth is that this culture has been based from the beginning to the present on privatizing benefits and externalizing costs. In other words, on exploiting others and leaving messes behind.

Hell, they call them ‘limited liability corporations’ because a primary purpose is to limit the legal and financial liability of those who benefit from the actions of corporations for the harm these actions cause.

Internalizing insanity

This is no way to run a childhood, and it’s an even worse way to run a culture. It’s killing the planet. Part of the problem is that most of us are insane, having been made so by this culture. We should never forget what RD Laing wrote about this insanity:

“In order to rationalize our industrial-military complex [and I would say this entire way of life, including the creation of messes we have neither the interest nor capacity to clean up], we have to destroy our capacity to see clearly any more what is in front of, and to imagine what is beyond, our noses. Long before a thermonuclear war can come about, we have had to lay waste to our own sanity.

“We begin with the children. It is imperative to catch them in time. Without the most thorough and rapid brainwashing their dirty minds would see through our dirty tricks. Children are not yet fools, but we shall turn them into imbeciles like ourselves, with high IQs, if possible.”

We’ve all seen this too many times. If you ask any reasonably intelligent seven-year-old how to stop global warming caused in great measure by the burning of oil and gas and by the destruction of forests and prairies and wetlands, this child might well say, “Stop burning oil and gas, and stop destroying forests and prairies and wetlands!”

If you ask a reasonably intelligent thirty-year-old who works for a ‘green’ high tech industry, you’ll probably get an answer that primarily helps the industry that pays his or her salary.

Part of the brainwashing process of turning us into imbeciles consists of getting us to identify more closely with-and care more about the fate of-this culture rather than the real physical world. We are taught that the economy is the ‘real world’, and the real world is merely a place from which to steal and on which to dump externalities.

Does nature have to adapt to us? Or us to nature?

Most of us internalize this lesson so completely that it becomes entirely transparent to us. Even most environmentalists internalize this. What do most mainstream solutions to global warming have in common? They all take industrialism as a given, and the natural world as having to conform to industrialism.

They all take empire as a given. They all take overshoot as a given. All of this is literally insane, in terms of being out of touch with physical reality. The real world must always be more important than our social system, in part because without a real world you can’t have any social system whatsoever. It’s embarrassing to have to write this.

Upton Sinclair famously said that it’s hard to make a man understand something, when his job depends on him not understanding it.

I would add that it’s hard to make people understand something when the benefits they accrue through their exploitative and destructive way of life depend on it. So we suddenly get really stupid about the waste products produced by this culture.

When people ask how we can stop polluting the oceans with plastic, they don’t really mean, “How can we stop polluting the oceans with plastic?” They mean, “How can we stop polluting the oceans with plastic and still have this way of life?”

And when they ask how we can stop global warming, they really mean, “How can we stop global warming without stopping this level of energy usage?”. When they ask how we can have clean groundwater, they really mean, “How can we have clean groundwater while we continue to use and spread all over the environment thousands of useful but toxic chemicals that end up in groundwater?”

The answer to all of these is: you can’t.

First we must recover our sanity. Then we must act

As I’ve been writing this essay about the messes caused by this culture, there’s an allegorical image I can’t get out of my mind. It’s of a half-dozen Emergency Medical Technicians putting bandages on a person who has been assaulted by a knife-wielding psychopath.

The EMTs are trying desperately to stop this person from bleeding out. It’s all very tense and suspenseful as to whether they’ll be able to staunch the flow of blood before the person dies.

But here’s the problem: as these EMTs are applying bandages as fast as they can, the psychopath is continuing to stab the victim. Worse, the psychopath is making wounds faster than the EMTs are able to bandage them. And the psychopath is paid very well for stabbing the victim, while most of the EMTs are bandaging in their spare time.

And in fact the health of the economy is based on how much blood the victim loses – as in this culture, where economic production is measured by the conversion of living landbase into raw materials, e.g., living forests into two-by-fours, living mountains into coal.

How do we stop the victim from bleeding out? Any child can tell you. And any sane person who cares more about the health of the victim than the health of the economy that is based on dismembering the victim can tell you. The first thing you need to do is stop the stabbing. No amount of bandages will make up for an assault that is ongoing, indeed, one that is accelerating.

What do we do about this culture’s fabrication of industrial wastes? The first step is stop their production. Actually the first step is that we regain our sanity, that is, we transfer our loyalty away from the psychopaths, and toward the victim, toward, in this case, the planet that is our only home.

Once we do that, everything else is technical. How do we stop them? We stop them.

 


 

Derrick Jensen is Member of the Steering Committee of Deep Green Resistance. See more details. Read Derrick Jensen’s blog.

Also on The Ecologist:Reclaim Environmentalism!’ by Derrick Jensen & Lierre Keith.

