Bicameral Nuclear
Energy Caucus
Senator Ryan P. Aument
District 36
Senate Box 203036
Harrisburg, PA 17120-3036
(717) 787-4420

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Bicameral
Nuclear Energy
Caucus Report
2017-2018 Session

Senator John T. Yudichak
District 14
Senate Box 203014
Harrisburg, PA 17120-3014
(717) 787-7105

Representative Becky Corbin
District 155
PO Box 202155
Harrisburg, PA 17120-2155
(717) 783-2520

Representative Robert F. Matzie
District 16
PO Box 202016
Harrisburg, PA 17120-2016
(717) 787-4444

Co-Chairs
Senator Ryan P. Aument
Senator John T. Yudichak
Representative Becky Corbin
Representative Robert F. Matzie

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

TABLE OF CONTENTS
1.

About the Nuclear Energy Caucus . . . . . . . . . . . . . . . . . . . 2

2.

Nuclear Energy Caucus Memorandum . . . . . . . . . . . . . . 3

3.

Pennsylvania’s Nuclear Energy Industry. . . . . . . . . . . . . . 8

4.

Epidemic of Premature Plant Shutdowns . . . . . . . . . . . 12

5.

Premature Plant Shutdowns: Jobs, Economy
and Consumer Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

6.

Premature Plant Shutdowns: Environmental
and Public Health Impacts . . . . . . . . . . . . . . . . . . . . . . . . . 21

7.

Premature Plant Shutdowns: Grid Resilience
and National Security Impacts . . . . . . . . . . . . . . . . . . . . . 24

8.

Other State’s Actions and Potential Options . . . . . . . . 30

9.

Other Considerations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

10. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
11. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Table of Contents   1

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

1. About the Nuclear Energy Caucus
On March 16, 2017, Senators Ryan Aument (R-Lancaster) and John Yudichak (D-Carbon/Luzerne)
along with Representatives Becky Corbin (RChester) and Rob Matzie (D-Allegheny/Beaver) announced the formation of the Pennsylvania Nuclear
Energy Caucus (“NEC” or “caucus”) a bi-partisan, bicameral caucus of Pennsylvania’s General Assembly
to focus on nuclear energy issues.
The caucus, the first nuclear caucus in a state legislature in the history of the United States, was formed
to give members of the General Assembly an opportunity to become more educated about nuclear energy’s importance to the Commonwealth’s energy
portfolio, economy, and environment.

•

Promote nuclear energy as a clean, safe,
reliable and affordable source of electricity to
power Pennsylvania’s economy and achieve
environmental goals.

•

Advocate for the Commonwealth of
Pennsylvania to recognize nuclear energy’s
zero carbon emission attributes, similar to other
zero carbon technologies.

•

Promote and seek to preserve the positive
contributions the nuclear industry provides
to the Commonwealth’s economy through
employment at the nuclear plants, indirect
employment through vendors and contracted
labor, civic and philanthropic engagement, and
taxes paid by the industry’s workforce
and businesses.

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2   About the Nuclear Energy Caucus

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To date, the caucus has over 75 members and has
hosted numerous educational meetings and tours
of the Commonwealth’s nuclear facilities, has supported pro-nuclear resolutions in the State Senate
and House of Representatives, and has weighed in
as a collective body with the regional electric grid
operator, PJM, and with the U.S. Federal Energy Regulatory Commission (“FERC”) on issues relevant to
the preservation of Pennsylvania’s nuclear industry.

The guiding principles of the Nuclear Energy Caucus
are to:

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 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

2. Report Transmittal Letter from Nuclear Energy
Caucus Co-Chairs
TO:

Members of the General Assembly

FROM:

Chairs of the Nuclear Energy Caucus:
Senator Ryan Aument
Senator John Yudichak
State Representative Becky Corbin
State Representative Rob Matzie

Subject: Report on the Findings of the Bicameral Nuclear Energy Caucus during the 2017-2018 Session
of the Pennsylvania General Assembly
Pennsylvania is the second largest nuclear capacity state
in the nation and is home to nine nuclear reactors at five
nuclear power plants – Beaver Valley Nuclear Power
Station in Beaver County, Susquehanna Nuclear Power
Station in Luzerne County, Three Mile Island Unit-1
Generating Station in Dauphin County, Peach Bottom
Atomic Power Station in York County, and Limerick
Generating Station in Montgomery County.
The power produced by these five nuclear plants
represents 42% of the Commonwealth’s total electricity
production and just over 93% of Pennsylvania’s zeroemission energy.
The nuclear industry supports 16,000 jobs in
Pennsylvania and contributes more than $2 billion
annually to the Commonwealth’s gross domestic
product.1 Promoting and preserving these important
benefits provided to our citizens by our Commonwealth’s
nuclear industry are precisely the reason the Nuclear
Energy Caucus was created.
Exelon’s May 2017 announcement that its Three Mile
Island (“TMI”) plant will prematurely retire2 in September
of 2019, was news that created a great deal of distress
both in the community around the plant and with
members of the caucus.

Here are an independent consultant’s findings about the
nuclear power industry in Pennsylvania:3
Our analysis has determined that the nuclear
plants operating in Pennsylvania :
• Contribute approximately $2 billion to
state gross domestic product (“GDP”)
($3.1 billion in gross output).
• Account for 15,900 in-state full time jobs
(direct and secondary).
• Help keep electricity prices low.
Pennsylvania consumers would pay $788
million more annually (2016$) and $6.6
billion more over the next ten years (on
a present value basis) without these plants.
• Are responsible for $69 million in net
state tax revenues annually.
• Avoid over 37 million tons1 of CO2
emissions annually over the next ten years,
valued at $1.6 billion per year.
• Avoid significant amounts of criteria
pollutants annually, valued at $260
million per year over the next ten years.
The concern about TMI’s imminent closure was exacerbated by FirstEnergy’s announcement, in March 2018,
that it would be prematurely retiring its Beaver Valley
Nuclear Power Station in 2021.

1 Pennsylvania

Nuclear Power Plants’ Contribution to the State Economy (The Brattle Group, 2016)
plant engineers may think a power plant retired prematurely if it has not yet run to the end of its nominal design life (for instance, approximately 40 years for post-1970 coal plants) or through the term of reasonable plant life extension modifications. Nuclear or hydroelectric plant owners
and regulators may think a power plant has retired prematurely if it has not yet run through the full term of its operating license and/or license extension. Federal Energy Regulatory Commission (FERC) hydro licenses run for up to 50 years with potential reauthorizations of 30–50 years, and Nuclear
Regulatory Commission (NRC) nuclear operating licenses run for 40 years with potential 20-year extensions. Source: Staff Report on Electricity Markets
and Reliability, United States Department of Energy, August, 2017, pg. 7.
3 Ibid., 1.
2 Power

Report Transmittal   3

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

According to the plants’ owners, these two plants together directly employ more than 1,500 Pennsylvanians
and provide millions of labor hours for thousands of
contract workers in the building and construction trades.
The loss of both Beaver Valley and TMI, coupled with
continuing and unmitigated financial pressures being
applied by a dysfunctional wholesale electric market is
something that members of the caucus fear could be a
devastating and permanent blow to Pennsylvania’s
economy and environment.
Both plants are being retired well before their current
operating licenses are set to expire4 and once these
plants are shut down, there is no mechanism in place to
bring them back into operation. The unfortunate bottom line is that once these plants close, Pennsylvania will
lose all the jobs and other benefits they provide, forever.
One of our top priorities in creating the Nuclear Energy
Caucus was to ensure our members are educated
about the value the nuclear energy industry provides
Pennsylvania and our citizens.
As state lawmakers, we take seriously our obligation to
set energy policies that help promote Pennsylvania’s
economy and protect our environment.
On the heels of these shutdown announcements, the
caucus sought to understand the underlying causes for
their premature retirements, and to determine if these
announced closures were an anomaly or if they are a
symptom of a larger problem for Pennsylvania’s
nuclear industry.
The caucus also sought to understand the employment,
economic, and environmental impacts associated with
the shutdowns and determine if there are any actions
the General Assembly or the Commonwealth has or
should be undertaking to prevent the premature closure
of these plants. The caucus began to host a series of
meetings with industry stakeholders and subject matter
experts to find answers to these questions.
The first meeting held by the Nuclear Energy Caucus in
2018, following the Beaver Valley announcement, featured a timely industry update from Pennsylvania’s nuclear station owners, including FirstEnergy Solutions,
Talen Energy and Exelon.5
4 Beaver Valley

The companies provided their view that, despite operating these facilities at world-class levels of efficiency, they
are shortchanged by a marketplace and federal and state
policies that do not compensate these plants for the
environmental and grid-resilience benefits they provide.
Environmental Benefits – Pennsylvania’s nuclear power
plants prevent substantial emissions of CO2, SO2, NOx,
and particulate matter, compared to the alternatives
of natural gas and coal-fired generation that would
replace them.
Grid Resilience and Reliability – Unlike natural gas or
coal-fired power plants, nuclear plants do not rely on
pipelines or train cars to provide a lifeline of fuel to generate electricity. Rather, nuclear plants can run 24/7 for
18-24 months without refueling. The 2014 “Polar Vortex”
and the “Bomb Cyclone of 2018” cold weather events
were illustrative of nuclear’s value to the resilience of
the grid.
Dr. Dean Murphy of the Brattle Group also participated in
this first meeting to give the caucus an overview of the
findings of their report, Pennsylvania Nuclear Power
Plants’ Contribution to the State Economy.
In his comments, Dr. Murphy reinforced the companies’
claims and reported that the Brattle study found “absent
Pennsylvania’s nuclear plants, Pennsylvania consumers
would pay significantly more for electricity, the economy
would suffer both in terms of Gross Domestic Product (GDP)
and jobs, and there would be substantially higher emissions
of CO2 and other pollutants.”
The caucus’ second meeting last spring focused on
the job losses that would result from nuclear plant
shutdowns.
Representatives from state and regional building trades
councils presented their views of the devastating impact
plant closures will have on the livelihoods of their members. The panel of Pennsylvania’s labor leaders was
unanimous in its view that the work opportunities provided by the nuclear industry are critically important to
the careers of the building trades workers because of the
sustained nature of the work and the frequent succession of temporary assignments.

Power Station Unit 1 is licensed to operate until 2036 and Unit 2 is licensed through 2047. Three Mile Island Generating Station Unit 1 is
licensed to operate until 2034.
5The Nuclear Energy Caucus convened a year earlier by hearing from grid operator PJM on April 26, 2017.

4   Report Transmittal

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

They shared that nuclear power plant maintenance is
especially significant to the building trades given the
amount of labor required during each maintenance outage. The panel pointed out that the General Assembly
often jumps at the opportunity to find ways to attract
jobs to Pennsylvania and encouraged the caucus to
consider the opportunity to preserve nearly 16,000
nuclear industry jobs in Pennsylvania as an equally
important priority.
The caucus later hosted a meeting with both national
and statewide environmental organizations to hear
their views on the impact nuclear plants have on
Pennsylvania’s air quality and their concerns about the
negative impact the premature plant shutdowns will
have on our environment. The organizations represented at the meeting were the Pennsylvania Environmental Council, the Environmental Defense Fund, the
Center for Climate and Energy Solutions, and the Union
of Concerned Scientists.
All four of the organizations agreed that the premature
shutdown of a nuclear plant would set back Pennsylvania’s air quality decades in terms of emission reductions,
particularly for carbon emissions. They cited a recent
study that showed that nuclear plant closures in Pennsylvania and Ohio (Beaver Valley, Three Mile Island, DavisBesse and Perry) will increase CO2 emissions about 21
million metric tons per year, which is the equivalent of
increasing cars on Pennsylvania’s roads by 50%, virtually
erasing 25 years of progress in the development of wind,
solar, and other zero-emission resources in the region.

Edward McGinnis, Principal Deputy Assistant Secretary,
Office of Nuclear Energy, United States Department
of Energy.
Dr. Stockton and Deputy Assistant Secretary McGinnis
vividly outlined why nuclear energy is a critical component to America’s overall national security interests noting that the United States’ dominance in nuclear energy
has allowed the U.S. government to set best practices for
nuclear nonproliferation around the world, exert geopolitical influence, and support the U.S. naval propulsion
program and nuclear weapons program.
The caucus also reviewed a recently released report, Back
from the Brink: A Threatened Nuclear Energy Industry,
which summarized the negative consequences of losing
the commercial nuclear sector relative to U.S. national
security objectives.
Finally, the caucus was made aware of a letter from more
than 70 national security experts, including former Pennsylvania Governor and U.S. Homeland Security Director,
Tom Ridge, urging the U.S. Department of Energy to,
“take concrete steps to ensure the national security attributes of U.S. nuclear power plants are properly
recognized by the policymakers and are valued in U.S.
electricity markets.”

