I read an important article on Bloomberg.com this morning. Here is the letter that I wrote to the author in response.
Dear Mr. Smith:
I read with great interest your detailed article titled Nuclear Utilities Redefine One Word to Bulldoze for New Plants. It is a fine work of investigative journalism. I am sure that the facts are probably correct and well researched. However, I must challenge the slant that the article took.
My bias in favor of nuclear power probably has something to do with the lens through which I look at this story. The key thought for me, however, is summarized by one of the section subheads in your own article that was not fleshed out in the same way that I would have written the section. As your article stated, nuclear power plants are Competing With Coal. In order for them to do so, the playing field should be level and the referees should be following similar rule books. That should include honest, detailed evaluations of their environmental impact.
Unfortunately, that facet of the competition is almost completely skewed since building a coal fired power plant is not defined as a “major federal action” under the 1970 National Environmental Protection Act, but issuing a nuclear power plant license is.
That means that a coal plant, though having many permitting requirements, does not require the submission or approval of a federal Environmental Impact Statement. That bit of legal nuance was the work of the well funded team that opposed Calvert Cliffs. They managed to persuade a court that the thermal discharges of a nuclear heated steam plant were somehow of great concern while the thermal and hazardous gaseous emissions of a coal fired steam plant never even get a federal review. It was a long time ago, but I still wonder whether or not the Calvert Cliffs legal team received any financial or political support from people with coal, oil or gas interests.
The Energy Information Agency cost analysis that you cited to compare the production costs for coal fired power plants against the cost of nuclear plant was performed under the assumption that nuclear power plants had much longer and more expensive construction periods. A good part of the difference is the result of the delays inherent in the federal review of the EIS. From a pure construction point of view, there is not much difference in the amount of time, materials and labor needed to build similar sized units of either coal or nuclear plants.
The cost study also assumed that discharging CO2 – plus all of the other noxious pollutants from a coal fired power plant – would remain essentially free forever. I hope that assumption will soon be proven to be a very poor input into the cost analysis. We must do something about the fact that coal fired electricity represents about 30% of the US emissions of gases that cause global climate change.
I am glad that the NRC made a reasonable decision to allow infrastructure development before completion of the EIS. That brings the project time line closer in line with the time required for a coal plant – though coal projects still can move more quickly and with less oversight.
It would surprise me greatly if an investigation found that Mr. Merrifield took any action that was not scrupulously within the existing federal ethics guidelines. I have met the man on several occasions – he is an honorable, hardworking man who took his public service responsibilities very seriously.