May ___, 2022
Senator Aric Nesbitt
c/o Josh Przygocki
Director of Constituent Relations
P.O. BOx 30036
Lansing, Michigan 48909-7536
Re: Proposed Voluntary Nuclear Carbon Offset Recognized by the State of Michigan
Dear Senator Nesbitt,
As you are aware, on April 20, 2022, Governor Whitmer wrote to Secretary Granholm  of the U.S. Department of Energy to inform her that Michigan intends to qualify Palisades for funding through the $6 billion Civil Nuclear Credit (CNC)  authorized in H.R. 3684 – 117th Congress (2021-2022): Infrastructure Investment and Jobs Act. Governor Whitmer wrote, “. . . I intend to do everything I can to keep this plant [Palisades Nuclear Generating Station] open, protect jobs, and expand clean energy production.” In the last sentence, Governor Whitmer stated, “I will work with anyone to get this done.” As concerned residents of Michigan, we believe in the merits of keeping Palisades in operation and support Governor Whitmer on this critical, non-partisan issue.
Level the Playing Field
To stay open, Palisades and all U.S. nuclear plants scheduled to close prematurely, require an ability to compete on what is still a non-level playing field. Right now, energy markets do not reward Palisades for delivering clean energy, nor do the markets penalize natural gas for producing carbon emissions. Additionally, while other sources of clean energy, particularly solar and wind, can generate separate revenue streams by selling carbon credits to the voluntary carbon market, up until now, nuclear has been precluded from benefiting from these supportive revenue streams.
Today’s carbon credit markets are mostly voluntary and unregulated. Buyers pay to voluntarily offset their unavoidable carbon emissions to show their commitment to reducing their impacts on climate change. They are obligated to assess which carbon offsets they select to ensure their purchases have a real impact. Of course, most carbon credits have very doubtful benefits. A typical carbon credit may be to pay to plant trees. The calculation estimates how much carbon would be sequestered by a mature tree—however, there is great uncertainty as to whether that planted tree will grow successfully. Nevertheless, people buy such credits to showcase their climate commitment.
This commitment to the climate is becoming more popular and people are considering nuclear power once again. Soon after Governor Whitmer wrote her letter to Secretary Granholm, California Governor Newsom made a similar pledge to save the Diablo Canyon Nuclear Power Plant by applying to the DOE’s new CNC program. It seems the war in Ukraine, climate change concerns, and rising energy prices are causing a re-evaluation of the role nuclear power should play in our lives moving forward.
The CNC concept can help to level the playing field for threatened nuclear power plants with a federally funded form of “carbon credit.” In qualifying, Palisades will have to effectively prove “additionality,” which establishes that without the CNC funding, Palisades’ clean energy will be lost and replaced by fossil fuels. This is the essence of what constitutes a carbon credit in the normal voluntary carbon market. Therefore, if Palisades qualifies for the CNC’s federal funding, that should serve to verify its clean generation for the voluntary carbon credit markets, the majority of which are far less ascertainable than saving clean nuclear power.
Help Make Palisades a CNC Pioneer
Palisades is likely to be the first nuclear plant in the nation to qualify under the new CNC. We therefore propose a state-based resolution officially recognizing Palisades Nuclear Generating Station as a legitimate source to sell carbon offsets. Because Palisades resides in the 26th District, and your support for nuclear power is well known, we believe you can play a critical role in keeping Palisades operating by submitting a resolution to the legislature for official recognition of Palisade’s right to sell carbon offsets into the voluntary market. We suggest the resolution go into effect June 1, 2022 to provide Palisades with an option to obtain playing field-leveling funding that bridges the time between when Palisades qualifies for CNC funding and when Palisades would receive that funding, about a year later.
The resolution should encourage Michigan businesses, such as the automobile companies, Dow Chemical, Consumers Energy, our major universities and others to voluntarily purchase Palisades’ carbon offsets. Demand for carbon offsets far exceeds supply in the U. S. voluntary carbon offset market. We are confident Michigan’s businesses and institutions will jump at the chance to inform their customers and the public that they are reducing or eliminating their carbon footprint by participating in this voluntary market. The State of Michigan could also become a purchaser of carbon offsets for its own carbon footprint, serving to protect both clean energy and clean energy jobs at Palisades.
Keep Palisades Profitable
Carbon credits range in price per ton of offset emissions based largely upon the certainty of CO2 emissions being prevented or sequestered. Based on Palisades’ current power generation and assuming there are voluntary buyers, Palisades’ owner/operator could potentially earn an additional $500 million per year through the voluntary market – enough to keep the plant profitable.
Some of us believe all energy subsidies negatively distort the market to various degrees. Our request is made acknowledging this belief because energy subsidies are a current reality. This proposal is simply to enable the free market to trade nuclear carbon offsets voluntarily, based upon the DOE’s certification of Palisades’ additionality. Nuclear energy’s ability to participate in normal carbon offset markets could have a meaningful impact on its ability to remain competitive.
Create a Lasting Benefit for All Michiganders
This resolution could emphasize that Palisades would be profitable if it were allowed to compete fairly, and hundreds of good paying jobs in the 26th district would be saved, avoiding the negative economic impact of losing Palisades forever. All Michiganders would benefit by having stable 24/7 baseline power available at a reasonable price regardless of weather. In addition, Michigan might then become recognized as a potentially attractive demonstration destination for Generation IV Nuclear Reactor development, which many states are now vying to get, with the prospect of bringing new technology and jobs to their regions.
We can’t think of anyone more appropriately positioned to propose this resolution than you. It would be a non-partisan, highly effective solution that involves zero costs to the state to advance the interest of all Michigan residents and all U.S. citizens.
We thank you for your consideration and implore you to act quickly.
 Governor’s Office: Letter from Governor Whitmer to Secretary of Energy, Jennifer Granholm, April 20, 2022 (https://content.govdelivery.com/attachments/MIEOG/2022/04/20/file_attachments/2136675/Palisades%20Letter.pdf)
 DOE Seeks Applications, Bids for $6 Billion Civil Nuclear Credit Program, posted April 19, 2022 (https://www.energy.gov/articles/doe-seeks-applications-bids-6-billion-civil-nuclear-credit-program)
 L.A. Times, California promised to close its last nuclear plant. Now Newsom is reconsidering, by Sammy Roth, posted April 29, 2022 (https://www.energy.gov/articles/doe-seeks-applications-bids-6-billion-civil-nuclear-credit-program)