Each one of the environmental groups recommended
Pennsylvania should focus on emission outcomes and
put in place clear regulatory requirements to ensure
those outcomes are met.

In addition to these in-person meetings, members of the
caucus have met with and/or corresponded with various
experts in the fields of energy policy, national security
and grid resilience, wholesale electricity markets, and
economics, and all have shared valuable information
that has helped the caucus compile the most comprehensive record of the challenges facing the nuclear
industry and the impacts these challenges will have on
the Commonwealth.

For example, they suggested placing a price on carbon
and setting carbon reduction targets would allow the
market the ability to determine how best to achieve
those environmental goals.

This report contains all this information. It is our hope
that our colleagues in the General Assembly will benefit
from the information the caucus has collected on this
very important topic.

Finally, the caucus hosted a meeting to discuss the
topic of nuclear energy’s value to grid resilience and
national security.

Where to Go from Here

Expert testimony was offered by Dr. Paul Stockton,
former Assistant Secretary of Defense for Homeland
Defense and Americas’ Security Affairs, as well as

Throughout the 2017-2018 Regular Session of the
Pennsylvania General Assembly, various opportunities
arose for the caucus and its Chairs to voice our support
for Pennsylvania’s nuclear industry and to correspond
with its regulators about our collective concern for the
Report Transmittal   5

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

future of the industry and encourage them to take actions to address the inequity in the treatment of these
resources. In a letter to the PJM Board of Managers,
dated February 9, 2018, we cautioned that:
While Pennsylvania currently benefits from
numerous sources of electric generation – including
coal, nuclear, natural gas, hydroelectric, and
renewables – we are losing confidence in the
ability of the wholesale electric markets to ensure
Pennsylvania maintains a diverse supply of
baseload generation resources that ensures stable
prices for our citizens and a reliable and resilient
electrical grid. Pennsylvania’s baseload power
plants continue to face the risk of premature
retirement, and we do not see expeditious and
sufficient action being taken by PJM or the Federal
Energy Regulatory Commission (“FERC”) to correct
the market flaws at the heart of this problem
– flaws that PJM itself acknowledges.
The caucus leadership was also successful in encouraging the members of the General Assembly to overwhelmingly adopt resolutions calling on FERC to take
swift action to address concerns about the loss of
baseload generation and its impact on grid diversity
and resiliency.
The October 2017 resolutions (SR227 and HR576) recognized that “absent market reforms to properly compensate
generators for currently uncompensated attributes, generation (including nuclear generation) in Pennsylvania is at severe risk of premature retirement.”
In further efforts to encourage FERC to work towards a
solution, the caucus leadership penned a letter to the
Pennsylvania Public Utility Commission (“PUC”) asking
the PUC to submit comments to FERC opposing PJM’s
market reform proposals.
As we noted in our letter, both proposals were seriously
flawed because they were designed to undermine state
efforts to value the environmental and resiliency attributes of nuclear generation. Should these PJM proposals
be adopted our Commonwealth’s ability to successfully
achieve these important goals would be lost. The PUC in
fact weighed in as requested with the FERC and FERC has
recently rejected PJM’s flawed proposals.

6   Report Transmittal

In their rejection, FERC decided to do something dramatic to call the question of whether or not states really
want to participate in wholesale power markets and to
either push them back to reregulation or force them to
find a way to price in the attributes (environmental, reliability, etc.) they want the markets to procure. PJM will
have to develop a solution to this problem, and the Commonwealth will have an opportunity to influence PJM
and encourage them to learn from their past mistakes of
ignoring state preferences when developing solutions.
As the Chairs of the Nuclear Energy Caucus, we sought to
be more than a cheering section for the industry. We
were willing to do the hard work of seeking answers to
these pressing questions to arm our fellow members
with the information necessary to craft a real solution.
Of this we are now certain, that solution cannot be a
federal, state, or regional solution alone.
The solution will require leadership decisions to be made
at all levels if we are to retain these valuable assets that
benefit our Commonwealth.
Therefore, this report not only contains information
about the impact of premature plant shutdowns, but it
also contains background on solutions other states have
successfully implemented that have survived legal
challenge. Other states have decided not to wait for
help from PJM or Washington, D.C., and have taken
matters into their own hands.
It is the view of the Chairs of this caucus that a similar
path may be necessary in Pennsylvania, but that is a
decision we will have to make as a collective body along
with the Governor.
We look forward to continuing this discussion in the
2019-2020 session.

NEC Activities 2017-2018
March 16, 2017 – Lawmakers announce formation of
first ever Nuclear Energy Caucus
March 28, 2017 – Op-Ed: Nuclear Energy: A Keystone for
Pennsylvania’s Economy and Environment
April 26, 2017 – Nuclear Energy Caucus hosts hearing
with PJM Interconnection, LLC

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

May 30, 2017 – Nuclear Caucus Chairs issue statement
on announcement of closure of Three Mile Island
Nuclear Generating Station
October 23, 2017 – Sen. Aument and Sen. White to
FERC: Fuel-Secure Baseload Generation at Real Risk
February 9, 2018 – Nuclear Energy Caucus Co-Chairs
send letter to PJM Interconnection expressing frustration and concern over current market constructs and
requesting expeditious consideration of energy price
formation proposal
March 29, 2018 – PA Nuclear Energy Caucus Chairs
react to FirstEnergy Nuclear Plant deactivation
notices
April 17, 2018 – Nuclear Energy Caucus hosts meeting
on nuclear plant operators, and briefing from Brattle
Group on economic and environmental consequences
of nuclear station closures
April 26, 2018 – Nuclear Energy Caucus Co-Chairs and
Chairman of the Senate Consumer Protection and
Professional Licensure and House Consumer Affairs
Committee forward letter to the PA Public Utility
Commission requesting their intervention in FERC
proceeding that would eliminate state rights
May 27, 2018 – Nuclear Energy Caucus hosts meeting
to discuss the value of nuclear power to Pennsylvania
labor
June 19, 2018 – Nuclear Energy Caucus hosts meeting
to discuss impact of nuclear station deactivations on
air quality
September 25, 2018 – Nuclear Energy Caucus hosts
meeting to discuss energy and national security
issues.
October 1, 2018 – Nuclear Energy Caucus hosts
meeting to receive update from PJM Interconnection
and nuclear station operators

Report Transmittal   7

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

3. Pennsylvania’s Nuclear Energy Industry
Summary:
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Nuclear energy is the largest source of electricity in
the Commonwealth.
The nuclear energy industry supports nearly 16,000
Pennsylvania jobs.
It adds $2 billion annually to state Gross Domestic
Product (“GDP”).
Pennsylvania’s nuclear plants prevent over 37 million
metric tons of CO2 emissions annually.
They avoid air pollutants (NOx, SO2, PM10 and
PM2.5) whose adverse effects would otherwise cost
the Commonwealth the equivalent of $260 million
annually.
If announced early closures proceed, Pennsylvania
will lose one fourth of its nuclear power by 2021.

Figure 1: Location of Pennsylvania Nuclear Plants

Source: The Brattle Group. Pennsylvania Nuclear Power Plants’ Contribution to the State
Economy. Dec. 2016.

Deeper Dive:
Pennsylvania has nine nuclear energy reactors at five
sites (Figure 1). Pennsylvania’s nuclear power plants provide 9,600 MW of reliable capacity. They generate 83 million MWh of electricity a year, comprising 42% of the
state’s generation - enough to power 57% of the state’s
6CY2016

electricity use - and 93% of the state’s emissions-free energy.6 In Pennsylvania, nuclear produces more electricity than either natural gas or coal, and 13 times as much
as wind, solar, and hydroelectric combined.7
Pennsylvania’s nuclear power plants are an anchor to the
Commonwealth’s economy. The nuclear energy industry
supports nearly 16,000 Pennsylvania jobs: over 3,000 fulltime jobs directly at the plants, and thousands of others
for maintenance during scheduled outages, jobs
brought to the areas for manufacturing, and others attributable to resulting economic activity.8 Between 2014
and 2016, Pennsylvania's five nuclear plants provided the
building trades with nearly seven million man-hours of
outage and maintenance work.9
Pennsylvania is a net exporter of power to the regional
electric grid operated by PJM. This advantageous position, which drives economic activity in the state, is made
possible by Pennsylvania’s rich energy resources including its nuclear fleet.
A study by The Brattle Group of the impacts of Pennsylvania’s nuclear power on the state’s economy concluded
that it adds two billion dollars annually to state Gross
Domestic Product (“GDP”).10 Further, without nuclear
power, electricity costs to Pennsylvanians would increase
by $788 million per year. These and other impacts estimated by The Brattle Group are shown in Figure 2 (see
next page) and from FirstEnergy Solutions testimony at a
Nuclear Energy Caucus hearing on April 17, 2018.
The Appendix to Chapter 3 contains profiles of each of
Pennsylvania’s nuclear plants:
•

Beaver Valley Power
Station, a plant with 1,815
megawatts (MW) located in
Beaver County. Unit 1 is
licensed to operate until
2036 and Unit 2 is licensed

percentage of state’s electricity use is 83 TWh Pennsylvania nuclear generation (EIA Electric Power Monthly, Feb. 2017) divided by 145 TWh retail sales (PA PUC Electric Power Outlook for Pennsylvania, Aug. 2017: http://www.puc.state.pa.us/General/publications_reports/pdf/EPO_2017.pdf ).
7Source: EIA Electric Power Monthly, CY2017 data (February 2018)
8The Brattle Group. “Pennsylvania Nuclear Power Plants’ Contribution to the State Economy.” Prepared by Mark Berkman, Ph.D., and Dean Murphy, Ph.D.
for Pennsylvania Building and Construction Trades Council, The Pennsylvania Chamber of Business and Industry, Allegheny Conference on Community
Development, and Greater Philadelphia Chamber of Commerce. December 2016.
9Martin Williams, Business Manager – Boilermakers Local 13, Philadelphia, Testimony for the Pennsylvania Senate Nuclear Caucus Hearing, May 23, 2018,
from data provided by Exelon, FirstEnergy, and Talen Energy.
10Ibid.

8   Pennsylvania’s Nuclear Energy Industry

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

until 2047. On March 28, 2018, Beaver Valley owner
FirstEnergy Solutions announced that, without
state or federal relief, the Beaver Valley reactors
will be shut down in 2021.
•

Limerick Generating
Station, a plant with 2,317
MW located in Montgomery
County. Unit 1 is licensed to
operate through 2044 and
Unit 2 through 2049.

•

Peach Bottom Atomic
Power Station, a plant with
2,700 MW located in York
County. Unit 2 is licensed
to operate until 2033 and
Unit 3 until 2034. Exelon
Generation co-owns Peach Bottom 50/50 with Public
Service Enterprise Group (PSEG). In July 2018 Exelon
filed applications with the Nuclear Regulatory
Commission for license extensions to allow the
Peach Bottom units to operate until 2053 and 2054.

•

•

Susquehanna Nuclear
Plant, a plant with 2,600 MW
located in Luzerne County.
Unit 1 is licensed until
2042; Unit 2 is licensed until
2044. Susquehanna Nuclear
LLC (rolls up to Talen Energy/Riverstone Holdings)
owns 90% of the plant; Allegheny Electric
Cooperative Inc. owns 10%.
Three Mile Island
Generating Station, a plant
with 837 MW located in
Londonderry Township,
Dauphin County. Unit 1 is
licensed to operate until
2034. On May 30, 2017, owner Exelon Generation
announced that, without policy reforms, Three Mile
Island would be closed in September 2019.11

It is not just Three Mile Island and Beaver Valley nuclear
generating stations that are at risk of closure.

Figure 2: Impact of Pennsylvania’s Nuclear Plants on
the State’s Economy

Source: Don Moul, President and CNO, First Energy. Testimony to Nuclear Energy Caucus (4/17/18)

It is not just Three Mile Island
and Beaver Valley nuclear generating
stations that are at risk of closure.
In the 2017 State of the Market Report for PJM, the Independent Market Monitor (“IMM”) estimates that Susquehanna and Peach Bottom did not cover their capital costs
in 2016. By 2020, the IMM projects that Susquehanna
would not cover industry average capital costs.12
Commenting on these findings at the NEC hearing on
April 17, 2018, Debra L. Raggio, Senior Vice President,
Regulatory & External Affairs Counsel, Talen Energy, said:
“[E]ven though we have not announced
shutdown, in the PJM Independent Market
Monitor <State of the Market> report . . . shows
a financial shortfall for Susquehanna in 2020,
looking at whether the plant will cover its
avoidable costs including a recovery of capital
costs. The IMM’s analysis relies on publicly
available pricing data and costs, based upon
benchmark information from the Nuclear Energy
Institute. In addition, we found that even under
generally acceptable accounting principles,
GAAP accounting, we would be forecasting a
net loss for future years.”