 

 




390964

Confronting industrialism: if you can’t clean it up, don’t make it! Updated for 2026





Some of the most important questions confronting us are: what should we do about this culture’s industrial wastes, from greenhouse gases to pesticides to ocean microplastics?

Can the capitalists clean up the messes they create? Or is the whole industrial system beyond reform? The answers become clear with a little context.

Let’s start the discussion of context with two riddles that aren’t very funny.

Q: What do you get when a cross a long drug habit, a quick temper, and a gun?
A: Two life terms for murder, with earliest release date 2026.

And,

Q: What do you get when you cross a large corporation, two nation states, 40 tons of poison, and at least 8,000 dead human beings?
A: Retirement with full pay and benefits. Warren Anderson, CEO of Union Carbide. Bhopal.

The point of these riddles is not merely that when it comes to murder and many other atrocities, different rules apply to the poor than to the rich. And it’s not merely that ‘economic production’ is a get-out-of-jail free card for whatever atrocities the ‘producers’ commit, whether it’s genocide, gynocide, ecocide, slaving, mass murder, mass poisoning, and so on.

Do we even care? We already know they don’t …

The point here is that this culture is clearly not particularly interested in cleaning up its toxic messes. Obviously, or it wouldn’t keep making them. It wouldn’t allow those who make these messes to do so with impunity. It certainly wouldn’t socially reward those who make them.

This may or may not be the appropriate time to mention that this culture has created, for example, 14 quadrillion (yes, quadrillion) lethal doses of Plutonium 239, which has a half-life of over 24,000 years, which means that in a mere 100,000 years that number will be all the way down to only about 3.5 quadrillion lethal doses: Yay!

And socially reward them it does. I could have used a whole host of examples other than Warren Anderson, who was playing on the back nine long after he should have been hanging by the neck (he was sentenced to death in absentia, but the US refused to extradite him).

There’s Tony Hayward, who oversaw BP’s devastation of the Gulf of Mexico and who was ‘punished’ for this with a severance package worth well over $30 million. Or we could throw another couple of riddles at you, which are really the same riddles:

Q: What do you call someone who puts poison in the subways of Tokyo?
A: A terrorist.

Q: What do you call someone who puts poison (cyanide) into groundwater?
A: A capitalist: CEO of a gold mining corporation.

We could talk about frackers, who make money as they poison groundwater. We could talk about anyone associated with Monsanto. You can add your own examples. I’d say you can ‘choose your poison’ but of course you can’t. Those are chosen for you by those doing the poisoning.

Civilization’s ability to overcome our native common sense

I keep thinking about one of the most fundamentally sound (and fundamentally disregarded) statements I’ve ever read. After Bhopal, one of the doctors trying to help survivors stated that corporations (and by extension, all organizations and individuals) “shouldn’t be permitted to make poison for which there is no antidote.”

Please note, by the way, that far from having antidotes, nine out of ten chemicals used in pesticides in the US haven’t even been thoroughly tested for (human) toxicity.

Isn’t that something we were all supposed to learn by the time we were three? Isn’t it one of the first lessons our parents are supposed to teach us? Don’t make a mess you can’t clean up!

Yet that is precisely the foundational motivator of this culture. Sure, we can use fancy phrases to describe the processes of creating messes we have no intention of cleaning up, and in many cases cannot clean up.

And so we get phrases like ‘developing natural resources’, or ‘sustainable development’, or ‘technological progress’ (like the invention and production of plastics, the bathing of the world in endocrine disruptors, and so on), or ‘mining’, or ‘agriculture’, or ‘the Green Revolution’, or ‘fueling growth’, or ‘creating jobs’, or ‘building empire’, or ‘global trade’.

But physical reality is always more important than what we call it or how we rationalize it. And the truth is that this culture has been based from the beginning to the present on privatizing benefits and externalizing costs. In other words, on exploiting others and leaving messes behind.

Hell, they call them ‘limited liability corporations’ because a primary purpose is to limit the legal and financial liability of those who benefit from the actions of corporations for the harm these actions cause.

Internalizing insanity

This is no way to run a childhood, and it’s an even worse way to run a culture. It’s killing the planet. Part of the problem is that most of us are insane, having been made so by this culture. We should never forget what RD Laing wrote about this insanity:

“In order to rationalize our industrial-military complex [and I would say this entire way of life, including the creation of messes we have neither the interest nor capacity to clean up], we have to destroy our capacity to see clearly any more what is in front of, and to imagine what is beyond, our noses. Long before a thermonuclear war can come about, we have had to lay waste to our own sanity.

“We begin with the children. It is imperative to catch them in time. Without the most thorough and rapid brainwashing their dirty minds would see through our dirty tricks. Children are not yet fools, but we shall turn them into imbeciles like ourselves, with high IQs, if possible.”

