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Nuclear Power Won’t Save the World. It Won’t Even Help.




Originally published at Green Energy Times.

An Old Paradigm

The electricity most of us use comes from a system that was designed mostly over a hundred years ago. It was built around concepts that benefited customers of that time. It started with baseload power plants with transmission lines carrying the electricity to towns and cities where customers lived.

A baseload power plant is designed for efficiency of scale and operation. In those days, that meant it had to be as big as possible. Since any ability to ramp power output up or down quickly would cost a lot extra, the plants were designed to have constant output. With constant output, a baseload plant had be sized to meet a demand that could be counted on always to be there. This is the base load, the lowest load that the grid would ever have over the course of time.

Since the baseload power plant was designed to cover the lowest load, any amount of electricity that would be in excess of that would have to come from other sources, all of which cost much more to run. They were load-following plants and peaker plants.

Baseload power plants were sited based on cost and access to resources they needed. Typically, they went up on inexpensive land at some distance from the market they served. They had to have access to fuel resources, which often meant that they needed their own docks or rail sidings. Also, they were often placed on bodies of water to take care of their cooling needs, which are great, because only about a third of the heat they produce could be used to generate electricity.

Originally, baseload plants mostly burned coal. When nuclear reactors were brought online, starting in mid-century, they fit right in with what was the current paradigm of the time. The difference was that they produced nuclear waste instead of air pollution and carbon dioxide.

We might note for reference here that when the state of Vermont was looking for a contract to replace electricity it had been getting from the Vermont Yankee (VY) nuclear plant, the owner of VY made an offer that they said the state could not refuse. It was the equivalent of 6.5¢ per kilowatt-hour (kWh). The state immediately found cheaper renewable electricity.

A New Paradigm

By contrast, today the least expensive source of renewable power need not be large. Solar panels operate at the same efficiency whether they be in utility-scale arrays or on a residential roof-top. Significant amounts of electricity can be generated by solitary wind turbines.

Of course there is a statement, “The sun doesn’t always shine and the wind doesn’t always blow,” which happens to fall into a range of unintentionally disingenuous to simply deceptive. The amount of electricity coming from a given solar array is really rather predictable and tends to come best in periods of light winds. And wind turbines do best when the sun is not shining brightest, so they compliment each other. But more to the point, while a single wind turbine can be idled in calm weather, the wind never stops blowing over wider geographical areas.

We might ask whether the problem of variable output of wind and solar power is as big as the problem of inability of baseload power to follow loads. The answer to this can be seen in the relative costs of electricity from load following and peaking plants, on the one hand, and batteries, on the other. We could do a detailed analysis of this, but it is really not necessary because the utilities are showing the results of their own analyses.

A number of utilities are replacing plants powered by natural gas, which includes most load-following and peaking plants, with solar arrays and batteries. In one case, Entergy Mississippi is planning to replace older natural gas plants with solar and windpower. In the case of Entergy Arkansas, a combined-cycle (base-load) natural gas plant it had planned will not be built, and the company will build renewable resources instead. (

Comparing Nuclear Power With Solar + Storage

An article in PV Magazine in August compared the cost of two new nuclear reactors with a combination of solar photovoltaics (PVs) and battery storage that would replace them functionally, as dispatchable power sources running full time. The article is titled, “Solar challenging nuclear as potential climate change solution.

The author, who had some expertise in systems that include solar+storage (S+S), used actual costs for the Vogtle reactors that are being built in Georgia. The two reactors, which have been under construction since 2013, are expected to come online in 2022 and 2023, at a cost of roughly $30 billion, including $3 billion in finance costs. Their capacities will be 1,117 megawatts each.

The PV Magazine article calculates the cost of a solar array big enough to provide the same output as the nuclear reactors in the winter in Georgia. It assumes battery storage to supply the output of the nuclear plants for 16 hours, increased by 10% to be safe.

The author shows that the cost of the S+S system designed to replace the two new Vogtle reactors would cost a little less than $17 billion. That would represent a saving of about $10 billion, not counting finance costs.

While that sounds impressive, the article fails in a number of respects. Here are some:

Output of the S+S system is calculated to be the same as nuclear in the dead of winter. The nuclear plant’s output will be constant year round, but the S+S system will produce far more electricity nearly all year than in the dead of winter. The value of the extra electricity from S+S is not accounted for.

The cost of the nuclear plant does not include the backup systems it requires, but the price calculated for S+S does.

The load-following and peaker plants used to work with nuclear power, are slow to react to demand changes. By comparison, battery backup can respond nearly instantly, making it far more valuable.

Nuclear waste is an unsolved problem that the US government guarantees, at taxpayer expense. The same is true for insurance, which is covered by the Price-Anderson act. S+S systems do not have comparable costs.

The author does not take into account Wright’s Law, a recognized law of economics referred to as “the learning curve.” It suggests that construction of a battery system of the size envisioned would be sufficient to drive the cost of storage down quickly enough to reduce the cost of the S+S system itself.

Electricity from new nuclear facilities is very expensive. It becomes far cheaper once the system is paid down. Please refer back to the bid from VY, of 6.5¢/kWh. By comparison the cost of electricity from S+S is very low. A report from February, 2020, which appeared at S&P Global, “Falling US solar-plus-storage prices start to level as batteries supersize,” says that power purchase agreements have dropped into the range of 3¢/kWh to 4¢/kWh. But the costs of solar, wind, and battery systems keep falling. According to the US DOE’s National Renewable Energy Laboratory, in an article published at CleanTechnica, the costs of S+S systems declined by over 12% from the first quarter of 2020 to the same quarter in 2021 alone.

Nuclear As An Answer To Climate Change

There are some who feel that the nuclear industry may have a way to become relevant in the new “small modular reactors.” An article on this appeared in the October, 2021, issue of Green Energy Times, “When It Comes to Nuclear Power, ‘Advanced’ Isn’t Always Better.” It explained that rhetoric around these reactors seemed to be unrealistic and achievable timetables were not able to help when we need most to address climate change, which is right now.

I would suggest that nuclear industry numbers about costs, timelines, and safety have historically been far off the mark, a problem that those promoting newer types of reactors have not addressed at all. In fact, it is almost as though the industry has three types of numbers.

There is one type that is simply correct, but it only relates to results of simple calculations.

A second type of number is one that relates to such things as the cost of a reactor or the time needed to build it. These seem very often to be off by a factor of 2. If a reactor is expected to take five years to build and cost $6 billion, it is probably best to bet that it will take ten years and cost $12 billion.

The third type is safety analysis calculations that can actually be checked have historically been off by an order of magnitude. Given the types of reactors that have operated commercially, the safety analysis made on them, and the time they have been running, we should probably have had one commercially operating reactor experience a partial or full melt down worldwide since commercial nuclear plants first started delivering energy. Instead, we have had eleven – that we know of.

All told, we might say that putting money into nuclear power goes beyond being a monumental waste. It detracts from the overarching issue of dealing with climate change by making that money unavailable for dealing with the problem using less expensive, more reliable energy that can be built far more quickly.

Featured image: San Onofre nuclear plant (awnisALAN, CC-BY-SA 2.0)


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




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




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)




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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