11Three

Mile Island Unit 2 is owned by First Energy. The unit is in post-defueling monitored storage. Exelon has an agreement with First Energy to provide oversight of the plant
12http://www.monitoringanalytics.com/reports/PJM_State_of_the_Market/2017/2017-som-pjm-sec7.pdf

Pennsylvania’s Nuclear Energy Industry   9

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Stranded Costs: The Nuclear Energy Caucus considered
whether stranded cost recovery, which occurred for
some nuclear generating assets, should be a factor in
evaluating the economics of the plants today.
Although the stranded cost recovery is something that
happened more than twenty years ago, we wanted to investigate whether these past payments guaranteed continued operation of the nuclear plants or constituted an
argument against intervention now.13

from customers any stranded cost payments.15
Furthermore, Pennsylvanians have benefitted from
competition and retail choice.
Many of Pennsylvania’s residential customers benefitted
from long-term price caps that protected them from
retail price spikes for over a decade. Not only were prices
for generation capped, but so were rates for still-regulated transmission and distribution service provided by
the restructured local electric utilities.

Here is what the NEC learned about stranded cost
recovery.
Prior to Pennsylvania’s 1996 legislation to restructure the
state’s electric industry, the vertically integrated utilities14
were granted recovery of capital costs and a rate of
return on their generating plant investments. This cost
recovery was part of the electricity rates approved by
regulators.
The 1996 legislation introduced direct competition and
retail choice for electricity suppliers. In the transition,
some utilities became eligible for stranded cost payments: the difference between the market value of their
generating assets and the value of the plants the utilities
still carried on their books for the remaining years of previously approved cost recovery of the investments.
The PUC approved comprehensive settlements for each
of the utilities as part of the competitive market policy
implementation. Those settlements provided stranded
cost recovery for some nuclear assets to some of the utilities in exchange for retail rate reductions and multi-year
price caps.
The stranded costs are what economists call “sunk” costs.
As such, they are irrelevant to recognizing the future
value of the benefits that the nuclear plants will provide.
Moreover, although some utilities received stranded cost
payments for their nuclear plants, not all did, because
some plants, such as Three Mile Island nuclear generating station and some other generating assets, were sold
by the previous owner at prices that were greater than
the unrecovered costs. Three Mile Island did not recover

13A

In all cases consumer benefits far
exceeded stranded cost payments, so
customers were provided greater value.
In addition, restructuring created
economic incentives to improve
generating plant efficiency, which has
also benefitted consumers.
In all cases consumer benefits far exceeded stranded
cost payments, so customers were provided greater
value. In addition, restructuring created economic
incentives to improve generating plant efficiency, which
has also benefitted consumers.
In conclusion, Pennsylvania’s nuclear plants are the
Commonwealth’s largest source of electricity. They
moderate electricity prices, benefitting Pennsylvania customers an estimated $788 million per year in lower bills.
Lose the state’s nuclear plants, and Pennsylvania would
have 16,000 fewer good jobs. Air quality would be
worse. State GDP would be two billion dollars lower.
CO2 emissions would increase very substantially - by
more than 37 million metric tons.
No one disputes the importance of Pennsylvania’s nuclear plants in providing reliable, emission-free electricity
to millions of households and businesses. However, the
plants are at financial risk of early closure. If announced
closures proceed, Pennsylvania will lose one fourth of its
nuclear power by 2021.

Policy Choice for Pennsylvania, John Hanger and Philip O’Connor, submitted to Nuclear Energy Caucus, September 5, 2018.
vertically integrated utility is one that owns all levels of the supply chain: generation, transmission and distribution. Historically, all utilities were vertically integrated and had a regulated monopoly on the production and sale of power.
15Ibid.
14A

10   Pennsylvania’s Nuclear Energy Industry

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Documents in Chapter 3 Appendix:
1. The Brattle Group. “Pennsylvania Nuclear Power
Plants’ Contribution to the State Economy.” Report
prepared by Mark Berkman, Ph.D., and Dean Murphy,
Ph.D. for Pennsylvania Building and Construction
Trades Council, The Pennsylvania Chamber of
Business and Industry, Allegheny Conference on
Community Development, and Greater Philadelphia
Chamber of Commerce. December 2016.
2. Fact Sheets for each of Pennsylvania’s five nuclear
power plants: Beaver Valley, Limerick, Peach Bottom,
Susquehanna, and Three Mile Island
3. Martin Williams, Business Manager – Boilermakers
Local 13, Philadelphia, Testimony for the Pennsylvania Senate Nuclear Caucus Hearing, May 23, 2018
4. John Hanger and Philip O’Connor stranded costs
paper (2018)

Pennsylvania’s Nuclear Energy Industry   11

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

4. Epidemic of Premature Plant Shutdowns
Summary:
•

Early closures of two Pennsylvania nuclear plants,
Three Mile Island and Beaver Valley, have been
announced for 2019 and 2021 respectively.

•

Up to half the nuclear energy fleet nationally is at risk
of early closure.16

•

Market pressures on nuclear power come from low
natural gas prices, sluggish growth in electricity
demand, subsidized renewable resources, and lack
of a national carbon policy.

•

Energy markets fail to value an always-there
megawatt hour of energy from nuclear any
differently from an on-again off-again megawatt
hour like wind or solar, and do not compensate for
carbon-free electricity production.

Nationally, five nuclear power plants closed between
2013 and 2016. The loss of energy from these plants is
the equivalent of all the solar power in the country combined.18 16,000 MW (about 16% of the nation’s nuclear
capacity) have either closed already or announced early
shutdown. Another 12,000 MW are at risk, as shown in
Table 1.
Table 1: Nuclear Plants at Risk of Early Closure

•

If low-carbon energy is a goal, nuclear energy is
cheaper than the alternatives.

Source: ScottMadden, While You Were Sleeping: The Unnoticed Loss of Carbon-free Generation in the
United States (April 2018)

Premature nuclear plant shutdowns are not unique to
Pennsylvania; they have occurred in or are announced in
ten other states. The locations of nuclear plants at risk
are shown in Figure 3.

Deeper Dive:
In hearings conducted by the Nuclear Energy Figure 3: Nuclear Plants Closing in Restructured States
Caucus, industry, labor, and environmental
groups expressed alarm about the epidemic of
premature nuclear plant shutdowns.
These shutdowns are eliminating what may be
the cheapest, or in some cases the only, options to assure an abundant, low-carbon and
secure energy future before policy makers
have a chance to map out pathways to achieve
these goals.
“It should be a source of profound
concern for all who care about climate
change that, for entirely predictable and
resolvable reasons, the United States
appears set to virtually lose nuclear
power, and thus a wedge of reliable and
low-carbon energy, over the next
few decades.” 17

16Bloomberg

Source: Don Moul, President and CNO, First Energy. Testimony to Nuclear Energy Caucus (4/17/18)

New Energy Finance. Half of U.S. Nuclear Power Plants are Underwater. (6/13/2017)
Granger Morgan et al. “US nuclear power: The vanishing low-carbon wedge” (July 2, 2018)
18David Roberts, Vox, The Simple Argument for Keeping Nuclear Power Plants Open (April 5, 2018)
17M.

12   Epidemic of Premature Plant Shutdowns

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Some states have acted and averted plant retirements,
while other states did not prevent premature plant
closures. When nuclear plants retire, some dislocated
workers move out of state to nuclear plants whose
future is more secure.

•

Economic risks of operating nuclear plants are nothing
new, but technological developments, structural
changes and other pressures have made the last few
years especially challenging.19

For many years, a price on carbon was being
seriously considered by lawmakers and regulators,
but markets remain generally unable to recognize
the low carbon value of nuclear generation.

•

Distressed Assets: Certain nuclear units have
especially challenging economics due to cost
structure, most especially the smaller stand-alone
plants, such as Three Mile Island. When they bid in
enough to cover the gap in their costs and energy
revenues in the capacity markets, they do not clear
PJM’s21 Base Residual Auction.

•

Favored Technologies Exclude Nuclear: Some state
laws pick technology winners, and usually these laws
favor several zero carbon resources but not nuclear.
This is true of Pennsylvania’s Alternative Energy Portfolio Standards Act (“AEPS”). In addition, out of
market subsidies to non-nuclear technologies have
had an impact on energy prices around many
nuclear units. The Federal Production Tax Credit has
incentivized the build-out of wind in the Midwest
that would not have been supported by energy and
capacity markets alone. The Federal Production Tax
Credit pays per MWh of wind generated, regardless
of energy price at the time. Thus, wind can run at
negative prices and still make money. Some nuclear
units experienced negative prices during off-peak
hours, in part from this effect.

Low natural gas prices provide
short-term gains, which are appreciated,
but these prices fail to factor in the
larger picture of fuel diversity and
long-term carbon emission
reductions.
•

•

On the revenue side, wholesale power prices came
down sharply from the high levels of 2006-2008 and
have never recovered to their prior levels. An influx
of low-cost natural gas from shale production has
brought prices lower. Low natural gas prices
provide short-term gains, which are appreciated,
but these prices fail to factor in the larger picture of
fuel diversity and long-term carbon emission
reductions.20 In addition, electricity demand has
stagnated, mostly due to changes in the structure of
the economy such as the failure of industrial demand
to fully recover from the deep recession in 20082009. Additionally, transmission constraints cause
congestion and low prices around some nuclear
units. For example, wind generation is built in areas
of low demand and stays bottled there because of
insufficient transmission to move it where power is
needed. Throughout this period, wholesale prices
have remained low.
On the cost side, growth in costs has out-paced
growth in power prices, leading to thin or non-

existent cash margins. These costs keep up with
commitments to safety, training and hardening for
potential extreme events.

Indicative of the severity of the crisis for PJM’s nuclear
generation, in May 2018 more than one third of PJM’s
nuclear power capacity failed to clear the capacity
auction for 2021-2022, including the Beaver Valley and
Three Mile Island nuclear plants. In just a year, the
nuclear capacity that failed to clear the PJM capacity
auction increased by more than 200 percent.22

19Jesse

D. Jenkins. What’s Killing Nuclear Power in U.S. Electricity Markets? MIT Center for Energy and Environmental Policy Research. (January 2018)
Nuclear Closures Undo Years’ Worth of Climate Progress (April 10, 2018)
21PJM, founded in 1927, is charged with ensuring the reliability of the high-voltage electric power system serving 65 million people in all or parts of
Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia. PJM coordinates and directs the operation of the region’s transmission grid, which includes 84,042 miles of transmission lines; administers a competitive wholesale electricity market (including the capacity market); and plans regional transmission expansion improvements to
maintain grid reliability and relieve congestion.
22PJM Power Auction Foretells Potentially Disastrous Environmental Impact (May 2018)
20Third Way,

Epidemic of Premature Plant Shutdowns   13

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Actions that other states are taking to achieve their own
energy and economic goals may sometimes impinge on
Pennsylvania nuclear assets.

It is less expensive to operate the average existing
nuclear plant than it is to build new wind or solar
generation.

Several nearby states are accelerating clean energy production, and that can further stress baseload energy assets in the region. A similar situation is occurring in
Arizona, where baseload generation is under stress in
part due to renewable energy policies in California,
which during some times of day send electricity prices
below zero in neighboring Arizona. Arizona will consider
a ballot measure to increase its renewables requirement
from 15% by 2025 to 50% by 2030. As an alternative,
Commissioner Andy Tobin of the Arizona Corporation
Commission (“ACC”) has proposed an 80% by 2050 clean
energy standard which includes nuclear in the mix.
When nuclear plants retire, it undoes the clean energy
progress made by years of renewable investments.