We’ve all seen this too many times. If you ask any reasonably intelligent seven-year-old how to stop global warming caused in great measure by the burning of oil and gas and by the destruction of forests and prairies and wetlands, this child might well say, “Stop burning oil and gas, and stop destroying forests and prairies and wetlands!”

If you ask a reasonably intelligent thirty-year-old who works for a ‘green’ high tech industry, you’ll probably get an answer that primarily helps the industry that pays his or her salary.

Part of the brainwashing process of turning us into imbeciles consists of getting us to identify more closely with-and care more about the fate of-this culture rather than the real physical world. We are taught that the economy is the ‘real world’, and the real world is merely a place from which to steal and on which to dump externalities.

Does nature have to adapt to us? Or us to nature?

Most of us internalize this lesson so completely that it becomes entirely transparent to us. Even most environmentalists internalize this. What do most mainstream solutions to global warming have in common? They all take industrialism as a given, and the natural world as having to conform to industrialism.

They all take empire as a given. They all take overshoot as a given. All of this is literally insane, in terms of being out of touch with physical reality. The real world must always be more important than our social system, in part because without a real world you can’t have any social system whatsoever. It’s embarrassing to have to write this.

Upton Sinclair famously said that it’s hard to make a man understand something, when his job depends on him not understanding it.

I would add that it’s hard to make people understand something when the benefits they accrue through their exploitative and destructive way of life depend on it. So we suddenly get really stupid about the waste products produced by this culture.

When people ask how we can stop polluting the oceans with plastic, they don’t really mean, “How can we stop polluting the oceans with plastic?” They mean, “How can we stop polluting the oceans with plastic and still have this way of life?”

And when they ask how we can stop global warming, they really mean, “How can we stop global warming without stopping this level of energy usage?”. When they ask how we can have clean groundwater, they really mean, “How can we have clean groundwater while we continue to use and spread all over the environment thousands of useful but toxic chemicals that end up in groundwater?”

The answer to all of these is: you can’t.

First we must recover our sanity. Then we must act

As I’ve been writing this essay about the messes caused by this culture, there’s an allegorical image I can’t get out of my mind. It’s of a half-dozen Emergency Medical Technicians putting bandages on a person who has been assaulted by a knife-wielding psychopath.

The EMTs are trying desperately to stop this person from bleeding out. It’s all very tense and suspenseful as to whether they’ll be able to staunch the flow of blood before the person dies.

But here’s the problem: as these EMTs are applying bandages as fast as they can, the psychopath is continuing to stab the victim. Worse, the psychopath is making wounds faster than the EMTs are able to bandage them. And the psychopath is paid very well for stabbing the victim, while most of the EMTs are bandaging in their spare time.

And in fact the health of the economy is based on how much blood the victim loses – as in this culture, where economic production is measured by the conversion of living landbase into raw materials, e.g., living forests into two-by-fours, living mountains into coal.

How do we stop the victim from bleeding out? Any child can tell you. And any sane person who cares more about the health of the victim than the health of the economy that is based on dismembering the victim can tell you. The first thing you need to do is stop the stabbing. No amount of bandages will make up for an assault that is ongoing, indeed, one that is accelerating.

What do we do about this culture’s fabrication of industrial wastes? The first step is stop their production. Actually the first step is that we regain our sanity, that is, we transfer our loyalty away from the psychopaths, and toward the victim, toward, in this case, the planet that is our only home.

Once we do that, everything else is technical. How do we stop them? We stop them.

 


 

Derrick Jensen is Member of the Steering Committee of Deep Green Resistance. See more details. Read Derrick Jensen’s blog.

Also on The Ecologist:Reclaim Environmentalism!’ by Derrick Jensen & Lierre Keith.

 

 




390964

Thai communities poisoned by illegal lead mine waste Updated for 2026





The Thai government has failed to clean up toxic lead in a stream in western Thailand, threatening hundreds of families with serious and irreversible health problems, says a new report from Human Rights Watch.

A Supreme Administrative Court’s order from nearly two years ago to clean up Klity Creek, the first of its kind in Thailand, was been ignored by the government while villagers remain exposed to lead in water, soil, vegetables, and fish.

The report, ‘Toxic Water, Tainted Justice‘ by Human Rights Watch, describes 16 years of failure by Thailand’s Pollution Control Department and public health authorities to prevent further exposure to lead among the village’s ethnic Karen residents, and highlights serious health and environmental damage caused by a now-defunct lead processing factory.

Despite the village’s idyllic setting, many residents of Lower Klity Creek suffer the symptoms of chronic lead poisoning, such as abdominal pain, headaches, fatigue, and mood changes. Some children have been born with severe intellectual and developmental disabilities.

