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Ask a Scientist: Will the Biden Nuclear Weapons Policy Wind up Being the Same Old Same Old?

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By Elliott Negin

More so than most of the previous occupants of the White House, Joe Biden — a former Senate Foreign Relations Committee chairman — is steeped in all things nuclear, and he has long embraced the common sense view that nuclear arsenals must be reduced dramatically.

During the 2020 presidential campaign, arms control advocates were heartened when Biden agreed that the US policy reserving the right to use nuclear weapons first in a conflict should be reevaluated and reiterated his opposition to a new “low yield” nuclear weapon the Trump administration planned to field on submarines. Likewise, they applauded when — just a week after taking office — President Biden extended the New Strategic Arms Reduction Treaty with Russia, which was set to expire in early February. This treaty limits deployed nuclear warheads on each side to 1,550.

But do Biden’s campaign talking points and his quick action on New START signal that his administration will make some sorely needed changes in US nuclear policy? We will soon find out. The administration plans to release what’s called the Nuclear Posture Review (NPR), which every administration since Bill Clinton was president has issued, early this year. The document will define what kind of nuclear weapons the United States will have, how it will use them, and how they fit in with the rest of US military and foreign policy plans.

The NPR has not changed much in 30 years, regardless of who was sitting in the Oval Office, and some would argue — including experts at UCS — that reform in light of 21st century realities is long overdue.

To get some insight into which direction the Biden administration might take on this critical issue, I contacted Eryn MacDonald, who has been an analyst with the UCS Global Security Program since 2011. MacDonald is an expert in international security, arms control and nonproliferation, US-China relations, and East Asian security, and earned a master’s degree in government from Cornell University. Below is an abridged version of our conversation.

EN: First, happy new year. Let’s hope this year is better than 2021, but based on what you had to say last year on this topic, I’m worried that we may be too optimistic about making progress. You wrote a blog last June, for example, pointing out the Biden administration’s fiscal year (FY) 2022 military budget request fully funded all the nuclear weapons the Trump administration proposed — including, of all things, the new, sea-launched cruise missile Biden said he opposed — and called for spending even more on the nuclear arsenal than the previous year. What just happened in Congress last month with the military budget, and what does that bode for the NPR?

EM: The Biden administration’s FY22 budget request was disappointing to those of us who hoped he would live up to his stated opposition to new nuclear weapons. Rather than making cuts, it fully funded all programs — including, as you said, the new nuclear weapons the previous administration wanted. The budget also added money to extend the life of the massive and unnecessary B83 bomb — 80 times more destructive than the atomic bomb dropped on Hiroshima — that the Obama administration had planned to retire. Biden’s first budget requested more funding for nuclear weapons programs than in the previous year and Congress essentially approved it wholesale as part of the FY22 National Defense Authorization Act, which Biden signed into law on December 27.

While the spending bill and the Nuclear Posture Review are separate processes and do different things — the NPR focuses much more on top-level policy — the failure of the Biden administration budget to reverse course on such new weapons as the nuclear sea-launched cruise missile or even eliminate low-hanging fruit such as the B83 does not bode well for the NPR’s outcome. At least, not for anyone hoping for real progress toward eliminating unnecessary nuclear weapons and instituting substantive changes in US nuclear policy to reduce the risk that these weapons would ever be used.

EN: The news media reported early last year that President Biden’s national security team supported negotiating new arms control treaties, cutting back the US nuclear arsenal, and taking a hard look at outdated military doctrine. But more recently, there have been stories about a Pentagon backlash against making any significant changes to the NPR because of Russian and Chinese nuclear buildups. Is that a credible rationale? What do you expect will happen when all the dust settles?

EM: President Biden has a long history of supporting nuclear arms control and reduction policies, and he entered office promising to carry through on his commitments in this area and tap experts who share a similar vision for his national security team. We thought that signaled there would be significant movement toward a saner, safer US nuclear policy via the Nuclear Posture Review process, which is the most obvious way for a president to direct major shifts.

It is not surprising that there would be pushback from status quo forces in the Pentagon and elsewhere against any substantial change. That has happened before, derailing attempts in more than one NPR to take anything more than incremental steps. As the Biden NPR process has unfolded, more progressive voices have been sidelined, so this NPR now seems to be consigned to the same fate.

