Replacement Before Retirement

Guest post by Jimmy Fortuna, Chief Product Officer at Enverus

A growing number of people today are rightly dismayed at the array of bad policies enacted in the name of decarbonizing electricity generation. Around the world, these policies have generally resulted in minimal emissions reductions, increasing electricity costs, and less reliable electrical grids. If that combination weren’t bad enough, the local effects of the same policies will soon result in the frequent shutdown of power plants that today provide high-quality, generationally secure jobs. Especially in rural communities, people now find themselves facing the daunting trifecta of reduced employment opportunities, increased energy costs, and the vulnerability of reliance on distant places for the vital resource of electricity. For advocates of nuclear energy, these outcomes are particularly frustrating, since history has repeatedly proven that utilizing nuclear energy simultaneously eliminates carbon emissions, reduces costs, maximizes energy security, and provides high-quality, lifetime employment opportunities.

Rightly frustrated with these damaging policies, some observers propose broad regulatory rollbacks to open pathways to solutions that will adequately provide reliable energy supplies while meaningfully addressing climate concerns. They should be careful what they wish for. It was a deregulatory push in electricity markets at the turn of the century that created a vacuum into which chaos and self-dealing rushed, laying the groundwork for today’s state of failure and regression. Simple regulatory rollbacks are therefore an untrustworthy solution to the complex problems associated with energy, the environment, and the people who depend on both for their quality of life. What then is to be done? Over the long haul, the answer lies less in regulatory particulars than in the principles that give rise to them.

Regulations are, of course, simply rules – rules which are almost always crafted to constrain or otherwise steer the behavior of business institutions. A particularly relevant thought related to rules and their effectiveness is attributed to Dee Hock, the man who founded Visa International in 1970 and thereby created what have since become the cashless commerce systems that we find globally indispensable today:

“Simple, clear purpose and principles give rise to complex and intelligent behavior. Complex rules and regulations give rise to simple and stupid behavior.”

A half-century later, the energy sector now finds itself supplied with an abundance of needlessly complex rules that give rise to simple and stupid behavior. Among nuclear technology advocates, the Nuclear Regulatory Commission’s rulebook is a favorite target of criticism in this regard, but there are other poorly crafted regulatory schemes that deeply afflict the energy sector. Each of the ever shifting, rarely improving “rulebooks” that now govern various parts of the U.S. electricity grid are often just as pernicious and destructive of an energy-positive future as the obsolescent sprawl overseen by the NRC.

Corollaries of Hock’s statement above provide helpful guidance regarding both how we got here and what to do about it. Consider that the simple, clear principles which work for or against something are vital to durable policy victories. In the case of nuclear energy, an historic case of “against” is easily found.

Educated nuclear advocates are aware of the Linear No-Threshold (LNT) Hypothesis and the As Low as Reasonably Achievable (ALARA) standard – LNT’s inevitable policy outgrowth. These two clear, simple principles dictated first that any amount of radiation no matter how small is harmful and second that no upper limit to cost should be accepted when aimed at minimizing any possible exposure to nuclear radiation. Of course, this scientifically indefensible combination has caused costs associated with nuclear energy to escalate without limit or benefit and served as a nearly perfect impediment to the buildout of nuclear energy since the 1980s. In other words, they have been quite effective, lying as they do at the very root of so much of what misgoverns nuclear energy to the present day. By comparison, the extraordinary expanse of the NRC’s rules which we might aim to either prune or shape differently are merely the branches of the problem at best and often as not the mere twigs. While concerned citizens should take any victory they can get – and improving something at the edge of the NRC’s rulebook would be better than nothing – real and lasting reform will come only from cutting the root.

But if better energy policies inclusive of nuclear power in the energy mix are the urgent objective, then targeting advocacy efforts directly at ALARA and LNT now might be much slower and more costly than hoped. Attempts at rolling back the inscrutable regulatory webs associated with today’s regional electricity markets may also be fruitless. What then might be more effective, and how might it be leveraged for an expansive and lasting policy victory?

Among the most damaging and least defensible actions taken in energy policy today are mandates for retiring existing electricity generation without firm assurance that something will adequately replace it. Therefore, perhaps this is the place at which advocates should fight hard for a simple, clear principle that would prevent such mandates. That principle might be expressed as “Replacement before Retirement,” and the goal of applying it would be to get legislators and policy makers to properly codify it into law. Thereafter, anyone wishing to retire a fossil-fueled power plant and thereby eliminate its emissions would first be required to commission one or more zero-emissions assets in its place that could adequately replace the original facility. Relying on an imported electricity supply of nebulous origin delivered from somewhere far away would not qualify, because for the people reliant on the original power facility, “doing their part” to reduce emissions does not mean hoping that someone else, somewhere else might someday do it for them. Similarly, replacing a fossil-fueled asset with something that can only do its job part of the time would self-evidently not meet the standard of adequate replacement.

A properly formed principle of “Replace before Retirement” would not advocate for or against any specific energy resource. Rather, it would simply require resource equivalence without emissions. A natural gas fired peaker plant, for example, might be adequately replaced with wind or solar generation paired with battery electric storage. To adequately replace a baseload coal-fired plant and eliminate its emissions, wind or solar resources could also pair with a natural gas power and carbon capture technology. Of course, that same coal fired plant could also be replaced with a nuclear power facility. Both properly informed and guided by law, policy makers would be free to choose which options best met the preferences of their constituents, comparing replacement options based on various factors including cost, safety, reliability, and land use.

Helpfully, “Replace before Retirement” might be difficult for public officials to stand against. It passes commonsense tests for most anyone, whether they understand the many complexities of electric power or not. Who, for example, would move out of their home before having an adequate place to move to, relying instead on the kindness of strangers for their shelter? These are concepts that voters can connect with.

Obviously, the specifics of implementation in law would matter a great deal. Careful attention to detail for crucial value characteristics such as dispatchability and capacity factors would be a must, as would real-world emissions capture where applicable. But, embodied properly in law, the principle would at minimum give political constituents legal recourse against bad decisions – including locally affected communities. This would likely mean that destructive policies would be much harder to carry out than they are today.

The forces presently arrayed against logical energy policy in the pursuit of narrow interests have proven themselves very good at using rules to make things they don’t like difficult and expensive, and all those rules emerged from principles that could give rise to little else. Perhaps proponents of rational energy policy – including nuclear advocates – can learn from that. The pursuit of reasonable principles like “Replace before Retirement” could prove as hazardous to senseless policies as bad principles have been to sensible ones, even if galling, unscientific principles such as LNT and ALARA can’t yet be excised from policy. Presented with fewer bad alternatives over time, policy makers may be more inclined to select good ones. It is possible that the advancement of nuclear technology as a logical part of the energy mix may someday seem as inevitable as it now seems difficult. If so, both local communities and the global community may yet be preserved and made more prosperous.

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