Authorities are ‘still studying’ the court order

“The Thai authorities apparently believe they can ignore a clear court order to clean up the toxic site”, said Richard Pearshouse, senior researcher at Human Rights Watch and author of the report.

“This is one of the most heavily polluted industrial sites in all of Thailand, hundreds of people suffer harm, and it needs immediate government action.”

On January 10, 2013, Thailand’s highest administrative court ordered the government to clean up toxic lead in the creek until test results from the water, soil, vegetables, and aquatic animals in and around the creek fall below permissible levels.

Although clean-up activities should have begun by May 1, 2014, Thailand’s Pollution Control Department says it is “still studying” how to clean up the creek.

Lower Klity Creek villagers may be exposed to lead in their daily lives – by drinking water or eating fish and other aquatic animals, by eating food grown in lead-contaminated plots or cooked in lead-contaminated water, by contact with polluted soil around their houses, or breathing air contaminated by lead dust.

The Pollution Control Department’s environmental tests found unacceptably high levels of lead in soil along the creek bank, as well as in the water and creek sediment, and contaminating fish, shrimp, crabs, and vegetables at various locations along the creek.

More lead mines on the way?

Despite this catastrophe, in 2011, the Ministry of Natural Resources and Environment commissioned an environmental assessment of lead mines in Kanchanaburi province, raising the possibility of Thailand reopening and further developing lead mining and the lead industry.  

“The Thai government seems to be ignoring the lessons from the pollution of Klity Creek and the poisoning of villagers”, Pearshouse said. “Thailand should clean up Klity Creek and provide medical care to affected villagers before even thinking of expanding lead mining.”

The response by provincial and district public health authorities to the situation has been wholly inadequate, Human Rights Watch said. Many village residents who were tested did not receive the results of their blood tests. Others were told the lead levels in their blood were “safe” despite international guidance that there is no safe level of lead exposure.

Children who had elevated lead levels did not receive follow-up medical care. Many villagers told Human Rights Watch that public health authorities simply stopped performing local blood tests for lead by 2008.

Lead is highly toxic and can interrupt the body’s neurological, biological, and cognitive functions. The ingestion of high levels of lead can cause brain, liver, kidney, nerve, and stomach damage as well as anemia, comas, convulsions, and even death.

Children and pregnant women are particularly susceptible, and high levels of lead exposure can cause permanent intellectual and developmental disabilities, including reading and learning disabilities, behavioral problems, attention problems, as well as hearing loss and disruption in the development of visual and motor functioning.

As Thailand pursues mineral wealth, legal obligations ignored

As a result of increasing industrialization and mineral extraction, Thailand faces rising concerns about health impacts from pollution in numerous sites around the country.

These include Na Nong Bong in Loei province (cyanide, mercury, and arsenic), Mao Tao in Tak province (cadmium), Pitchit province (manganese and arsenic), and near the Map Tha Phut industrial area in Rayong province (industrial chemicals).  

Thailand has ratified core international human rights conventions and a range of environmental treaties. These place obligations on governments to protect the environment, safe drinking water, and the health of its citizens, with a special emphasis on children and other vulnerable groups, including women, people with disabilities, and indigenous people.

Thailand’s National Health Act also provides that everyone has the right to a healthy environment. In international law, the rights to the highest attainable standard of health and to water also entail the right to an effective remedy for violations of these rights.

“The Thai government needs to stop ignoring the court order and set out a clear, defined plan with a specific timeline to comply”, Pearshouse said.

“A thorough clean-up of Klity Creek could help Thailand create a model for cleaning up the many places where extreme industrial pollution damages human health.”

 


 

The report: Toxic Water, Tainted Justice – Thailand’s Delays in Cleaning Up Klity Creek‘ is by Human Rights Watch.

More information: Thailand’s Delays in Cleaning Up Klity Creek.

 




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There’s no place for nuclear in the ‘Clean Power Plan’ Updated for 2026





Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

  1. Remove the preservation of existing nuclear reactors from the BSER.
  2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
  3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
  4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

  • Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
  • Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

  • New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
  • Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

 


 

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

 




387540

There’s no place for nuclear in the ‘Clean Power Plan’ Updated for 2026





Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

  1. Remove the preservation of existing nuclear reactors from the BSER.
  2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
  3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
  4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

  • Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
  • Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

  • New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
  • Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

 


 

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

 




387540

There’s no place for nuclear in the ‘Clean Power Plan’ Updated for 2026





Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

  1. Remove the preservation of existing nuclear reactors from the BSER.
  2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
  3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
  4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

  • Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
  • Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

  • New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
  • Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

 


 

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

 




387540

There’s no place for nuclear in the ‘Clean Power Plan’ Updated for 2026





Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

  1. Remove the preservation of existing nuclear reactors from the BSER.
  2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
  3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
  4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

  • Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
  • Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

  • New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
  • Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

 


 

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

 




387540

There’s no place for nuclear in the ‘Clean Power Plan’ Updated for 2026





Dear Administrator Gina McCarthy,

We strongly support the Environmental Protection Agency’s goals in the Clean Power Plan draft regulation, and we are grateful for the agency’s leadership in setting a critical policy for reducing emissions from the electricity generation sector.