Russian and Chinese nuclear buildups certainly have not helped, giving cover to the folks who would have resisted change in any case. But what Russia and China are doing actually make the kinds of changes we want Biden to make more important. Declaring that the United States would never be the first to use nuclear weapons — a policy China has had since it first built nuclear weapons, ending the president’s sole authority to order a nuclear launch, and taking US nuclear weapons off hair-trigger alert are all changes that could help de-escalate the budding arms race with Russia and China. None of these policy changes would undermine the US nuclear deterrent, and all of them would strengthen US security by reducing the risk of accidental or mistaken nuclear war.

At this point, the prospect for major change through the NPR process appears slim. To say that President Biden has had a lot to deal with in his first year in office is beyond an understatement, and his attention has very likely been elsewhere, despite his longstanding interest in nuclear issues. The remaining hope is that once he sees the document himself, he may reject an NPR draft that goes against his stated desire to reduce the role of nuclear weapons in US policy and leaves out some of the policies — such as no-first-use — that he has said he supports. In that case he would have to ask for a revised draft more in keeping with his own vision.

EN: Let’s talk about the ramifications of the United States adopting a no-first-use policy, which would have the United States pledge to never use nuclear weapons first in a conflict or declare their “sole purpose” is to deter, or retaliate against, a nuclear attack on the United States or its allies. According to some press reports, the prospect of such a policy makes some US allies nervous, like Britain, France, and Japan. What would be the benefit of this policy? What are the chances that the new NPR will include one?

EM: During his 2020 presidential campaign, Biden expressed clear support for a no-first-use policy, but it is not a new position for him. He addressed the issue near the end of his last term as vice president, stating that “the president and I strongly believe we have made enough progress that deterring — and if necessary, retaliating against — a nuclear attack should be the sole purpose of the US nuclear arsenal.”

Some may quibble with the difference between declaring “sole purpose” and “no first use,” but the result in either case would be an immediate reduction in the possibility of a nuclear war. It would lower the risk of miscalculation in the event of a crisis with another nuclear-armed state, because it would lessen their incentive to try to preempt the United States from using nuclear weapons. It would also reduce the risk associated with the US president’s sole authority to order the use of nuclear weapons by removing the option for any president to order a launch first.

Concern about US allies’ reaction is apparently what prevented the Obama administration from declaring a no-first-use policy a decade ago. But such concerns are likely overblown. In Japan, for instance, my colleagues Gregory Kulacki, Jennifer Knox, and Miyako Kurosaki found that while there may be a minority of hardliners within the government opposed to a US no-first-use declaration, a majority of the general population is in favor of the United States taking such a step.

In a 2020 column in Foreign Affairs, Biden reiterated his support for a sole purpose declaration, adding that as “president, I will work to put that belief into practice, in consultation with the US military and US allies.” The Biden administration should do as he promised and reassure Japan and our European allies that the United States remains committed to their security and that first use of nuclear weapons is not a necessary — or realistic — part of upholding that commitment.

EN: Last February, more than 30 House Democrats sent a letter to the White House asking President Biden to renounce the president’s sole authority to order a nuclear launch, arguing that no single individual should have that power. UCS has been advocating for the end to this policy for years. Does Biden have the ability to make this change? What are the prospects?

EM: President Biden absolutely has the ability — and authority — to make this change, and it would go a long way toward making us all safer. Just last year, Chairman of the Joint Chiefs of Staff General Mark Milley was so concerned about President Trump’s stability, especially after the January 6 insurrection at the US Capitol, that he made plans to intervene if the president gave the order to launch nuclear weapons. Milley reportedly told senior officers that although the president could give such an order, Milley also needed to be involved.

In fact, Milley had no real authority to insert himself into this process, regardless of any understanding he may have reached with those officers. But while stories like this one make the dangers of sole authority glaringly obvious, they can also distract from the fact that it is a problem even when there are no serious concerns about a president’s mental state.

There have been attempts to end sole authority through legislation, and Massachusetts Sen. Ed Markey and California Rep. Ted Lieu last year reintroduced a bill prohibiting the president from launching a nuclear first strike without a declaration of war by Congress. But this approach would be unusual. Normally, US nuclear policy is set by the president, so Biden is the one who could most straightforwardly make a change, simply by declaring that he wants to end the policy and instructing the Pentagon to adjust its procedures accordingly. UCS experts, as well as others, have suggested multiple ways that this could be done quickly and easily using existing communications systems.

It is still unclear whether Biden will take this step. So far, there does not seem to be much of an appetite in his administration for rocking the boat, but ending sole authority might be less controversial than some other policy changes, and would be an easy way to reduce the risk of nuclear war.