Documents in Chapter 4 Appendix:

This is seen on a national level in Figure 4. The loss of
nuclear carbon-free generation reverses most of the
gains from wind and solar.23
Figure 4: Change in U.S. Carbon-Free Generation

1. Nicholas Steckler. Half of U.S. Nuclear Power Plants are
Underwater. Bloomberg New Energy Finance
(6/13/2017)
2. M. Granger Morgan et al. “US nuclear power: The
vanishing low-carbon wedge” Carnegie Mellon
University's Department of Engineering and Public
Policy. In Proceedings of the National Academy of
Sciences of the United States (PNAS) July 2, 2018
www.pnas.org/cgi/doi/10.1073/pnas.1804655115
http://www.pnas.org/content/early/2018/06/26/
1804655115
3. David Roberts, Vox, The Simple Argument for Keeping
Nuclear Power Plants Open (April 5, 2018)
4. Scott Madden, While You Were Sleeping: The
Unnoticed Loss of Carbon-free Generation in the
United States (April 2018)
5. Jesse D. Jenkins. What’s Killing Nuclear Power in U.S.
Electricity Markets? MIT Center for Energy and
Environmental Policy Research. (January 2018)
6. Third Way, Nuclear Closures Undo Years’ Worth of
Climate Progress (April 10, 2018)
7. PJM Power Auction Foretells Potentially Disastrous
Environmental Impact (May 2018)

ScottMadden While You Were Sleeping: The Unnoticed Loss of Carbon-free Generation in the United States
(April 2018)

8. Amber Robson. Preserving America’s Clean Energy
Foundation. Third Way (12/8/16)

Nuclear power is cost-effective in comparison with other
ways of achieving a low carbon energy mix.
“In most cases, electricity produced by existing
nuclear reactors is cheaper than alternative
sources of clean energy, such as new wind or
solar power. Today’s power markets do not fully
value the climate and grid benefits of America’s
nuclear fleet – something that state and federal
policymakers should resolve, as they have for
other important sources of clean energy like wind
and solar.”
Amber Robson, Third Way (12/08/16)
23Third Way,

Nuclear Closures Undo Years’ Worth of Climate Progress (April 10, 2018)

14   Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

5. Premature Plant Shutdowns: Jobs, Economy and
Consumer Impacts
Summary:
•

Announced closures of the Beaver Valley and Three
Mile Island nuclear plants will eliminate thousands of
steady good-paying jobs.

•

Nuclear plants are typically the largest employer in
their communities. Plant closures drain the
community of tax base and resources and harm local
schools, services, and businesses.

•

Pennsylvania electricity customers will pay $285
million more annually on their power bills if Beaver
Valley, Three Mile Island, and two Ohio nuclear plants
close as announced.

Deeper Dive:
Nuclear power plants contribute nearly $2 billion to
Pennsylvania’s gross domestic product and account for
approximately 16,000 direct and indirect full-time jobs.
Nuclear plants keep Pennsylvania electricity prices lower
by approximately $788 million per year and are responsible for more than $400 million in annual state and federal tax collections.24 These estimates are from modeling
conducted by The Brattle Group using REMI, a widelyused dynamic input-output model of the U.S. economy.25

Nuclear power plants contribute
nearly $2 billion to Pennsylvania’s
gross domestic product and account
for approximately 16,000 direct and
indirect full-time jobs.
Negative economic impacts resulting from the early
retirement of the Three Mile Island and Beaver Valley
nuclear generating stations would be considerable.
The Brattle Group modeled these impacts, coupled with
impacts from the early closures of the Davis-Besse and
Perry nuclear plants announced by FirstEnergy at the
same time as Beaver Valley.

“The four plants considered here employ over
3,000 people directly, as well as other nonemployee contractors. Most of these jobs would
be lost with the plants’ retirement and, based on
our previous work, thousands of additional
secondary jobs would be lost. In addition, state
GDP for Ohio and Pennsylvania would be lower
by hundreds of millions of dollars, and state and
local tax revenues would fall by tens of millions
of dollars.”26
If the Three Mile Island, Beaver Valley, Davis-Besse and
Perry nuclear generating stations shut down early,
Pennsylvanians can expect to pay $285 million per year
more for electricity. Across PJM, electricity costs would
increase by $1.5 billion per year.27
Low and stable electricity prices are critical to
Pennsylvania’s industrial and commercial-based
economic base. First, energy-intensive businesses are
more likely to come to Pennsylvania and to stay.
Second, continuing to be a net exporter of electricity –
an economic strategy of the Commonwealth – depends
on the state’s nuclear fleet and is an important source of
state income and jobs.

24The

Brattle Group. Pennsylvania Nuclear Power Plants’ Contribution to the State Economy (2016)
p. 4
26The Brattle Group, Impacts of Announced Nuclear Retirements in Ohio and Pennsylvania (April 2018), pp. 8-9
27Ibid. p. 5
25Ibid.,

Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts   15

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Electricity Price Impacts: The Brattle Group estimates
the impact to Pennsylvania consumers of losing its
nuclear fleet would be higher electricity costs of $788
million per year, and the impact to consumers in all of
PJM would be higher electricity costs of $3.4 billion per
year.28 The Nuclear Energy Caucus sought further detail
as to why, if nuclear plants close, electricity prices
will increase.
During the April 17, 2018 NEC hearing, Dr. Dean Murphy
of The Brattle Group presented the slide shown in Figure
5 and explained how it was possible that if nuclear units
are taken out of the market, electricity prices will go up.
“When nuclear plants retire, power prices rise.
That seems to be a bit of a conundrum: how
could prices rise, when an expensive asset retires.
It’s because that expensive asset was not recovering
its costs from the market. But, by the law of supply
and demand, if demand stays the same and supply
decreases, prices rise. . . Other generators are
receiving higher prices for the same output they
would have produced otherwise, plus the additional
output that they are producing to replace the
nuclear plants.” Dr. Dean Murphy, Principal, The
Brattle Group, testimony to the Nuclear Energy
Caucus, April 17, 2018
Figure 5: Electricity Cost Impacts of Four Announced
Nuclear Retirements

A recent Penn State University (PSU)
study similarly concludes that if Beaver
Valley and Three Mile Island retire,
energy prices would increase in PJM.
A recent Penn State University (PSU) study similarly concludes that if Beaver Valley and Three Mile Island retire,
energy prices would increase in PJM.29 New gas plants
would come in at higher cost, and the nuclear power is
replaced with higher priced energy. The study observes:
•

“In all retirement scenarios, however, the energy
output from Beaver Valley and Three Mile Island is
effectively replaced with higher-cost energy.” 30

•

“…any nuclear retirement will tend to increase
clearing prices in the PJM real-time market because
new natural gas plants as modeled will have slightly
higher marginal operating costs than existing
nuclear plants.”

•

“In a scenario where Beaver Valley and Three Mile
Island retire and are not replaced by any new
capacity, total energy market costs would rise by
around $750 million over a three year period. In a
scenario where Beaver Valley and Three Mile Island
are more than replaced by new gas capacity, total
energy market costs would rise by around $600
million over a three year period.”

While the Brattle Group and the PSU numbers do not
match exactly, they are directionally the same. In both
studies, energy costs go up when the nuclear plants
retire.
Other generators are aware of these price effects and
would collect more money for the same power if nuclear
plants retire. For example, in New York, retirements of
some nuclear plants were staved off by regulatory implementation of a Clean Energy Standard that includes Zero
Emissions Credit (ZEC) provisions. A filing by a coalition
of fossil generation companies complains:
28The

Brattle Group. Pennsylvania Nuclear Power Plants’ Contribution to the State Economy (2016)
Blumsack. “Impacts of the Retirement of the Beaver Valley and Three Mile Island Nuclear Power Plants on Capacity and Energy Prices in
Pennsylvania.” Pennsylvania State University. Electricity J. (August 2018)
30The Blumsack study posits three scenarios, but only one is somewhat plausible. The other two scenarios involve implausible market responses
(attributing new natural gas builds 1 for 1 or even 3 for 1 to retired nuclear capacity). In the first scenario overall electricity costs to Pennsylvania
ratepayers would increase by $400 million over a three-year period.
29Seth

16   Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

“[T]he PSC is using the ZEC subsidy to exert a large
depressive effect on energy and capacity prices,
which one group of experts estimated at $15 billion
over 12 years.”31
Similarly, in Illinois the Electric Power Supply Association
wrote in their filing that the ZEC’s impact on market
prices in the wholesale market will:

“harm other generators, including the Plaintiffs,
because the lower auction prices will result in lower
revenues.” 32
This is, of course, one of the reasons behind well-funded
campaigns to oppose equal treatment of nuclear with
other zero-carbon resources.

Source: Clean Jobs for Pennsylvania
31Coalition
32Electric

for Competitive Electricity et al. v. Zibelman, et al. U.S. District Court Southern District of New York, 10/19/16
Power Supply Association, et al. v. Anthony M. Star et al., Case cv-01164, Filed 2/14/17

Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts   17

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Employment Impacts: Pennsylvania’s nuclear fleet
directly employs approximately 4,200 people.33 The fleet
also supports skilled labor who service plants during
refueling and maintenance.34 Numerous manufacturing
and small businesses are supported by the economic
activity from the nuclear plants. The Brattle Group
model estimates that without its nuclear fleet, the
Pennsylvania economy would shrink by 15,900 jobs.35

…without its nuclear fleet, the
Pennsylvania economy would shrink
by 15,900 jobs.

“Closure of just one facility will eliminate thousands
of job opportunities for building trades workers and
prove distinctly harmful to Boilermakers since power
generation is one of the main industries we service.”
Martin Williams, Boilermakers Local 13, Nuclear
Energy Caucus hearing May 23, 2018
"Beaver Valley Power Station provides familysustaining jobs for hundreds of workers. It supports
the local economy, and supplies affordable, reliable,
and resilient energy to regional households,
hospitals, schools, and businesses. Meanwhile,
other parts of our
nation face energy
shortages because
too many other
fuel-secure plants
closed prematurely.
In New England,
grid operators rely

on imported energy to meet demand. Pennsylvania
should not follow their example. Nationally, our lack
of a comprehensive energy policy undermines our
security and energy independence. The Beaver Valley
Power Station provides resilient power necessary for
the electric grid, and it is vital it and others stay
open.” Congressman Keith Rothfus (PA-12), press
release, April 6, 2018
“Pennsylvania’s
nuclear industry
supports 16,000
good-paying jobs
alone. In addition,
nuclear facilities
spend $1.8 billion
in our local
economies, benefiting 4,150 Pennsylvania
companies, and contribute $2 billion annually to
the commonwealth’s economy. Without nuclear,
all of that will disappear.” Anna Dale, Londonderry
Township supervisor, letter to the editor, Press &
Journal, November 29, 2017
Local Impacts of Plant Closure in Other States: Nuclear retirements in states that failed to act have had dire,
but predictable consequences on local communities.
Vermont Yankee is one such case:
“When Vermont Yankee closed, the jobs and the
tax revenue disappeared and have not returned.
Employees were forced to retire or move to find
similar jobs in other states. Housing prices dropped.
Also, in response to the closure, property taxes were
raised by 20% to help replace lost tax revenue.”
Joe Gusler, Central PA Building & Construction
Trades Council, Nuclear Energy Caucus hearing
May 23, 2018
Our counterparts in Ohio have heard similar testimony:
“When Vermont Yankee closed, the cornerstone of
our local community disappeared, causing families
and friends to move away, and in turn, our
businesses shuttered and many community
members were left searching for jobs.

33Sources: Company fact sheets for Limerick (890) and Peach Bottom (860). Martin Williams statement at NEC hearing for Three Mile Island and Beaver
Valley (1,400 together). Steve Knoebel at NEC hearing for Susquehanna (1,000).
34Kristopher Anderson, IBEW, testimony to Nuclear Energy Caucus 5/23/18
35The Brattle Group. Pennsylvania Nuclear Power Plants’ Contribution to the State Economy (2016)

18   Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

About 300 million dollars a year no longer circulates
in Vermont’s economy due to the plant shutdown.
Sadly, our small businesses are feeling that crunch
the most, with reports as high as 20% in lost
revenues. In addition, $58 million in payroll per year
is no longer paid to the over 500 people Vermont
Yankee once employed.
This money no longer supports the town of Vernon,
the community’s small businesses, and the many
non-profits around the region that relied on
Vermont Yankee. Programs that serve our youngest
population have been greatly reduced or eliminated,
and services for our elderly population are at risk.
The engine that drove our community died, and our
town and region have slowed to a halt because of it.
At our last Town Meeting, residents regretfully
voted NOT to fund any of the social services that
traditionally aided our most at-risk population.
Financial pressures in the face of rising taxes have
forced residents to make difficult choices in order
to make ends meet. Our only local retail store has
closed, housing values have plummeted, and taxes
are expected to continue to increase. Residents have
been forced to fill the financial gap in order to
maintain minimum town services. Increases in
property taxes and declining home values have
placed a significant burden on those members of
our community that can least afford it.
The impact has been more than financial. When
Vermont Yankee closed, families moved or were
torn apart when houses couldn’t sell and some
parents were forced to find work at other plants –
only able to come home on the weekends, if they
are lucky. Our friends were scattered to other states
when the cornerstone of our economy disappeared.
The culture and identity of our town will be forever
changed.”36 Josh Unruh, Vermont Selectboard
Chairman, testimony for Ohio House Bill 178,
April 25, 2017.
As discussed previously, there is an epidemic of nuclear
plant closures in the nation.
The Nuclear Energy Caucus learned of several occasions
where states did not act sufficiently and lost or are losing
36STestimony

their plants, such as the above case of Vermont Yankee,
the Kewaunee plant in Wisconsin, and, to date, the
Davis-Besse and Perry plants in Ohio.
Meanwhile, where states have acted, closures have
been forestalled, such as in New York, New Jersey, Illinois,
and Connecticut.