We also appreciate the fact that the Clean Power Plan’s purpose is to create enforceable goals for states to reduce emissions, and a framework (the Best System of Emissions Reduction / BSER) for them to implement and comply with the targets.

The framework must be flexible and adaptable, to account for technological advances and regional differences in energy resources and regulatory systems, but it must also encourage rational and effective policies.

Unfortunately, the treatment of nuclear energy in the draft rule is unsupported by meaningful analysis, and would make it possible for states to implement the rule in ways that are counterproductive to the Clean Power Plan’s purpose of reducing emissions.

The role of nuclear power must be re-evaluated

We are, additionally, very concerned about industry proposals to expand provisions to encourage nuclear. We urge the EPA to conduct a thorough and fact-based analysis of nuclear, and to do the following:

  1. Remove the preservation of existing nuclear reactors from the BSER.
  2. Do not force Georgia, South Carolina, and Tennessee to finish building new reactors.
  3. Conduct a thorough and accurate analysis of the environmental impacts of nuclear power, from radioactive waste and uranium mining to reactor accidents and water use.
  4. Recognize and incorporate the much greater role renewable energy and efficiency can, will, and must play in reducing carbon emissions and replacing both fossil fuels and nuclear.

We recognize that the EPA has undertaken a monumental task in developing the Clean Power Plan – perhaps the most important single step in setting the U.S. on the path to reducing emissions enough to avert the worst of global warming and climate change.

It is essential that we begin making substantial reductions in emissions immediately, and that the institutional inertia and narrow self-interest of utilities and major power companies do not stand in the way of deploying the most cost-effective and environmentally sustainable energy solutions.

For that very reason, it is important the regulation ensures states do not get off on the wrong foot and implement the rule in ways that are counterproductive.

False and irrational assumptions

Unfortunately, the Clean Power Plan’s treatment of nuclear incentivizes the preservation and expansion of a technology that is and has always been the most expensive, inflexible, and dangerous complement to fossil fuels.

The Clean Power Plan incorporates nuclear into the BSER in two ways:

  • Assumes five new reactors will be completed and brought online in the states of Georgia, South Carolina, and Tennessee, and irrationally estimates the cost of doing so as $0. In fact, billions more remain to be spent on these reactors and there is a great deal of uncertainty about when, if ever, they will be completed, facing years of delays and billions in cost overruns. The cost assumption would force states to complete the reactors no matter the cost, rather than enabling them to choose better ways to meet their emissions goals. Even though renewables and efficiency could be deployed at lower cost than nuclear, the draft rule would make it look like they are much more expensive because of the zero-cost assumption about completing the reactors.
  • Encourages states to ‘preserve’ reactors economically at-risk of being closed, equivalent to 6% of each state’s existing nuclear generation. While it is true that about 6% of the nation’s operating reactors may close for economic reasons, this provision encourages every state to subsidize existing reactors, greatly underestimates the cost of doing so, and overestimates their role in reducing emissions. Uneconomical reactors have high and rising operating costs, and cannot compete with renewables and efficiency. If anything, EPA should simply recommend that low-carbon energy sources be replaced with other low-carbon resources, but singling out nuclear for ‘preservation’ suggests it is better for states to lock themselves into obsolete and increasingly uneconomical nuclear.

The rule also says states may utilize two other ways of adding nuclear capacity as options for achieving the goals, even though they are not incorporated in the BSER:

  • New reactors other than those currently in construction. EPA recognizes that new nuclear is too expensive to be included in the BSER, so it should not suggest states consider it as a way of meeting their emissions goals.
  • Power uprate modifications to increase the generation capacity of existing reactors. Power uprates are capital-intensive and expensive, and several recent projects have been cancelled or suffered major cost overruns, in the case of Minnesota’s Monticello reactor, at a total cost greater than most new reactors ($10 million/megawatt). [1]

Rather than suggesting states waste resources on nuclear generation too expensive and infeasible to be included in the BSER, EPA should include an analysis of these problems so that states can better evaluate their options and select lower-cost, more reliable means for reducing emissions, such as renewables and efficiency.

Serious nuclear concerns ignored

The Clean Power Plan also considers some non-air quality impacts of nuclear generation, as it is required to do under the Clean Air Act. However, the EPA’s evaluation is both woefully incomplete and alarmingly inadequate. EPA dismisses concerns about radioactive waste and nuclear power’s impact on water resources, simply characterizing them as equivalent to problems with fossil fuel generation.