EN: Last month, nearly 700 scientists and engineers, including 21 Nobel laureates, made news when they called on President Biden to use the NPR to declare a no-first-use policy and cut the US nuclear arsenal by a third. Their open letter also asked the president to cancel plans to replace the current ICBM fleet. That letter came on the heels of a similar letter from local, county and state officials. What kind of an impact can letters like these have?

EM: Advocacy on nuclear policy issues can sometimes be frustrating. Apart from occasional headline-grabbing moments, such as a North Korean nuclear test or a US president vowing “fire and fury” in response to North Korean threats, nuclear weapons are not top-of-mind for most people these days. Many also believe that they are not qualified to have an opinion on nuclear issues because they are not experts, even though decisions that political and military leaders make about nuclear weapons have the potential to impact the lives of every person on the planet.

In reality, pressure from specific groups, such as scientists, as well as the general public have historically been key to making progress in reducing the nuclear threat. The recent letter is just the latest example of scientists using their technical expertise as a springboard to speak out against nuclear weapons — a movement that began with some of the scientists who worked on the Manhattan Project to develop the first atomic bomb. The Union of Concerned Scientists itself was born out of that legacy of scientists who were deeply invested in ending the nuclear threat.

The letter you mentioned from more than 300 local and state level officials was the result of ongoing hard work by my colleagues at UCS, the Physicians for Social Responsibility, and other groups that organized the Back from the Brink campaign. The campaign now has a supporter base of nearly 400 organizations, more than 300 state and local elected officials, 55 municipalities, and six state legislatures, all working to prevent nuclear war and make nuclear abolition a reality.

Bringing in voices outside of the usual suspects is a necessary first step to shift the dialogue about nuclear weapons from its entrenched focus on such traditional topics as deterrence and military security to a broader perspective that prioritizes a more human-centered definition of security. Expanding the conversation also could encourage a wider recognition of the true costs of nuclear weapons, not only the potential human and environmental devastation resulting from their use, but also the fact that they divert billions of dollars that could otherwise be used for healthcare, education, housing, and other basic human needs.

Originally published by Union of Concerned Scientists, The Equation.

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Tesla’s Policy Lead Testifies at PUCT Open Meeting As Tesla Focuses on Supporting the Texas Grid

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Tesla’s US Energy Markets Policy Lead, Arushi Sharma Frank, was recently asked to testify at a Public Utility Commission of Texas Open Meeting. A photo of Frank wearing an LFDECARB tee shirt popped up on Twitter. The tee shirt itself is a message focused on decarbonization by the group Bros for Decarbonization. You can learn more about the group here.

Frank confirmed that it was an impromptu request to testify. She also shared exactly what she talked about.

The document Frank shared was a filing receipt for supplemental comments from Tesla signed by Frank. There’s also a video of her testimony which you can watch here. In the document, Tesla said that it appreciated the opportunity to share its comments regarding PUCT’s discussions that were held on June 16, 2022 — the open meeting regarding Tesla’s proposal OBDRR041 as well as its prior work demonstrating how virtual power plants (VPPs) work.

I recently published an article about Tesla’s VPP workshop, which was related to OBDRR041. Tesla also said that it appreciated the Commission’s comments related to its Distributed Energy Resource (DER) pilot projects. Tesla especially supported the conversation between Commission representatives and the staff at the Electric Reliability Council of Texas (ERCOT), as well as with the market participants. The conversation covered the real implementation of the system through a pilot as opposed to a task force approach. The latter, Frank noted, could unnecessarily create delays in implementing a grid service solution for DERs.

Looking At The Document & Tesla’s Statements

The Commission’s decision to encourage ERCOT to get stakeholders together and develop a pilot project allowing the market solution of exports from VPPs to be tested is also something Tesla expressed its appreciation for. This allowed for addressing issues raised by utilities and other market participants that have concerns about the potential impacts of site-exporting DERs on distribution facilities. It also allowed for a discussion of the net impact and benefits to the transmission grid.

Tesla also clarified and provided information as a response to a few discussion topics and questions that were raised at the open meeting. These topics included the OBDRR041 status, the ERCOT Pilot Proposal, and a question posed to Tesla by Chairman Lake at the open meeting.

OBDRR041 status

Tesla noted that since the OBDRR041 is currently tabled at the ERCOT Technical Advisory Committee, it would not seek a vote until there was further development of issues and positions from ERCOT and the potential members of the committee.