“I bet the members of the Pennsylvania
House and Senate would jump at the
opportunity to help if I said we were
creating 16,000 new jobs in Pennsylvania.
What we are asking for is your help in
saving 16,000 good paying jobs in
Pennsylvania.” Joe Gusler, Central PA
Building & Construction Trades Council,
testimony to Nuclear Energy Caucus,
May 23, 2018
As a closing thought on the economic impacts, we
share this testimony from the Nuclear Energy Caucus
May 23 hearing:
“I bet the members of the Pennsylvania House
and Senate would jump at the opportunity to help
if I said we were creating 16,000 new jobs in
Pennsylvania. What we are asking for is your
help in saving 16,000 good paying jobs in
Pennsylvania.” Joe Gusler, Central PA Building
& Construction Trades Council, testimony to
Nuclear Energy Caucus, May 23, 2018
In fact, as was recently publicly disclosed, Democrat
Governor Wolf offered up to $4.6 billion in state-backed
financial incentives to Amazon to entice it to locate its
next headquarters in Pittsburgh or Philadelphia37 (which
did not include additional incentives from Philadelphia
or Pittsburgh).
Likewise, former Republican Governor Corbett advocated for and successfully implemented a $1.65 billion
Resource Manufacturing Tax Credit for companies that
build a cracker plant in the Commonwealth. The tax
credit would give Royal Dutch Shell – or any other company that builds a petrochemical plant in Pennsylvania –

of Josh Unruh, Vermont Selectboard Chairman, Ohio House Bill 178, 4/25/17

37https://triblive.com/local/allegheny/14289172-74/gov-tom-wolf-says-pennsylvania-offered-46b-in-incentives-for-amazon.

Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts   19

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

a $2.10 break on every barrel of ethane it purchases from
energy companies located in the Commonwealth.38

“What these incentives do, is they don’t
just bring a company to Pennsylvania.
They bring an entire industry to
Pennsylvania,” Labor and Industry
Secretary Julia Hearthway said. “They
bring an entire industry to northeastern
United States. And with it comes jobs.
Not a few hundred jobs. Not one company
hiring 300 or 400 jobs. But thousands
and thousands of jobs to Pennsylvania.”
“What these incentives do, is they don’t just bring a
company to Pennsylvania. They bring an entire industry
to Pennsylvania,” Labor and Industry Secretary Julia
Hearthway said. “They bring an entire industry to northeastern United States. And with it comes jobs. Not a few
hundred jobs. Not one company hiring 300 or 400 jobs.
But thousands and thousands of jobs to Pennsylvania.” 39

5. Kristopher Anderson, IBEW, testimony to Nuclear
Energy Caucus 5/23/18
6. Coalition for Competitive Electricity et al. v.
Zibelman, et al. U.S. District Court Southern District
of New York, 10/19/16
7. Electric Power Supply Association, et al. v. Anthony
M. Star et al., Case cv-01164, Filed 2/14/17
8. Martin Williams, Boilermakers Local 13, testimony to
Nuclear Energy Caucus 5/23/18
9. Congressman Keith Rothfus (PA-12), press release,
5/6/18
10. Anna Dale, Londonderry Township supervisor, Press
& Journal letter to the editor, 11/29/17
11. Josh Unruh, Vermont Selectboard Chairman,
testimony on Ohio House Bill 178, 4/25/17
12. Joe Gusler, Central Pennsylvania Building Trades,
testimony to Nuclear Energy Caucus 5/23/18

Pennsylvania’s nuclear industry certainly deserves no
less consideration than Amazon or the oil and natural
gas industry.

Documents in Chapter 5 Appendix:
1. The Brattle Group. Pennsylvania Nuclear Power
Plants’ Contribution to the State Economy. Dec.
2016. (see Chapter 3 Appendix)
2. The Brattle Group, Impacts of Announced Nuclear
Retirements in Ohio and Pennsylvania (April 2018)
3. Dr. Dean Murphy, slides presented to the Nuclear
Energy Caucus, 4/17/18
4. Seth Blumsack. “Impacts of the Retirement of the
Beaver Valley and Three Mile Island Nuclear Power
Plants on Capacity and Energy Prices in Pennsylvania.” Pennsylvania State University. Electricity J.
(August 2018) (protected by Electricity J. copyright)

38https://triblive.com/business/headlines/10595729-74/tax-shell-pennsylvania.
39https://stateimpact.npr.org/pennsylvania/2012/06/14/corbett-administration-sells-ethane-cracker-tax-break-secretary-says-shell-asked-for-it/

20   Premature Plant Shutdowns: Jobs, Economy and Consumer Impacts

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

6. Premature Plant Shutdowns: Environment and
Public Health Impacts
Summary:
•

The shutdown of nuclear plants across the country
are a greenhouse gas emergency.40

•

Losing the Beaver Valley and Three Mile Island
nuclear plants will negate five times the emissions
benefits of all the solar and wind power installed in
Pennsylvania to date.41

•

Nuclear power plants prevent significant quantities
of harmful criteria air pollutants, including seasonal
NOx, annual NOx, SO2, and PM2.5. These pollutants
rise when nuclear plants shut down.

Deeper Dive:
Pennsylvania has made some headway in reducing its
carbon dioxide (CO2) emissions.
During the period from 2010 to 2015, Pennsylvania
reduced energy sector CO2 emissions nine percent, from
256 million metric tons (mmt) to 233 mmt per year,
partly due to the shift from coal to gas.
Despite its progress, Pennsylvania still ranks third in the
country in CO2 emissions (but fourth in generation).42

Numerous experts testified to the
Nuclear Energy Caucus that existing
nuclear plants are a critical component
of limiting greenhouse gas emissions,
and nuclear plant closures are
devastating to greenhouse gas goals.
Nuclear closures cause back-sliding on greenhouse gas
reductions.

Numerous experts testified to the Nuclear Energy Caucus
that existing nuclear plants are a critical component of
limiting greenhouse gas emissions, and nuclear plant
closures are devastating to greenhouse gas goals.43
Closures more than negate the emission benefits from
switching from coal to natural gas, thereby erasing the
emissions benefits of state investments in wind
and solar.
“We believe that the loss of today’s nuclear fleet
would be a terrible blow to the progress already
made in reducing Pennsylvania’s contribution to
climate change and would hamstring all of our
combined efforts.” Davitt Woodwell, President,
Pennsylvania Environmental Council, at Nuclear
Energy Caucus June 19, 2018

If it were not for its nuclear power
plants, Pennsylvania’s CO2 emissions
would be an estimated 37 mmt higher
each year.
If it were not for its nuclear power plants, Pennsylvania’s
CO2 emissions would be an estimated 37 mmt higher
each year.44 The premature closure of any of the nuclear
plants further perpetuates the loss of the reductions the
state has achieved already (see Figure 6).
“These four plants…account for one and a half
times the total amount of zero emitting generation
from all the wind and all the solar across the entire
PJM footprint. [Prematurely closing them] would set
back more than 25 years of progress.” - Dr. Dean
Murphy, The Brattle Group, NEC hearing
April 17, 2018

40Testimony to the Nuclear Energy Caucus by the Pennsylvania Environmental Council, the Environmental Defense Fund, and the Union of Concerned
Scientists, June 19, 2018.
41Testimony to Nuclear Energy Caucus of Kathleen Barrón, April 17, 2018. Data publicly sourced from EIA-923, EIA Electric Power Monthly (Feb 2018),
and Monitoring Analytics 2017 PJM State of the Market report. See also testimony of Dr. Dean Murphy, The Brattle Group, April 17, 2018 “If you look at
the two Pennsylvania plants Three Mile Island and Beaver Valley, they account for 22 million megawatt hours of carbon free electricity. All the renewables in PA, all the wind and all the solar account for about 4 million.”
42EIA State Carbon Dioxide Emissions Data for 2015 (10/24/2017), https://www.eia.gov/environment/emissions/state/. Texas and California carbon
dioxide emissions rank first and second, respectively.
43Testimony to the Nuclear Energy Caucus by the Pennsylvania Environmental Council, the Environmental Defense Fund, and the Union of Concerned
Scientists, June 19, 2018
44The Brattle Group. “Pennsylvania Nuclear Power Plants’ Contribution to the State Economy.” December 2016

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The nuclear plant closures announced already in Pennsylvania and Ohio (Beaver Valley, Three Mile Island, DavisBesse and Perry) will increase CO2 emissions about 21
mmt per year and is equivalent to a 50% increase in the
number of Pennsylvania passenger vehicles driven for
a year.
Some parties recommend replacing lost output with additional renewable energy, but replacing the lost output
from nuclear retirements with renewables would take
years at current development rates.
If the Three Mile Island, Beaver Valley, Davis-Besse and
Perry plants retire as announced, the growth of renewables would have to double their current growth rate, an
unlikely scenario, and it would still take PJM until 2034 to
get back to the same levels of non-emitting generation it
has today. Meantime, emissions will have been up to 21
mmt higher annually in the intervening years.45,46
Figure 6: Announced OH and PA Nuclear Retirements Produce More Zero-Carbon Electricity than all the Wind and
Solar in all of PJM

Loss of the plants would increase air pollution and may
trigger ozone alert days, asthma attacks, lung disease,
hospital visits, and lost days of work from poor air
quality. High-pollution days disproportionately impact
urban and suburban residents.
A study of all the Commonwealth’s nuclear plants
concluded that without them:48
•

SO2 emissions would increase by 8,500 tons
annually. SO2 is regulated by the EPA Cross-State
Air Pollution Rule (“CSAPR”) and by Ozone National
Ambient Air Quality Standards (“NAAQS”).

•

NOx emissions would increase by 11,500 tons
annually. NOx is regulated by the EPA Ozone
NAAQS.

•

PM2.5 emissions would increase by 13,500 tons
annually. PM2.5 are criteria pollutants regulated by
the EPA NAAQS.

•

Ozone would also increase substantially.

Nuclear plant closures in other PJM states also increase
NOx emissions in Pennsylvania.
A report by The Brattle Group, Nuclear Impact on NOx
Emissions in Designated EPA Ozone Nonattainment Areas
(May 2018), notes that loss of nuclear plants in New
Jersey, Pennsylvania, Ohio or Illinois all lead to more
NOx emissions in and affecting Pennsylvania.

Pennsylvania’s nuclear plants also keep thousands of
tons of SO2, NOx, and small particulates from the air we
breathe.47

Loss of all of Pennsylvania’s nuclear plants would result in
an increase in NOx emissions of about 4,100 metric tons
annually, and would result overall in a 15-25% increase
over baseline power sector NOx emissions in combined
Mid-Atlantic ozone nonattainment areas in New Jersey,
Maryland and eastern Pennsylvania.49

Pennsylvania air quality would be worse without its
nuclear plants, and it would be more difficult for the
Commonwealth to comply with Federal environmental
regulations.

Since NOx emitters in Pennsylvania must purchase Cross
State Air Pollution Rule (“CSAPR”) allowances from a limited supply, they will pay more for compliance if NOx
emissions increase, thereby increasing the demand for

Source: David Roberts, Vox, The Simple Argument for Keeping Nuclear Power Plants Open (4/5/18)

45Dr.

