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Speak up for safety, transparency and environmental justice in DOE nuclear subsidy programs!

The Department of Energy (DOE) is seeking public comment on the next 5 years (Phase 2) of the Civil Nuclear Credit (CNC) program and we need your voice! The bipartisan Infrastructure Investment and Jobs Act mandated that DOE establish the CNC program to allocate $6 billion in “credits” (subsidies) to uneconomical nuclear reactors whose closures would result in higher greenhouse gas emissions.

To be clear, this is a bad bailout. This multi-billion dollar program should instead be invested in clean, renewable energy, NOT dirty and expensive nuclear reactors. And, if DOE does it’s job right, it will find that NO reactor in the country qualifies to receive these bailouts.

We must ensure:

CNC program requirements and eligibility criteria are clear, transparent, and consistent
CNC program does not squeeze the Nuclear Regulatory Commission (NRC) to overlook safety problems
Environmental justice impacts of CNC awards are fairly and rigorously assessed

Comment deadline: November 4, 2022

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Under the law, to be eligible to receive credits, nuclear reactors must meet three criteria:

Be shown to be unprofitable
Be at imminent risk of closing in the next 2 years due to being unprofitable
The closure of the plant would result in an increase of greenhouse gas emissions.

The DOE has never designed or implemented a credit program of this nature, so it’s important that they take into consideration the following before launching a multi-billion dollar nuclear bailout:

The CNC eligibility process must ensure transparency and accountability for how these funds are spent
The CNC vetting process must thoroughly verify that applicants meet the criteria for eligibility
DOE must consult with state governments to independently verify the projected emissions impacts of prospective reactor closures
Nuclear corporations currently under investigation for corruption should NOT be eligible for federal credits
The allocation of CNC funds should require companies to guarantee that they will NOT cut any jobs at reactors for which they are receiving these subsidies
The DOE must set up a thorough review of financial filings to ensure that reactors owners’ are truly eligible under the criteria

Background

On September 30, 2022, DOE released and requested feedback on draft Guidance for the Civil Nuclear Credit Program’s second award cycle. The draft Guidance describes the timelines, deliverables, and supporting information needed from eligible owners or operators of nuclear power reactors that are projected to shut down due to economic circumstances within the next four years to submit certification applications to become certified and instructions on formulating and submitting sealed bids to receive credit allocations.

Request for Public Commit on CNC Second Award Cycle Draft Guidance

Feedback is requested by 5 pm Eastern Time on November 4, 2022, and can be sent to rfi-cnc@nuclear.energy.gov.

https://www.energy.gov/gdo/civil-nuclear-credit-second-award-cycle

Department of Energy

Subject: Response to RFI: CNC Second Award Cycle Draft Guidance

Message:

Please consider the following comments: Sect. V - DOE must clarify the definition of “economic factors” to align with the competitive market requirement. Applicants must demonstrate they compete in a competitive electricity market and the ability to continue operating with no further (or reduced) CNC revenues after the award period. Reactors at risk of closure because they require major capital investments that are simply uneconomical should not qualify for the credits: they are at risk of closure because of mechanical factors (not economic factors) which would prompt a rational business decision to retire a power plant and invest in new generation. Sect. VI -The IIJA requires DOE to make findings that the NRC has reasonable assurance that the nuclear reactor a) will continue to be operated in accordance with the current licensing basis, and b) poses no significant safety hazards. This could place NRC in a conflicted position as a safety regulator. It is not NRC’s responsibility to make predictive assurances about the future performance of its licensees, but rather to ensure that each licensee is held accountable to its obligations under the Atomic Energy Act and the terms and conditions of its license. DOE must ensure that implementation of the CNC program does not place NRC in a conflicted position, nor that licensees receive disparate treatment by NRC for seeking a CNC award. As an alternative, DOE could request instruction from NRC as to the documentation that would enable DOE to ascertain the NRC’s judgment as to compliance with the current licensing basis and significant safety hazards. DOE could also ask NRC to provide notice when it finds a reactor receiving CNC credits is in violation of the license or poses safety hazards. Sect. VII.H. - The scope of information required is appropriate. These requirements include descriptions of negative impacts on disadvantaged communities, outreach, Tribes' feedback, steps to address feedback, and worker/community transition plans for eventual plant closure. DOE must apply a rigorous review to claimed benefits of CNC awards for disadvantaged communities. The May 2021 report on Justice40 implementation by the White House Environmental Justice Advisory Committee identified “procurement of nuclear energy” in a list of “Examples of the Types of Projects that Will Not Benefit a Community.” In this context, CNC awards will face significant barriers to qualify as Justice40 investments. The identification of Justice40-qualified benefits to disadvantaged communities must include both positive environmental impacts and economic benefits. - IIJA’s directive to prioritize CNC awards for reactors that procure their fuel from domestic sources may cut against Justice40 qualification. Domestic uranium mining and processing has an extensive record of polluting disadvantaged communities, resulting in widespread, multigenerational environmental health burdens.

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Speak up for safety, transparency and environmental justice in DOE nuclear subsidy programs!

Comment deadline: November 4, 2022

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Background

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