“At this time, Tesla believes that OBDRR041 may remain tabled at the Technical Advisory Committee pending consideration of the feasibility of a Virtual Power Plant pilot as the Commission proposed at the Open Meeting.”

ERCOT Pilot Proposal

Tesla expressed its views on the formal ERCOT Pilot Proposal that was introduced at the Open Meeting. Tesla noted that for a formal ERCOT pilot approach to be a feasible alternative to OBDRR041, a pilot should :

Have ERCOT’s support and the market’s acceptance and approval from ERCOT’s governing board.
Be amenable to commercialization in that sufficient participants could be aggregated across sufficient distribution service areas (more than one, but in capped quantities, in each service area as described in a proposed pilot framework).
Adequately capture data addressing clearly identified distribution utility concerns, in parallel to or as part of the pilot’s scope.
Have provisions to ensure market services compensation commensurate with grid services provided by pilot participants
Have an identified “start date” and “end date” which are technically feasible for involved parties.

In addition to that last point, Tesla added that the following are requirements in Section 25.361 (k) regarding pilot development and approval:

“ERCOT may conduct a pilot project upon approval of the scope and purposes of the pilot project by the governing board of ERCOT. Proposals for approval of pilot projects shall be made to the governing board only by ERCOT staff, after consultation with affected market participants and commission staff designated by the executive director.

“The ERCOT governing board shall ensure that there is an opportunity for adequate stakeholder review and comment on any proposed pilot project.”

Tesla noted that pilot  project proposals approved by the ERCOT governing board should include the following:

The scope and purposes of the pilot project;
The designation of temporary exceptions from ERCOT rules that ERCOT expects to authorize as part of the pilot project;
Criteria and reporting mechanisms to determine whether and when ERCOT should propose changes to ERCOT rules based on the results of a pilot project.
An estimate of costs ERCOT will incur attributable to the pilot project.
An estimated date of completion of the pilot project.

Tesla’s Response To Chairman Lake

Tesla expressed its appreciation for Chairman Lake, who stated that “nothing teaches like experience, so the sooner you get something in the field, the more you learn faster.”

Tesla also responded to a question posed by the chairman and said that it’s concerned that it will not be able to scope a pilot program in a Non-Opt-in-Entity (NOIE) area. Currently, Texas homeowners are unable to participate in VPPs due to the law. Tesla said:

“Primarily, this approach may not be economically rational as it could mean a substantial resource investment in a pilot that is not scalable to a commercial retail offer where Tesla could continue to directly serve those customers and grow the program’s strength and viability.

“The customers in a pilot should be able to continue to benefit from the value for their systems beyond the end-date of the pilot, in a commercially viable solution – but with a NOIE-only pilot, Tesla would have no control, legally or otherwise, over the continued participation of such customers once the pilot closes, even if a viable market participation framework is implemented following that pilot’ s conclusion.

“Any formal program participation of those customers would be solely at the option of the NOIE serving those customers. More simply, the purpose of a pilot is to study a solution that can be scaled following adoption of market rules based on pilot learnings. To build a program off the learnings of a pilot, the customer base involved in the pilot should be able to continue service under that formalized program, so that parties involved are not running the risk of raising a wholly new set of unstudied issues in a new distribution system type that was not part of the pilot.”

Frank also shared a link to over 60 pages of data from Tesla. Deep dive coming soon.

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Coalition Calls for EU Hydrogen Quota for Shipping

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Energy providers, shipping companies and NGOs call on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030

A broad coalition of energy providers, shipping companies and NGOs — including Siemens Energy, Viking Cruises, Green Power Denmark and Brussels-based organisations Hydrogen Europe and Transport & Environment (T&E) — has called on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030.

Last year the European Commission, the EU’s executive body, proposed a shipping fuel law (FuelEU Maritime Regulation) aimed at increasing the uptake of alternative marine fuels. Unfortunately, the law fails to guarantee the competitiveness of sustainable and scalable e-fuels, and risks promoting cheaper, unsustainable fuels. The coalition therefore calls on the European Parliament and EU Council to improve the proposal by including a dedicated e-fuels sub quota in the proposed regulation.

Delphine Gozillon, sustainable shipping officer at T&E, said:

“An ambitious shipping fuels law will be key to set the shipping sector on course for full decarbonisation. Sustainable e-fuels are currently too expensive compared to other alternatives such as fossil LNG and biofuels, holding back investments in production facilities, refuelling infrastructure in ports and zero-emission ships. However, with a bit of a push e-fuels produced from renewable hydrogen can be scalable. That’s why we need a quota to get the ball rolling and encourage companies to start investing in clean shipping fuels. Shipping does not need to be a dirty industry forever.”