Dean Murphy, presentation to the Pennsylvania Nuclear Energy Caucus, April 17, 2018.
Brattle Group, Impacts of Announced Nuclear Retirements in Ohio and Pennsylvania (April 2018)
47The Brattle Group. “Pennsylvania Nuclear Power Plants’ Contribution to the State Economy.” December 2016.
48Ibid.
49The Brattle Group, Nuclear Impact on NOx Emissions in Designated EPA Ozone Nonattainment Areas (May 2018)
46The

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allowances and putting pressure on their price (2018
Ozone Season NOx allowances were trading at $150 to
$175/ton at season start).50 Public health impacts from
poor air quality are disproportionately felt in urban areas
such as Philadelphia and Pittsburgh neighborhoods.
In 2004, the General Assembly enacted the Alternative
Energy Portfolio Standards (“AEPS”) to source a minimum
level of electricity supply from certain preferred
technologies.
The AEPS percentage began in 2006 at 5.7% of electricity
sales across all AEPS tiers and is currently 14.7% of electricity sales. It increases to 18% of sales in 2021. Sixteen
technologies are eligible for the AEPS, but nuclear is not
one of them.51
Wind and solar are in Tier 1, but other sources are also
given preference. Wood pulp, coal-mine methane, waste
coal municipal solid waste, and pulp industry byproducts
are all preferred technologies in Pennsylvania’s AEPS
program, but not nuclear energy.
In the year ending May 31, 2017, Pennsylvania’s
electricity customers spent $122.7 million on in-state
and out-of-state Alternative Energy Credits for compliance with the AEPS. None of these expenditures
support zero-carbon generation from existing zeroemission nuclear plants.
For controlling CO2 emissions, preventing premature
nuclear retirement is more cost-effective according to
the Institute for Energy Research, and as noted by the
Pennsylvania Environmental Council.52, 53 It has been the
basis for regulatory action in New York State and legislative action in Illinois and New Jersey.
The Pennsylvania Environmental Council and other
stakeholders are studying potential energy futures that
would achieve further carbon reductions.54
A key measure Pennsylvania is exploring to reduce
greenhouse gas emissions is the electrification of trans-

portation and other fossil-intensive uses. To obtain the
most greenhouse gas reductions from electrification efforts, generation must come from clean resources.
The loss of nuclear power undermines the decarbonization of the electric power sector and makes programs
such as those to encourage electric vehicles less effective, moving the Commonwealth in the wrong direction.

Documents in Chapter 6 Appendix:
1. Testimony to the Nuclear Energy Caucus,
June 19, 2018
a. Davitt Woodwell, President, Pennsylvania
Environmental Council
b. Rama Zakaria, Sr. Manager, Regulatory Policy &
Analysis, Environmental Defense Fund
c. Steve Clemmer, Director of Energy Research &
Analysis, Union of Concerned Scientists
2. Testimony to Nuclear Energy Caucus of Kathleen
Barrón, Senior Vice President Federal Regulatory
Affairs & Wholesale Markets, Exelon Corporation
(April 17, 2018)
3. The Brattle Group, Impacts of Announced Nuclear
Retirements in Ohio and Pennsylvania (April 2018)
(see Chapter 5 Appendix)
4. Dr. Dean Murphy, presentation to the Pennsylvania
Nuclear Energy Caucus, April 17, 2018.
5. The Brattle Group, Nuclear Impact on NOx Emissions
in Designated EPA Ozone Nonattainment Areas
(May 2018)
6. Pennsylvania Environmental Council, Achieving Deep
Carbon Reductions: Paths for Pennsylvania’s Electricity
Future (June 2017)
7. David Roberts, Vox, The Simple Argument for Keeping
Nuclear Power Plants Open (April 5, 2018)

50http://www.evomarkets.com/content/news/reports_28_report_file.pdf
51In Tier 1, nine qualified technologies include solar, wind, low-impact hydro, geothermal, wood pulp, coal-mine methane, biologically-derived
methane gas, fuel cells, and manufacturing byproducts from in-state energy facilities. In Tier 2, seven qualified technologies include waste coal, largescale hydro, municipal solid waste, byproducts of the pulping process, integrated combined coal gasification technology, distributed generation systems, and demand-side management. Many of these technologies have environmental impacts nuclear does not, such as harmful air emissions or
polluted discharges.
52Institute for Energy Research, The Levelized Cost of Electricity from Existing Generation Resources (July 2016).
53Pennsylvania Environmental Council, Achieving Deep Carbon Reductions: Paths for Pennsylvania’s Electricity Future, (June 2017), p. 15
54Ibid.

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7. Premature Plant Shutdowns: Grid Resilience and
National Security Impacts
The FERC, NERC, PJM and other RTOs and
ISOs are assessing the power system’s
vulnerability to low probability high
impact disruptions, such as multiple
pipeline disruptions, that are not
currently part of system planning.
Summary:
•

A diverse portfolio of energy generation resources
contributes to grid reliability and resilience while
keeping costs low for consumers.

•

Due to its ability to operate in any weather and any
time of day, nuclear energy excels as a uniquely
steady and reliable energy generation source.

•

•

A continued leading role by the U.S. in international
safety and non-proliferation standards depend on
the continued vitality of the nuclear energy sector.
U.S. nuclear expertise and capabilities are
maintained because the nuclear energy industry
provides jobs, professional development, and a
practice area outside of the defense industry.
The FERC, NERC, PJM and other RTOs and ISOs are
assessing the power system’s vulnerability to low
probability high impact disruptions, such as multiple
pipeline disruptions, that are not currently part of
system planning.
•

Such threats are real, according to experts.

•

Fuel security (the ability to deliver fuel to a
generating plant during a disruptive event) is
known to be one of the factors needed for a
resilient system.56, 57

55

•

Loss of nuclear generation through plant closures
increases Pennsylvania’s and PJM’s dependence on a
few major and potentially vulnerable gas pipelines
and on intermittent resources such as wind.

•

Dual-fuel and oil-only resources can’t be relied upon
for longer than a few days during natural gas
curtailment periods.58

•

A significant gas infrastructure event, which could
be the result of a natural or man-produced disaster,
such as a cyber-security attack59 or other serious
event, could prevent the PJM Mid-Atlantic area from
serving electric load on several days, weeks or
months if existing nuclear capacity was retired.60

Deeper Dive:
The costs of long-term power outages are enormous.
Historically, design mechanisms assure the reliability of
the bulk power system by creating alternative pathways
for nodes in the event of potential failure. However,
emerging physical and cyber-security threats mean
these traditional assurance mechanisms may not be
sufficient given today’s potential threats.
As a result, efforts are currently under way to understand
what design basis to use to prevent disruptions from
these emerging threats or if they occur, to assure quick
recovery. In addition, recent extended extreme weather
events have revealed vulnerabilities when numerous
generators failed to be on-line when needed most.
Nuclear resources are among the most fuel secure and
weather-resilient resources.
They typically maintain between 18 to 24 months of fuel,
can operate during virtually any weather scenario while
complying with strict security regulations (both cyber
and physical). However, nuclear resources are not
compensated for the value of these fuel security and

55Paul

Stockton. Fuel Resilience for the Bulk Power System: Threat-Based Modeling and Analysis. SonEcon (5/8/2018)
Makovich and James Richards. Ensuring Resilient and Efficient Electricity Generation. IHS Markit. (Sept. 2017)
57Power Engineering editors, Report Breaks from PJM Interconnection, Says Nuclear Closings Could Harm Resiliency (5/3/18)
58Navigant Consulting. PJM Liquid Fuel Survey and Research Results and Recommendations. (4/25/2018)
59See https://www.nytimes.com/2018/04/04/business/energy-environment/pipeline-cyberattack.html
60ICF. The Impact of Fuel Supply Security on Grid Resilience in PJM - Final Report. (6/8/2018)
56Lawrence

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resilience attributes. Both PJM and FERC have activities
under way to determine how to strengthen bulk power
system resilience including how to assure fuel security.61
What is Resilience: “A reliable system is not the same
thing as a resilient electric system. . . a resilient grid is one
with the following characteristics: It is one where the
grid planners, operators and regulators assume that they
cannot foresee and avoid every type of event that could
take out the system in a very big way; where they therefore plan for how they will ride through big-impact
events with as much of the system still intact as possible”62 – Susan Tierney Utility Dive (December 13, 2017)
PJM is operating at very high levels of reliability, but according to PJM testimony to the Nuclear Energy Caucus,
they may need operational and pricing changes to increase the resilience of the system and improve price
formation.63 Such changes have not yet occurred.
Extreme Weather: In January 2014, a broad swath of the
country, including Pennsylvania, experienced an extended period of extreme cold in a weather event known
as a “Polar Vortex”. Temperatures were 20 to 30°F below
average in places, and these temperatures resulted in
record high regional electrical demand. The weather
conditions exceeded the design basis of some generating units, and limits on natural gas transportation curtailed fuel supplies to gas generation plants.64 Some coal
plants were shutting down because of frozen coal piles.
Following the 2014 Polar Vortex, PJM established a capacity performance product which partially prices
weather-related resilience into the PJM capacity auction.
However, a multi-region cold snap in January 2018
showed the weather-related hardening to date is insufficient. By the sixth day of the January 2018 cold snap,
PJM had 23,750 MW of forced outages disrupting its supply. As Figure 7 shows, most of these outages continued
to be from non-performance or unavailability of natural
gas, coal, and oil. Nuclear plants are clearly needed to
61See

assure power supply in the event of major gas delivery
disruptions and gas and coal outages.
One of the cold-hardening measures natural gas plants
take is to install dual-fuel capabilities to enable burning
oil for up to a couple of days in the event natural gas is
not delivered.
The efficacy of such measures was tested in January
2018 when an unusually powerful winter storm traveled
up the East Coast. In New England, dual-fuel units
burned through not only oil, but most of their emissions
limits for the year when they needed to switch fuels. This
will keep them unavailable to similarly respond in another cold spell for the remainder of the calendar year,
unless they run anyway in violation of their air permits.65
Forbes contributor James Conca detailed nuclear’s value
in a September, 2018 article entitled, “Hurricane Florence
No Problem for Nuclear Power Plants.”66
In his article, Conca details examples of extreme weather
events and how nuclear power producers safely and reliably performed during those challenges.
For example, Duke’s Brunswick nuclear station was in the
direct path of Hurricane Florence and, “has withstood
several hurricanes since the two reactors there began
operation in the mid-1970s, including Category 3
Hurricane Diana in 1984 and Category 3 Hurricane Fran
in 1996. Category 4 Hurricane Hugo, the most oftencompared to Florence, made landfall about 150 miles
southwest of Brunswick in South Carolina in 1989.” 67
Conca notes that unlike other power plants, nuclear operators keep food, water and other necessities onsite to
prepare for potential isolation of the site, and staff
needed during the storm are brought in to ensure
proper resources are available for an extended period.68
In fact, he writes, “Nuclear is the only energy source
immune to all extreme weather events – by design.

http://www.pjm.com/-/media/library/reports-notices/special-reports/2018/20180430-valuing-fuel-security.ashx, and FERC Docket No. AD18-7

62https://www.utilitydive.com/news/about-that-national-conversation-on-resilience-of-the-electric-grid-the-ur/512545/
63PJM FERC filing, State Policies and Wholesale Markets Docket No. AD17-11-000, provided to NEC in 4/26/2017 hearing NERC Polar Vortex Review
(Sept. 2014)
64https://www.nerc.com/pa/rrm/January%202014%20Polar%20Vortex%20Review/Polar_Vortex_Review_29_Sept_2014_Final.pdf
65Andrew Coffman Smith. New England Dual-Fuel Units Burning Through Oil, Emissions Limits Amid Cold Snap. S&P Global (1/2/2018)
66https://www.forbes.com/sites/jamesconca/2018/09/13/hurricane-florence-no-problem-for-nuclear-power-plants/#2e5e1e17a71b
67Ibid.
68Ibid

Premature Plant Shutdowns: Grid Resilience and National Security Impacts   25

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

Plants have steel-reinforced concrete containments with
over 4-foot thick walls. The buildings housing the reactors, vital equipment and used fuel have steel-reinforced
concrete walls up to 7 feet thick, which are built to withstand any category hurricane or tornado. They can even
withstand a plane flying directly into them.” 69

As was repeated time and again during
the Nuclear Energy Caucus’ review of
nuclear power’s reliability and
resiliency, regardless of weather event –
hurricane, flood, earthquake, heat
wave or severe cold, nuclear units
outperformed other generation types
consistently to the benefit of electricity
customers.
Citing another example, Conca notes that in the Summer
of 2017, a heat wave blanketed the United States with
extreme temperatures, which affected most energy production, causing electricity use to spike as 122 million
Americans were under heat alerts. “Fortunately, nuclear
power didn’t mind, scoring record capacity factors of
96% and up, with no increase in price.”70
As was repeated time and again during the Nuclear Energy Caucus’ review of nuclear power’s reliability and resiliency, regardless of weather event – hurricane, flood,
earthquake, heat wave or severe cold, nuclear units outperformed other generation types consistently to the
benefit of electricity customers.
Figure 7: 2014 and 2018 Forced Outages by Fuel Type

Man-Made Threats: Weather contingencies are only part
of the resilience problem.
PJM is conducting a study, Valuing Fuel Security, to
simulate grid disruptions that could occur from extreme
weather or from other threats, such as coordinated
physical or cyber-attacks.71
In recommendations to PJM, Dr. Paul Stockton writes:
“the risks of physical attacks on natural gas systems merit
special concern.” Dr. Stockton was Assistant Secretary of
Defense for Homeland Defense and America’s Security
Affairs from June 2009 until January 2013. In his recommendations to PJM, Dr. Stockton discusses the need for
PJM to assess manmade disruption scenarios that would
disrupt multiple pipelines and storage facilities simultaneously, either reducing delivery capability on constrained pipelines, or a realistic but extreme contingency
where adversaries disrupt 80% of the gas pipelines in the
PJM region for six months.72