In fact, radioactive waste is an intractable problem that threatens the environment for potentially hundreds of thousands of years. In addition, nuclear reactors’ use of water is more intensive than fossil fuel technologies, and a majority of existing reactors utilize the most water-intensive once-through cooling systems.

Regardless, however, rather than only comparing them to fossil fuels, EPA should have compared these impacts to the full range of alternatives, including renewables and efficiency, which do not have such problems.

EPA leaves out a host of other environmental impacts unique to nuclear, including uranium mining and nuclear accidents.

There are over 10,000 abandoned uranium mines throughout the US, which are subject to lax environmental standards, pose major groundwater and public health risks, present serious environmental justice concerns, and could entail billions in site cleanup and remediation costs.

The failure to consider the impacts of a nuclear accident is a glaring oversight, in the wake of the Fukushima disaster. EPA must consider both the environmental and economic impact of nuclear accidents.

Renewables can do the job!

In general, the Clean Power Plan’s consideration of nuclear appears to be based on a dangerous fallacy: that closed reactors must be replaced with fossil fuel generation, presumably because other low- / zero-carbon resources could not make up the difference.

In fact, renewable energy growth has surpassed all other forms of new generation for going on three years, making up 48% of all new electricity generation brought online from 2011 to July 2014. [2]

The growth rate of wind energy alone (up to 12,000 MW per year) would be sufficient to replace all of the ‘at-risk’ nuclear capacity within two years, at lower cost than the market price of electricity, [3] let alone at the subsidized rate for nuclear the draft rule suggests.

Assuming that closed reactors will be replaced with fossil fuel generation both encourages states to waste resources trying to ‘preserve’ (or even build) uneconomical reactors rather than on more cost-effective and productive investments in renewables and efficiency.

While states are free to develop their implementation plans without using the specific energy sources included in the BSER, the rule should not promote such foolishness.

No amount of spending or subsidies for nuclear has been effective at reducing the technology’s costs nor overcoming lengthy construction times and delays, whereas spending on renewables and efficiency has had the effect of lowering their costs and increasing their rate of deployment.

The economic problems facing currently operating reactors merely underscore the point that nuclear is not a cost-effective way of reducing emissions.

We are hopeful that the Clean Power Plan will be a watershed in setting the country on a path to emissions reductions and climate action, and we are grateful to the EPA for taking this step.

We believe that correcting the problems with the way nuclear is considered in the draft rule, and increasing the role of renewables and efficiency, will make the Clean Power Plan much stronger and lead states to implement it more productively and cost-effectively.

 


 

Action – organizations: Make sure your organization is signed on to our comments on the Clean Power Plan, which expand on the points above. The comments, and current list of endorsers, are here. If your organization is not listed, please sign on now by sending an e-mail to me at nirsnet@nirs.org with your name, title, organization name, city, and state (and country if outside the US – we encourage our international friends to support us in this effort!). Please sign on by midnight, Sunday, November 30, 2014.

Action – individuals: Please send in your comments on our action page here. And please share the action page with your friends and colleagues using the logos at its top, or share our previous Alert on the issue on Facebook and Twitter here. More than 19,000 of you have acted so far; we want to top 20,000 (do I hear 25,000?) comments before the December 1 deadline. Your help in outreach is essential to meet that goal.

Tim Judson is Executive Director of Nuclear Information & Resource Service, Takoma Park, MD.

For full list of signatories see NIRS.

References

1. Shaffer, David. ‘Xcel management blamed for cost overruns at Monticello nuclear plant‘. Minneapolis Star-Tribune, July 9, 2014.

2. Sun Day Campaign. ‘Renewables Provide 56 Percent of New US Electrical Generating Capacity in First Half of 2014‘. July 21, 2014.

3. Lawrence Berkley National Laboratory. ‘2013 Wind Technologies Market Report‘. US Department of Energy. August 18, 2014.

 




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ECJ affirms UK’s right to clean air – the Government must act! Updated for 2026





The European Court of Justice delivered a landmark verdict today by ruling in favour of ClientEarth’s case against the UK Government for its failure to tackle air pollution.

This ground-breaking ruling, the first ever on the effect of the EU’s Air Quality Directive, puts the UK Government in “ongoing breach” of UK law.

And it means that the UK Supreme Court will be compelled to take action against the Government, with the threat of huge fines being handed out further down the line if the breach continues.

The ruling has also paved the way for future legal actions to enforce other EU targets on emissions and energy efficiency.

How did the Government get in such a mess?

The EU’s Air Quality Directive sets legal limits on air quality which member states are required to meet within a certain time frame.

Our current government is failing spectacularly to meet these targets: it has drawn up plans which show it will not meet nitrogen dioxide limits until after 2030 – 20 years after the original deadline!