A list of all the coalition’s demands can be found here.

Download the letter.

Courtesy of Transport & Environment.

Featured image courtesy of Maersk.

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Diving Into Tesla’s 60+ Pages of PUCT Filings (Mostly Data)

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Tesla has over 60 pages of Public Utility Commission of Texas (PUCT) filings that have recently been shared publicly, and we’re about to dive into them. Grab some water and a coffee and let’s go.

Tesla and its team, including its US Energy Markets Policy Lead, Arushi Sharma Frank, have been working hard to help Texan Powerwall customers be able to take part in virtual power plant (VPP) pilot programs. In May, Tesla held a VPP workshop for the Electric Reliability Council of Texas (ERCOT) and Frank was one of the key leaders hosting the meeting.

Recently, Frank was asked to testify at an open meeting of the PUCT, and there she shared Tesla’s comments and statements addressing questions and other concerns relating to VPPs.

Frank tweeted a thank you to the PUCT for the opportunity of allowing Tesla to provide comments. In addition, she followed up with two more tweets, with one mentioning her favorite part of the filings — Tesla describing a phenomenon called “clumping.” Clumping is a reference to capturing the full value of distributed energy renewables capacity in an aggregate load resource (ALR).

63 Pages Of Data For PUCT

In total, there were 63 pages. I’m only going to go over some of the data briefly. I think it’s important to highlight Tesla’s hard work because if Texas allows its residents who own Powerwall batteries systems to participate in VPPs, this opens the door for other states in the Deep South to at least consider clean energy solutions for various problems, especially grid-related. Texas is well known for its grid instability, and if it allows Tesla Powerwall customers to take part in VPPs, this could mean saving lives during disasters.

Included in the filings were comments from Tesla, a request from Tesla that the Commission direct ERCOT to prioritize several actions such as allowing ALRs (Aggregated Load Resources) to provide injection capacity from individual sites in a framework by December 2022, an informal narrative of Tesla’s VPP demonstration in ERCOT, and 47 slide pages detailing the ERCOT/Tesla ancillary service demonstration.

I think the most important part for us outsiders observing here is the 47 slides, because they highlighted a lot of data that shows just how the Texas grid will benefit from VPPs. The 47 slides showed several key meetings between Tesla and ERCOT about the demo program.

Key Meeting Between Tesla & ERCOT Shows Tesla Has Been Working Hard Trying To Convince Texas To Allow VPPs

In March, there were four meetings in which Tesla defined clumping, Frank’s favorite part, as well as two telemetry signal approaches. Following that were weekly meetings around the demo results with the last demo result being April 15, 2022. On April 9, Tesla and ERCOT revisited clumping and the two telemetry signals approach.

This tells me and anyone paying close attention that Tesla has been quietly working with ERCOT to help the Texas grid for quite some time. This, I think, is a good thing, especially for Texas.

Tesla Seeks To Register The First ALR In ERCOT

According to the documents, Tesla wants to register the first ALR in ERCOT and participate in services that are currently unavailable. These services include non-spin and sCED load reduction dispatch. Tesla wants to do this with the full value of grid services that injecting devices can provide in an ALR.

Tesla said that it will lead efforts to modify the utility’s ALR Policy Other Binding Document to make it fit with practical operational, registration, and qualification issues. It clarified that ERCOT can exchange two telemetry points with an aggregation-qualified scheduling entity (QSE).

Tesla ERCOT Demo Tests

Tesla’s first demo looked at the comparison of battery and premise-level telemetry. Below is a chart showing the initial conditions, test steps, data collected, and pass criteria.

Table courtesy of Tesla

This first test results show that VPPs work beautifully in Texas. According to the results, the load decreased during the evening while in the morning it decreased while exporting to the grid. And during the daytime, the exporting of energy to the grid only increased. Tesla explained further:

“Discharging from the customer’s battery using a step function can clearly be identified in the premise-level data.

“At different times of day, premise-level data will look differently, depending on the current load:

1. Evening time: during the evening peak, user load is typically high, and discharging the battery will show up as a decrease in premise-level load.

2. Morning time: during the night/morning time, user load is typically lower, and discharging the battery will both decrease load, and export energy to the grid.

3. Daytime: during the daytime, solar is exporting to the grid, and discharging the battery will increase the export.”

You can view the full demo, test results, and all of Tesla’s comments here.

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