“the risks of physical attacks on natural
gas systems merit special concern.”
A study by the consulting company ICF, The Impact of
Fuel Supply Security on Grid Resilience in PJM, similarly
found PJM is vulnerable to extended electricity outages
if there are major pipeline disruptions.73
The results of the ICF analysis show that “a significant gas
infrastructure event could prevent the PJM Mid-Atlantic
area from serving electric load on a number of days if existing nuclear capacity was retired. Such an event could
result in the loss of nearly 27 GW of gas-fired generation,
with 18 GW serving the PJM MidAtlantic area, depending on the
severity and location of
such event.
When combined with the retirement of a similar amount of nuclear capacity, the analysis implies
such an event would put as much
as 22 percent of the area’s load at

Source: PJM Cold Snap Performance: Dec. 28, 2017 to Jan. 7, 2018. PJM Interconnection (2/26/18)

69Ibid.
70Ibid.
71http://www.pjm.com/-/media/library/reports-notices/special-reports/2018/20180430-valuing-fuel-security.ashx
72Paul

Stockton. Valuing Fuel Security: Recommendations on Study Scope and Simulated Disruptions. SonEcon. June 8, 2018.
Energy Institute (NEI), The Impact of Fuel Supply Security on Grid Resilience in PJM (6/8/18)

73Nuclear

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 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

their tanks promptly if the entire dual-fuel and oil-only
PJM fleet were simultaneously trying to refill their tanks,
and if they were competing for scarce delivery sources
with other fuel oil users, such as hospitals, governmental
institutions, and others operating generators. Logistics
for refilling this level of fuel oil in a reasonable amount
of time would likely exceed the current delivery
capabilities.
The Department of Energy (“DOE”) has publicly stated on
numerous occasions that the grid must be “resilient and
secure.”

risk of being shed in the highest load hours. Of the
nearly 18 GW of gas-fired capacity that could be impacted by such an event, over 45 percent has no backup
fuel capability and would be immediately unavailable
during such an event.
While the remaining capacity reports having dual-fuel
backup capabilities, on-site fuel resources would last
generally less than 5 days, if these units are operated at
higher load factors as a result of the loss of gas-only resources during such an event. While backup supplies
could be ordered to replace fuel used during such an interruption, the ability of the upstream oil distribution
network to replenish such supplies during such an event,
and the associated logistics of such refill, is questionable,
particularly if such event is widespread. The study also
shows that the preservation of nuclear capacity in PJM
would successfully mitigate the loss of load risk.
Gas curtailment periods may be the result of extreme
weather events, major gas infrastructure failures and/or
interruption due to other events such as terrorism.
In a recent study, Navigant Consulting found that “if a
curtailment event lasts longer than a few days, significant quantities of dual fuel and oil-only resources could
be forced out due to a lack of fuel and be unable to
timely receive new fuel supplies.”
The study showed that more than 50% of the capacity
would be off line within 4 days and more than 75%
would be off-line within six days.
Plants would face an even greater challenge in refilling

Resources that have a secure on-site fuel supply, including nuclear, are essential to support the nation’s defense
facilities and critical infrastructure. In October 2017, the
DOE used Section 403 of the Department of Energy Organization Act of 1977 to order FERC to consider action
to preserve fuel-secure generation within 60 days (“DOE
NOPR”).74 The DOE action found that the resiliency of the
nation’s electric grid is threatened by the premature retirements of power plants that can withstand major fuel
supply disruptions and, in those critical times, continue
to provide electric energy, capacity, and essential grid reliability services.

In October 2017, the Pennsylvania House
of Representatives adopted (176-9)
HR 576, and the Pennsylvania Senate
adopted (42-8) SR 227, bi-partisan
Resolutions in support preserving the
Commonwealth’s fuel-secure generation
resources.
In October 2017, the Pennsylvania House of Representatives adopted (176-9) HR 576, and the Pennsylvania
Senate adopted (42-8) SR 227, bi-partisan Resolutions in
support preserving the Commonwealth’s fuel-secure
generation resources.
The General Assembly urged the FERC to swiftly consider
DOE’s proposed Grid Resiliency Pricing Rule and implement policies to ensure fuel-secure generation resources
receive proper compensation for their reliability and resiliency.75 Despite the call for swift action, FERC did not
respond accordingly. Instead, it issued an order in early

74https://www.energy.gov/articles/secretary-perry-urges-ferc-take-swift-action-address-threats-grid-resiliency
75https://legiscan.com/PA/text/HR576/2017

Premature Plant Shutdowns: Grid Resilience and National Security Impacts   27

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

2018 terminating the DOE NOPR and opening an administrative docket on resilience. That docket provides a
forum for further study, but by the time it materializes
into action, some of the resources needed for resiliency
will already be gone.

Latest PJM Report Confirms the Problem: On November
1, 2018, PJM released the results of a fuel security analysis designed to test the grid’s limits to endure high-impact, long-term disruptions to generators’ fuel supply.

Experts feel so strongly about the role of nuclear energy
in enhancing national security that 77 national security
officials, former statesmen, and business leaders in June
2018 wrote an open letter to U.S. Secretary of Energy
Perry urging DOE to take immediate action to prevent
the closure of U.S. nuclear energy reactors.76

“The study also identified scenarios in
which the system would face power
outages, applying extreme, but
reasonably plausible assumptions for
weather, customer demand, generator
retirements and fuel availability.”

That letter echoes an earlier letter of warning by Tom
Ridge, in which he states “As Congress and the administration work in the years ahead to advance economic opportunity while preventing threats to our security, they
must strengthen and preserve our nation’s baseload nuclear fleet, thus protecting our national security while
ensuring a diverse, resilient energy grid.”77

According to PJM, “The study also identified scenarios in
which the system would face power outages, applying
extreme, but reasonably plausible assumptions for
weather, customer demand, generator retirements and
fuel availability.” 80

Or, as James Conca put it in a Forbes op-ed: “Nuclear in
America is on a cusp between two very different paths.
One path leads to continued global leadership. The other
leads to a slow fading of our nuclear program to that of a
third-rate power, leaving Russia and China to lead the
world.”78
Resilience to man-made high-impact disruptions is not
priced into the market.
There is no price signal that indicates dependency on
natural gas has grown to be “too high.” In the meantime,
the urgency for nuclear operators is growing.
In the May 2018 PJM Base Residual Auction for capacity,
over one-third of PJM’s nuclear power failed to clear – a
200% increase in uncleared capacity since the previous
year.79 According to Exelon and FirstEnergy Solutions
company announcements, the uncleared capacity included both the Three Mile Island and Beaver Valley
nuclear generating stations.

The results of the study confirm what the NEC has feared
- that while today’s grid can withstand extreme conditions, tomorrow’s grid without the reliability and resiliency of nuclear power could, “result in material levels
of generation unavailability and load shedding.”81
In practical terms, this means that, after conducting hundreds of stress test scenarios, starting in 2023, “…the
more the grid was stressed, the more important fuel supply characteristics, location of fuel supply disruption and
demand response became,” according to Michael Bryson,
Vice President of PJM Operations.82
PJM’s analysis identified key variables to the security of
the grid’s fuel supply, including availability of non-firm
gas service, ability of the fuel-oil delivery system, physical breaks at key locations on the pipeline system, customer demand (load), generator retirements and
replacements, and the use of operating procedures to
conserve fuel during peak winter conditions.

76Akerson et al.; Letter to DOE Secretary Rick Perry (6/26/18) https://www.nei.org/CorporateSite/media/filefolder/resources/letters-filingscomments/letter-secretary-energy-rick-perry-nuclear-national-security-20180626.pdf
77Tom Ridge. Keeping Nuclear in the Nation’s Energy Mix. The Philadelphia Inquirer (8/9/17)
78James Conca. Nuclear Energy in America is Teetering On A Cusp. Forbes (11/2/17)
79Press release. “Exelon Announces Outcome of 2021-2022 PJM Capacity Auction.” (5/24/18)
80See https://www.pjm.com/-/media/about-pjm/newsroom/2018-releases/20181101-pjm-completes-fuel-security-study-as-part-of-resilience-initiative.ashx
81Ibid.
82Ibid.

28   Premature Plant Shutdowns: Grid Resilience and National Security Impacts

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

In uncharacteristic directness, PJM reported that, “The
findings underscore the importance of PJM exploring
proactive measures to value fuel security attributes, and
PJM believes this is best done through the competitive
wholesale markets.”83
It is important to note that other than the premature
closure of nuclear plants, nuclear energy sources help
avoid all of the key variables identified by PJM.
The NEC is hopeful that the benefits of nuclear power
can be part of PJM’s solution and we encourage PJM to
take seriously their obligation to ensure the reliability of
the high-voltage electric power system, particularly because the loss of a nuclear asset is irreversible.

9. NERC Polar Vortex Review (Sept. 2014)
https://www.nerc.com/pa/rrm/January%202014%20
Polar%20Vortex%20Review/Polar_Vortex_Review
_29_Sept_2014_Final.pdf
10. Andrew Coffman Smith. New England Dual-Fuel Units
Burning Through Oil, Emissions Limits Amid Cold Snap.
S&P Global (1/2/2018)
11. http://www.pjm.com/-/media/library/reportsnotices/special-reports/2018/20180430-valuingfuel-security.ashx
12. Paul Stockton. Valuing Fuel Security:
Recommendations on Study Scope and Simulated
Disruptions. SonEcon. June 8, 2018.

Documents in Chapter 7 Appendix:
1. Paul Stockton. Fuel Resilience for the Bulk Power
System: Threat-Based Modeling and Analysis.
SonEcon (5/8/2018)

13. https://www.energy.gov/articles/secretary-perryurges-ferc-take-swift-action-address-threats-grid
-resiliency

2. Lawrence Makovich and James Richards. Ensuring
Resilient and Efficient Electricity Generation. IHS
Markit. (Sept. 2017)

14. https://legiscan.com/PA/text/HR576/2017

3. Power Engineering editors, Report Breaks from PJM
Interconnection, Says Nuclear Closings Could Harm
Resiliency (5/3/18) https://www.power-eng.com/
articles/2018/05/ report-breaks-from-pjminterconnection-says-nuclear-closings-couldharm-resiliency.html

15. Akerson et al.; Letter to DOE Secretary Rick Perry
(6/26/18) https://www.nei.org/CorporateSite/
media/filefolder/resources/letters-filingscomments/letter-secretary-energy-rick-perrynuclear-national-security-20180626.pdf
16. Tom Ridge. Keeping Nuclear in the Nation’s Energy Mix.
The Philadelphia Inquirer (8/9/17)

4. Navigant Consulting. PJM Liquid Fuel Survey and
Research Results and Recommendations. (4/25/2018)

17. James Conca. Nuclear Energy in America is Teetering
On A Cusp. Forbes (11/2/17)

5. ICF. The Impact of Fuel Supply Security on Grid
Resilience in PJM - Final Report. (6/8/2018)

18. Press release. “Exelon Announces Outcome of
2021-2022 PJM Capacity Auction.” (5/24/18)

6. PJM Interconnection. PJM Cold Snap Performance:
Dec. 28, 2017 to Jan. 7, 2018. (2/26/18)
7. PJM FERC filing, State Policies and Wholesale Markets
Docket No. AD17-11-000, provided to NEC in
4/26/2017 hearing
8. https://www.utilitydive.com/news/about-thatnational-conversation-on-resilience-of-the-electricgrid-the-ur/512545/

83Ibid.

Premature Plant Shutdowns: Grid Resilience and National Security Impacts   29

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

8. Other State Actions and Potential Options
Summary:
•

•

Several states have placed their faith in Regional
Transmission Organizations ("RTOs") like PJM and
federal policymakers to prevent the premature shut
down of their nuclear plants but have instead
witnessed a lack of action (and, in some instances,
resistance to helpful action) resulting in the
devasting economic, environmental, and consumer
impacts associated with losing their state's nuclear
industry.
Other states learned from these mistakes, and have
taken action into their own hands and implemented
creative policies that would preserve their states'
nuclear industry:
•

•

•

•

In 2016, New York and Illinois implemented Zero
Emission Credit ("ZEC") programs that, like
Renewable Energy Credits ("RECs"), are designed
to pay generation resources for their "zero
-emission" attributes.
In 2017, Connecticut enacted legislation
allowing their nuclear plant to compete in
energy markets with renewable generators,
such as solar and wind.
In 2018, New Jersey created a Zero Emission
Certificate program designed to compensate
nuclear plants for their zero-emission and
environmental attributes; as well as their fuel
diversity attributes.

