We need your help to protect grid reliability

(NOTE: THIS CAMPAIGN HAS ENDED, SEE PART 2: SUPPORT GRID RELIABILITY)

In mid-August, California faced the largest power outages in its history right amid record heatwaves and unprecedented amount of smoke pollution that obscured the skies as a result of record-breaking forest fires. The scary and sad reality of climate change is that this may be an increasing part of our future.  On the other hand, there is a lot that we can do to improve the reliability of our grid, rather than allow our grid reliability to be further weakened.

An opportunity exists right now to throw your support behind an action taken by Californians for Green Nuclear Power (CGNP), a non-profit environmental group in California that has called on the Federal Energy Regulatory Commission, known as FERC, to step in and review the planned retirement of California’s largest single source of clean energy and the only source of firm clean power—Diablo Canyon—as a threat to California’s grid reliability.

(Graph shows California’s vulnerability to outages from wind, solar and gas)

Californians for Green Nuclear Power filed a complaint with FERC in late October asking that they investigate whether the decision shutting down Diablo Canyon violates federal grid reliability standards (EL21-13). The “voluntary”plan to retire Diablo Canyon was a result of prejudicial Renewable Portfolio Standards that, rather than reward PG&E for Diablo Canyon’s clean and reliable energy, penalized PG&E by not accepting allocations of this energy towards the state’s clean energy portfolio, despite Diablo having the most reliable energy in California. This prohibition plus other factors forced PG&E into agreeing to retire the plant in 2025.  This was done through a highly politicized process that did not properly analyze the adverse impacts to the reliability of the grid from this closure.  PG&E may have succeeded in getting compensated for agreeing to shutter Diablo Canyon but California rate payers will suffer when their grid fails for long periods of time as a result of this closure.

The complaint further alleges that the North American Electric Reliability Corp. (NERC), which crafts and enforces the reliability standards for the bulk power system, and the Western Electricity Coordinating Council (WECC), a regional compliance authority of NERC, “failed to conduct proper oversight or enforce NERC’s reliability standards to prevent reliability standards violations caused by removing [Diablo Canyon’s] 2,240 MW from the California electric grid.”

What you can do to help

CGNP needs your support to get FERC to review the CPUC’s plan.  You can write a letter in support and submit it online or join as an intervening party.  Directions are below but all submittals have to be done by 5:00 pm EST on November 16, 2020.

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Step 1: Learn more by going to FERC site

Go to the FERC website and search for the CGNP docket. Use docket number EL21-13-000 with the link to access all of CGNP’s filings as well as all submittals of comments and interventions since the action was filed on October 26, 2020. These are available at no-cost download (link: https://elibrary.ferc.gov/eLibrary/idmws/search/results.asp?searchType=docket). Once there, enter CGNP Docket #  EL21-13-000 into the box at the top which says “Enter Docket Number” that allows you to search by docket number.  You will be able to see everything in chronological order. 

If you have never submitted a comment to FERC before, here are general F.A.Q.s about submitting comments to FERC. Note that all parties must be copied on the submittal but that can be done by email. (link: https://www.ferc.gov/about/what-ferc/frequently-asked-questions-faqs/frequently-asked-questions-faqs-active)

Step 2: Submit a supportive comment

(ANS’ Comment to FERC as an example)

Anyone, individual or organization, can submit a comment to FERC (called an eComment, as long as it is less than 6,000 words). After reading through the docket materials, write out your comment with your reasons for supporting CGNP’s demand that FERC review the issue of decreased grid reliability for California in the decision to shutter Diablo Canyon, first.  Once you have the text you want to use, then go to the FERC Online page.  If you want to comment as an individual and your statement is less than 6,000 words, you can use the eComment feature.  You will need to provide the docket number for the case, which is Docket No: EL21-13-000

Note: American Nuclear Society (ANS) has submitted a comment in support of the issues that CGNP raised, which you can use as an example of the kind of statement that you might provide. Those filing comments in opposition include Public Citizen, Friends of the Earth and San Luis Obispo-based Mothers for Peace. You can find these statements in the docket and choose to address the issues that they raise in their claims.

Step 3: Determine if you should be an intervenor

(You can submit a very basic statement online and be added as an intervenor.)

If you or your organization have standing to participate—i.e. will be materially affected by the outcome or have a stake in helping to determine the outcome—then you should consider becoming an intervenor.  Consider that this is “a never-before-explored avenue to protect an operating nuclear power plant. The grounds are that Diablo Canyon Power Plant makes vital reliability contributions to California’s electric power grid and supports the reliability of the state’s natural gas system as well.”  Groups like PG&E, SoCal and the Edison Electric Institute (EEI) have intervened to become a party to this proceeding. EEI’s intervenor motion states how pertinent this matter is for all decisions to shutter nuclear power plants across the US: “EEI’s members include generator owners and operators, transmission owners and operators and other entities that are subject to the mandatory NERC Reliability Standards and thus may be affected by the outcome of this proceeding.”  To become an intervenor, you must follow the FERC Online steps for eFiling.  This requires registering with FERC but it does not require that a long state be written, just a simple assertion of standing to intervene. The image on the right is a sample of PG&E’s assertion of a material interest in the matter.

Step 4: Share with the members of your network who #KnowNukes

STEP 4:  Share information about the CGNP action with those who understand the importance of clean nuclear power to our low-carbon future. Please consider sharing with your pronuclear social media networks by sharing this page (https://climatecoalition.org/support-grid-reliability/) with others you know who can and should intervene or comment.  An example of a tweet is:  [We support #CaliforniansforGreenNuclearPower in their @FERC action to review whether #GridReliability impacts were properly considered by those who agreed to the forced early retirement of #DiabloCanyon. You can help #SaveCleanReliableNuclearEnergy here: https://climatecoalition.org/support-grid-reliability]

Click on the document on the right for FERC’s How-to Guide for Online Public Commenting.  It’s not difficult to follow these steps—especially if you take time to write out your response first—and your submission can have an important impact on the proceedings.

Step 5: Support CGNP

STEP 5:  Californians for Green Nuclear Power, a small non-profit, has funded the research and legal work that was required to submit this important action—consisting of more 700 pages of documentation—to FERC. If you are unable to take the time to submit a comment or intervene, you can still support CGNP’s efforts by becoming a member for $30 a year or by simply donating to help them fund their expenses.

Thank you for your consideration and support!

 

Climate activists who #KnowNukes don’t say “No Nukes,” they say “Save our nuclear and shut down natural gas!”