Comment submitted to the EPA regarding the proposed carbon emissions rules

As an engineer (BSEE, University of Kansas, 1988), I generally support the proposed new EPA regulations on carbon pollution for electrical power generation, with the exception of the rules concerning the contribution of nuclear-powered generation. In particular, the accounting of nuclear power in the calculations of CO2 output, as proposed, makes no sense to me, from a scientific, engineering, or mathematical standpoint.

The contribution of existing nuclear-powered electricity to our supply should be treated equally, by including 100% of its output in baseline CO2 generation calculations — no more, no less.

States in which new nuclear plants are being constructed should not have those plants included in existing production calculations, but rather those plants should be included in calculations of CO2 reduction targets. Those calculations should include 100% of that new production — no more, no less.

A production facility that generates electrical power with a low carbon footprint by using nuclear power should be treated the same as a facility that does the same via solar, wind, hydro, efficiency programs, or any other means.

Low-carbon is low-carbon. The objective of the EPA carbon-reduction rules should not be to favor one technology over another for any other reason than their comparative abilities to accomplish the specific goal of reducing such emissions.

-Eric Schmitz
Bloomington, Indiana