This prompted environmental lawyers at ClientEarth to take our Government to court. This is embarrassing for the Government to say the least – and it’s deeply concerning that it takes an EU Court ruling for them to start taking the issue of air pollution seriously.

ClientEarth got it right when they said: “We have a legal right to breathe clean air. When the government fails in its duty to uphold that, the courts must step in.

“If the government were allowed to stick with current proposals for tackling pollution, a child born today in London, Birmingham or Leeds would have to wait until after their 16th birthday before they can breathe air that meets legal limits.

“ClientEarth does not believe this is acceptable, which is why we have challenged the government through the courts for the past five years to tackle the problem urgently. The longer government is allowed to delay, the more people will die or be made seriously ill by air pollution.”

In their judgment, the panel of European judges said the Government should have planned to secure compliance with the Directive by January 2015 – 15 years earlier than it intended.

Air pollution and disease – the facts

Air pollution, primarily caused by emissions from road vehicles, is the second biggest killer in our country after smoking. According to the Healthy Air campaign, air pollution contributes to around 200,000 early deaths in the UK each year.

Cars, lorries, vans and buses emit large amounts of air pollution directly into the streets where we live and work. With more vehicles on the road than ever, this is creating significant problems. In densely populated areas like London the impacts are exacerbated.

Burning fuels in boilers and power stations is another source of air pollution. Heating boilers, power generation, and industry burning coal, oil, wood, petrol, diesel and natural gas – energy sources which we are very reliant on, are all significant sources of pollution.

I also remain concerned about the impact of aviation on air pollution – particularly with proposals for a new runway at either Heathrow or Gatwick.

Air pollution is an invisible public health crisis. Long term exposure to air pollution is associated with heart and lung disease. Diesel fumes are the main source of nitrogen dioxide (NO2) – a harmful gas linked with heart attacks and asthma and the gas that this court case rests on.

Children can be particularly vulnerable to the impacts. Research has shown that children growing up near motorways can suffer permanently reduced lung capacity. This may also be the case for people living nearby to other high polluting industries such as airports.

Even those who live and work in areas with clean air can have their health affected when they visit a polluted area as short term exposure to air pollution can irritate our airways, causing wheezing and shortness of breath. This is particularly a problem for those with existing respiratory conditions, such as asthma.

What happens next?

The growing problem of air pollution isn’t going to go away. As the Green MEP for South East England, an area widely affected by poor air quality, I believe this issue needs to be tackled at every level of Government, from local councils to Westminster.

For that to happen the Government must wake up to the reality of air pollution. Clean air is one of the fundamental things we need in order to enjoy good health and a good quality of life.

The judgment is also good news for the rest of Europe. As ClientEarth points out, today’s judgment sets a “groundbreaking legal precedent in EU law” – one that will paves the way for other legal challenges across the EU. ClientEarth has promised to “spearhead these efforts to help people defend their right to clean air in court.”

The legal case will return to the UK Supreme Court for a final ruling in 2015, for judges to apply the ECJ’s ruling to the facts in the UK case, following the judges order that

“it is for the national court having jurisdiction, should a case be brought before it, to take, with regard to the national authority, any necessary measure, such as an order in the appropriate terms, so that the authority establishes the plan required by the directive in accordance with the conditions laid down by the latter.”

In other words the UK Supreme Court is required to order the government to draw up a new plan to meet limits in a much shorter timeframe. But the Government should not wait until it is ordered – it should draw up and implement urgent plans immediately to drastically cut pollution from diesel vehicles and bring itself within the law.

In my opinion, dirty diesel-burning HGVs, buses and trains in particular should be a first priority for emissions reductions, with urban buses switching to ‘hybrid’ and purely electric technologies.

There’s also a case for ‘grounding’ all non-essential diesel vehicles at times of high air pollution. And the Green Party believes that London’s plans for an ‘ultra low emission zone‘ should be rolled out nationally.

But we must also address the deeper causes – which means investing much more in sustainable transport methods such as cycling and walking, and the shift from cars to public transport to reduce overall traffic levels. The public must also be properly warned of the risks, and how to reduce exposure.

There’s lots to do – and it’s high time for the Government to stop prevaricating, wake up and get on with the job!

 


 

Keith Taylor is the Green MEP for South East England.

Website: keithtaylormep.org.uk.

 

 




380987

ECJ affirms UK’s right to clean air – the Government must act! Updated for 2026





The European Court of Justice delivered a landmark verdict today by ruling in favour of ClientEarth’s case against the UK Government for its failure to tackle air pollution.

This ground-breaking ruling, the first ever on the effect of the EU’s Air Quality Directive, puts the UK Government in “ongoing breach” of UK law.

