Dear Commission
Members:
The Iowa Chapter of
the Sierra Club hereby submits the following comments to the Commission’s Draft
Report:
The Sierra Club is a
non-profit environmental advocacy organization. Its Iowa Chapter has
approximately 5,000 members. The Sierra Club advocates for the transition from
non-renewable energy, including nuclear, to the use of clean and renewable
energy. We oppose nuclear power because of its many adverse impacts. We are
especially concerned about the environmental impacts of the mining of the
uranium to produce the fuel and the long-term impact of the spent fuel.
BEGIN TRANSITIONING AWAY FROM NUCLEAR ENERGY
This Commission’s
mission is to examine the issue of disposal of nuclear waste and to recommend a
new strategy for managing that waste. The quickest and easiest first step in
controlling nuclear waste is stop making more. It is clear from the fact that
this Commission has been formed that nuclear waste is dangerous and poses many
severe problems that are difficult, and perhaps impossible, to solve. It makes
no sense to compound those problems into the future by producing more waste. To
use a medical analogy, first stop the bleeding.
This Commission
should recommend that no new nuclear plants be built and that all existing
nuclear plants be shut down and decommissioned as soon as possible. This
suggestion is not contrary to or beyond the scope of this Commission’s task.
Your mission is to recommend policies to address the problem of nuclear waste.
The first and most important policy should be to make sure we do not add to the
problem. This fits perfectly with your mission. And although your report, at
one point, says your mission is not to make recommendations about the
appropriate role of nuclear power in the future, the sixth element of the
strategy you recommend is support for continued U.S. innovation in nuclear
technology. It seems that your report is contradictory and if you can recommend
continued use of nuclear power, you can also reconsider that recommendation and
recommend that nuclear power be discontinued.
Nor is our suggestion
of discontinuing the use of nuclear power unrealistic. The United States can,
and must, transition to clean and renewable energy.
BEGIN TRANSITIONING TO CLEAN AND RENEWABLE ENERGY
A 21st
Century energy policy must be defined by clean and renewable energy. Nuclear
energy is not clean and it is not renewable. If it were clean, this Commission
would never have been formed to deal with the problem of radioactive nuclear
waste.
Numerous studies
have shown that we can generate all the energy we need from renewable sources
with a comprehensive transmission and distribution grid if we will adopt
policies supporting that vision. See, e.g., Archer and Jacobson, Supplying
Baseload Power and Reducing Transmission Requirements by Interconnecting Wind
Farms, Journal of Applied Meteorology and Climatology (v. 46, Nov. 2007);
Jacobson and Delucchi, Providing All Global Energy with Wind, Water, and
Solar Power, Part I: Technologies, Energy Resources, Quantities and Areas of
Infrastructure, and Materials, Energy Policy (v. 39, p. 1154-1169);
Jacobson and Delucchi, Providing All Global Energy with Wind, Water, and
Solar Power, Part II: Reliability, System and Transmission Costs, and Policies,
Energy Policy (v. 39, p. 1170-1190. See also, The Energy Report:100%
Renewable Energy by 2050, prepared for the World Wildlife Fund by Ecofys
and found at www.worldwildlife.org/climate/energy-report.html.
The electric
utilities and energy companies assert that in order to provide baseload power
they have to use coal, natural gas or nuclear energy. But baseload as viewed by
the utilities and power companies is an outdated concept. They are stuck with
the narrow view of electric power coming from power plants. But rather than
referring to the term baseload we are really talking about energy and capacity.
Energy is the total amount of electricity that is being supplied to consumers.
Capacity is the highest level of electricity that can be supplied at any one
time to meet peak demand.
Renewable energy can
meet the energy and capacity demands of the country, combined with a program of
energy efficiency and conservation and expansion of the transmission grid. Most
states, including Iowa, have energy efficiency programs subject to public
utility regulation. This Commission should recommend a national energy
efficiency program. Likewise, many states have renewable electricity standards
requiring that a certain amount of the energy consumed in the state be from
renewable sources. This Commission should recommend a national renewable
electricity standard. There are other policies, including feed-in tariffs, tax
credits, loan programs, etc., that should be adopted to encourage the expansion
of renewable energy. This Commission should recommend that such policies be
studied and adopted. We realize that the Commission does not have time to study
all of these policies, but you should at least recommend that policies to
encourage renewable energy be studied and considered by the appropriate
entities. This would lead us to a renewable energy future and away from the
production of more radioactive nuclear waste.
The other important
policy needed to support renewable energy is expansion of the transmission
grid. We have heard the comment that since adequate transmission is not
available right now we need to continue to expand the use of nuclear energy.
That comment is incorrect for two reasons. First, expanded transmission is
occurring right now. The Federal Energy Regulatory Commission (FERC) has over
the past few years adopted policies to promote expansion of transmission lines.
The most recent FERC action is Order 1000 adopted on July 21, 2011. And every
area of the country has a regional transmission organization (RTO) that promotes
and coordinates expanded transmission in each respective region. In the
Midwest, for example, the Midwest RTO (MISO) had approved a number of
transmission expansion projects designed to accommodate increased renewable
energy production and they are ready for regulatory approval. Second, it takes
at least 10 years for a new nuclear plant to be licensed and put on line. New
transmission will begin to be constructed within the next year or two, long
before we would gain any alleged benefit from additional nuclear power.
Furthermore, a new nuclear plant, which would not be needed when renewable
energy becomes dominant, would be licensed for probably 40 years and
undoubtedly relicensed for another 20 years. We would be stuck with 60 more
years of radioactive waste that could be avoided with the right policies
supporting renewable energy.
All of these
measures are part of a 21st Century energy policy that must be the
replacement for coal, gas and nuclear power. The best part of renewable energy
is that the wind will always blow and the sun will always shine and neither
creates radioactive waste that lasts for millions of years.
CONCLUSION
This Commission can
perform a tremendous service to the policymakers and to the American people by
helping lead us to a sustainable 21st Century energy future by
recommending the policies we have suggested. Thank you for considering our
comments.
Very truly yours,
/s/ Wallace L. Taylor
Wallace L. Taylor
Legal Chair
/s/ Pamela Mackey Taylor
Pamela Mackey
Taylor
Energy Chair