And it means that the UK Supreme Court will be compelled to take action against the Government, with the threat of huge fines being handed out further down the line if the breach continues.

The ruling has also paved the way for future legal actions to enforce other EU targets on emissions and energy efficiency.

How did the Government get in such a mess?

The EU’s Air Quality Directive sets legal limits on air quality which member states are required to meet within a certain time frame.

Our current government is failing spectacularly to meet these targets: it has drawn up plans which show it will not meet nitrogen dioxide limits until after 2030 – 20 years after the original deadline!

This prompted environmental lawyers at ClientEarth to take our Government to court. This is embarrassing for the Government to say the least – and it’s deeply concerning that it takes an EU Court ruling for them to start taking the issue of air pollution seriously.

ClientEarth got it right when they said: “We have a legal right to breathe clean air. When the government fails in its duty to uphold that, the courts must step in.

“If the government were allowed to stick with current proposals for tackling pollution, a child born today in London, Birmingham or Leeds would have to wait until after their 16th birthday before they can breathe air that meets legal limits.

“ClientEarth does not believe this is acceptable, which is why we have challenged the government through the courts for the past five years to tackle the problem urgently. The longer government is allowed to delay, the more people will die or be made seriously ill by air pollution.”

In their judgment, the panel of European judges said the Government should have planned to secure compliance with the Directive by January 2015 – 15 years earlier than it intended.

Air pollution and disease – the facts

Air pollution, primarily caused by emissions from road vehicles, is the second biggest killer in our country after smoking. According to the Healthy Air campaign, air pollution contributes to around 200,000 early deaths in the UK each year.

Cars, lorries, vans and buses emit large amounts of air pollution directly into the streets where we live and work. With more vehicles on the road than ever, this is creating significant problems. In densely populated areas like London the impacts are exacerbated.

Burning fuels in boilers and power stations is another source of air pollution. Heating boilers, power generation, and industry burning coal, oil, wood, petrol, diesel and natural gas – energy sources which we are very reliant on, are all significant sources of pollution.

I also remain concerned about the impact of aviation on air pollution – particularly with proposals for a new runway at either Heathrow or Gatwick.

Air pollution is an invisible public health crisis. Long term exposure to air pollution is associated with heart and lung disease. Diesel fumes are the main source of nitrogen dioxide (NO2) – a harmful gas linked with heart attacks and asthma and the gas that this court case rests on.

Children can be particularly vulnerable to the impacts. Research has shown that children growing up near motorways can suffer permanently reduced lung capacity. This may also be the case for people living nearby to other high polluting industries such as airports.

Even those who live and work in areas with clean air can have their health affected when they visit a polluted area as short term exposure to air pollution can irritate our airways, causing wheezing and shortness of breath. This is particularly a problem for those with existing respiratory conditions, such as asthma.

What happens next?

The growing problem of air pollution isn’t going to go away. As the Green MEP for South East England, an area widely affected by poor air quality, I believe this issue needs to be tackled at every level of Government, from local councils to Westminster.

For that to happen the Government must wake up to the reality of air pollution. Clean air is one of the fundamental things we need in order to enjoy good health and a good quality of life.

The judgment is also good news for the rest of Europe. As ClientEarth points out, today’s judgment sets a “groundbreaking legal precedent in EU law” – one that will paves the way for other legal challenges across the EU. ClientEarth has promised to “spearhead these efforts to help people defend their right to clean air in court.”

The legal case will return to the UK Supreme Court for a final ruling in 2015, for judges to apply the ECJ’s ruling to the facts in the UK case, following the judges order that

“it is for the national court having jurisdiction, should a case be brought before it, to take, with regard to the national authority, any necessary measure, such as an order in the appropriate terms, so that the authority establishes the plan required by the directive in accordance with the conditions laid down by the latter.”

In other words the UK Supreme Court is required to order the government to draw up a new plan to meet limits in a much shorter timeframe. But the Government should not wait until it is ordered – it should draw up and implement urgent plans immediately to drastically cut pollution from diesel vehicles and bring itself within the law.

In my opinion, dirty diesel-burning HGVs, buses and trains in particular should be a first priority for emissions reductions, with urban buses switching to ‘hybrid’ and purely electric technologies.

There’s also a case for ‘grounding’ all non-essential diesel vehicles at times of high air pollution. And the Green Party believes that London’s plans for an ‘ultra low emission zone‘ should be rolled out nationally.

But we must also address the deeper causes – which means investing much more in sustainable transport methods such as cycling and walking, and the shift from cars to public transport to reduce overall traffic levels. The public must also be properly warned of the risks, and how to reduce exposure.

There’s lots to do – and it’s high time for the Government to stop prevaricating, wake up and get on with the job!

 


 

Keith Taylor is the Green MEP for South East England.

Website: keithtaylormep.org.uk.

 

 




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