In addition to their own inaction, PJM actively
opposed states' efforts to prevent the premature
shut down of their nuclear plants and initiated
litigation at FERC to implement rule changes that
would have led to higher prices in states that enact
clean energy policies. For example, both the PJM
Board and the PJM Market Monitor filed amicus
briefs in federal court opposing the ZEC program in
Illinois. In addition, in April 2018, PJM filed two
proposed changes to its capacity markets that would
have required capacity market prices to increase
significantly for states supporting nuclear resources.

30   Other State Actions

The FERC is now engaged in an ongoing
proceeding to determine a way for PJM
to accommodate state programs designed
to support preferred energy resources…
The FERC is now engaged in an ongoing proceeding to
determine a way for PJM to accommodate state programs designed to support preferred energy resources
(including Pennsylvania's Alternative Energy Portfolio
Standards program, among others). Depending on the
outcome of this FERC proceeding Pennsylvania likely will
be left with four options to preserve the Commonwealth’s clean energy resources, including its nuclear
plants. These options are:
1. Do nothing and leave Pennsylvania's clean
energy resources, including its nuclear plants, on
a trajectory to early retirement – effectively
allowing PJM to dictate the mix of resources
serving Pennsylvania.
2. Modify AEPS (or establish a ZEC program) to put
nuclear generation on equal footing with other
zero-emission electric generation resources in
Pennsylvania.
3. Modify AEPS (or establish a ZEC program) with a
“safety valve” mechanism that (depending on the
outcome of the FERC proceeding) would allow
Pennsylvania to adopt a new capacity construct
proposed by FERC that is designed to
accommodate state programs to support
preferred generation resources.
4. Establish a Pennsylvania carbon pricing program.

Deeper Dive:
Since 2013, six nuclear reactors in the United States have
permanently and prematurely shut down and another 12
reactors have been scheduled to shut down. In the Commonwealth, TMI and Beaver Valley have announced they
will be permanently and prematurely closed.

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

The issue has played out over the past several years,
but our Commonwealth has now reached the point of
no return and, like other states, must decide whether to
properly value all the attributes of these enormously
important assets or let them and all the benefits that
come with them (jobs, economic, security, reliability,
resiliency, fuel diversity, and environmental benefits) disappear forever, to the detriment of our Commonwealth
and the families and businesses we are responsible
for representing.
This section of the Report focuses on actions other states
initiated to preserve nuclear generation and potential
options for Pennsylvania to consider.
It provides specific state legislative and regulatory actions proposed in various states and what has worked
and not worked, so far.
Despite the enormous benefits of preserving in-state
nuclear generation, as described throughout this report,
only a few initiatives (legislative or regulatory) have
advanced.
Nevertheless, policymakers in several states are increasingly discussing this issue as more plants come under
pressure. Policies range from offering tax incentives or
imposing carbon emission fees, to the creation of
statewide programs that require utilities to purchase a
specified amount of the environmental attribute of nuclear power, similar to AEPS. The intent of this section is
to describe state level actions that have been effective in
preserving affordable, reliable and clean energy.
The Commonwealth needs a solution that recognizes the
value of existing nuclear plants to energy reliability, the
economy and the environment.

…the ongoing FERC proceeding to adopt
a new market construct that recognizes
the right of states to regulate its
generators and the environment, … may
add a new layer of required action
One framework already exists: Pennsylvania, through
AEPS, already recognizes the value of other clean energy
technologies, with Alternative Energy Credits ("AECs").
However, the ongoing FERC proceeding to adopt a new

market construct that recognizes the right of states to
regulate its generators and the environment, and
accommodate state programs like AEPS, may add a new
layer of required action that will be further discussed in
this section.
I. States That Did Not Act: Several states placed their
faith in regional and federal policymakers to prevent the
premature shutdown of their nuclear plants. A passive
strategy and lack of initiative resulted in the devasting
economic, environmental, and consumer impacts associated with losing their state’s nuclear industry. The following are the outcomes experienced by states that
failed to take matters into their own hands:

✓ Vermont
Vermont Yankee – The
620 MW Vermont Yankee nuclear plant shut
down in 2014, citing
the same economic
pressures that have put
other U.S. nuclear
plants at risk. The plant had 625 full time employees and
employment grew significantly during outages.
Because of the premature closure, many people lost their
jobs and New England carbon emissions increased. The
projected economic impact is a loss of more than 1,100
jobs and $480 million in annual economic activity.
Despite all the benefits the plant brought to Vermont
and the broader New England region, there was lack of
effective action by the state and unfortunately, the plant
closed.

✓ Wisconsin
Kewaunee Power Station – The 550 MW nuclear plant shut down in
2013, citing the same
economic pressures
that have put other U.S.
nuclear plants at risk.
The plant had 650 full time employees that grew to 900
every 18 months during scheduled outages.
For decades, the Kewaunee nuclear plant was a financial
powerhouse in northeastern Wisconsin, boosting the annual economy in a three-county region by $630 million.

Other State Actions   31

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

While the plant was operating, Dominion paid utility
taxes to the state of Wisconsin, which in turn distributed
roughly $750,000 annually to Kewaunee County and
around $400,000 to Carlton.
Despite all the benefits the plant brought to Wisconsin,
on October 22, 2012, Dominion publicly announced
plans to close the Kewaunee Power Station. Unfortunately for the residents of Kewaunee County and the
state of Wisconsin, action was not taken by the state to
preserve the plant.

✓ California
San Onofre – When the
San Onofre nuclear
plant in Southern
California closed due to
equipment failure in
2012, its 2,200 MW
output was replaced
mostly by natural gas. The result: enormous increases in
emissions and negative environmental impact.
A 2015 study found that, during the year after the
shutdown, California carbon emissions rose by 9 million
metric tons – equivalent to putting 2 million additional
cars on the road.
Additionally, an economic study found electricity generating costs rose by $350 million during the year following the closing of the twin-unit San Onofre nuclear plant
in Southern California.84
II. State Actions to Preserve Existing Nuclear Plants:
Other states have learned from the mistakes made by
Vermont, Wisconsin, and California.
Rather than hope that Congress, FERC or the RTOs would
intervene to preserve their states’ nuclear plants, New
York, Illinois, Connecticut, and New Jersey have each initiated new state level policies to prevent the premature
retirement of their nuclear plants.
Although each state followed a slightly different approach, the policy initiatives are all based on the core
principles that: (i) nuclear generation has enormous economic, security, reliability, resiliency, fuel diversity, and
environmental benefits; (ii) nuclear retirements cannot

84Davis

be reversed, and after shut-down, all nuclear generation
derived benefits are lost forever; and (iii) environmental
and other attributes from nuclear generation have not
been compensated by the market.

Rather than hope that Congress, FERC or
the RTOs would intervene to preserve
their states’ nuclear plants, New York,
Illinois, Connecticut, and New Jersey
have each initiated new state level
policies to prevent the premature
retirement of their nuclear plants.
Although the recent FERC order, to be discussed later
in this section, undermines the programs developed in
Illinois and New Jersey, the elements of these state programs and as well as programs created in New York and
Connecticut are described here:

✓ Illinois
Illinois, the country’s top producer of nuclear energy
with 11 nuclear reactors at six plants, was faced with the
same dilemma we have before the Commonwealth
today. Those 11 reactors generate approximately 50% of
the state’s electricity and over 90% of the state clean energy.
In late 2016, the Future Energy Jobs Act (“FEJA”) was enacted into law, with broad bi-partisan support. Among
other things, FEJA updates Illinois’ RPS, net metering,
and energy efficiency standards, as well as creates a new
Zero Emissions Credit (“ZEC”) program. It is calculated
that the Illinois ZEC program will preserve over $1.2 billion in economic activity annually.
ZEC Program Details: Per
the ZEC
program
and beginning in
2017, any
electric
utility serving at least

and Hausman, Market Impacts of a Nuclear Closure, American Economic Journal of Applied Economics 2016, 8(2):92-122.

32   Other State Actions

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

100,000 retail customers in Illinois is to procure zero
emissions credits (ZECs) to cover 16% of the actual
amount of electricity to its retail customers in the 2014
calendar year.

It is calculated that the Illinois
program will preserve over $1.2 billion
in economic activity annually.
ZECs are to be contracted for a period of 10 years - ending May 2027. Like a renewable energy credit, a ZEC can
only be used once to comply with a single portfolio or
other standard. The price per ZEC is computed as the social cost of carbon ($16.50 per MWh), adjusted downward according to a market price index for wholesale
power. Importantly, as market prices increase, ZEC prices
decrease. Customer costs are further restrained by an
overall cap which limits the total annual cost of ZEC
payments.
The Illinois ZEC program:
• Preserves the most cost-effective zero-emission
resource.
•

Protects thousands of jobs and preserves billions in
state economic activity annually.

•

Prevents significant increases in air pollution
emissions.

•

Preserving nuclear with these programs is a less
expensive outcome for customers than the
alternative.

The Illinois ZEC program has been challenged in
the courts.85

✓ New York
In December 2015, Governor Andrew Cuomo directed
the New York State Department of Public Service (“DPS”)
to develop a Clean Energy Standard (“CES”) to meet the
state energy plan’s 50% renewable energy by 2030 target
through an enforceable mandate. The Governor also
directed the DPS to explore ways to keep emission-free
nuclear power facilities operational to continue New
York’s greenhouse gas emissions reductions.
Then in early 2016, Governor Cuomo’s staff issued a report that proposed including nuclear power in the state
renewable portfolio standard, along with making nuclear
facilities eligible for ZECs.
On Aug. 1, 2016, the New York Public Service Commission approved a proposal that included ZECs for upstate
nuclear plants but dropped the RPS-style mandate. The
policy went into effect in 2017, and it compensates upstate nuclear plants for every megawatt-hour (“MWh”) of
emissions-free electricity generated. The Public Service
Commission staff said the state will experience “significant economic and environmental benefits” as a result of
the ZEC program.

By retaining the state’s nuclear fleet,
New York avoids replacing the lost
baseload capacity with plants that
would result in emissions of around
31 million metric tons of carbon
dioxide during the next two years
As background, nuclear power accounts for roughly 30%
of New York’s electricity generation. There are six operating nuclear reactors at four nuclear power facilities in the
state. The Ginna and FitzPatrick facilities are single-reactor power plants, while Indian Point and Nine Mile Point
each operate two reactors.

85On February 14, 2017, two lawsuits were filed in the Northern District of Illinois against the Illinois Power Agency (“IPA”) alleging that the state’s ZEC
program violated certain provisions of the U.S. Constitution. One complaint was filed by a group of ComEd customers, and the other was brought by
the Electric Power Supply Association (“EPSA”) and three other electric suppliers. The focus of both complaints is that the IL ZEC program would distort
the FERC-approved energy and capacity market auction system of setting wholesale prices, and both actions sought preliminary and permanent injunctive relief preventing the implementation of the program. On July 14, 2017, the judge issued an order dismissing the case. Oral argument was
held January 3, 2018. At the oral argument, the 7th Circuit requested supplemental briefs, which were filed on January 26, 2018. On February 21, 2018,
the 7th Circuit issued an order inviting the views of the United States as amicus. The Solicitor General filed the amicus brief on May 29, 2018, which
largely supported the position that the ZEC program was lawful. On September 13, 2018, the Seventh Circuit Court of Appeals affirmed the lower
court’s dismissal of both lawsuits. On September 27, 2018, the plaintiffs filed a request for a panel rehearing with the U.S. Circuit Court of Appeals for
the Seventh Circuit, which has been denied.

Other State Actions   33

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

ZEC Program Details: In the first two years, upstate nuclear plants are receiving compensation from ZECs at a
rate of $17.48 per MWh, based on the social cost of carbon and the avoided carbon emissions the plants represent. The rate will be adjusted every two years based on
several factors, including the social cost of carbon and
market conditions. Importantly, if the forecast price of
electricity and capacity rises above $39 per MWh, ZECs
compensation would drop correspondingly. Lastly the
program preserves competitive rates and saves customers $1 billion annually.
The New York ZEC program:
• Preserves the most cost-effective zero-emission
resource.
•

Protects thousands of jobs and preserves $1 billion
in state economic activity annually.

•

Prevents significant increases in air pollution
emissions.

•

Preserving nuclear with these programs is a less
expensive outcome for customers than the
alternative.

The New York ZEC program has been challenged in
the courts.86

✓ New Jersey
On May 23, 2018, Governor Phil Murphy signed two bills
into law. The first bill, S-2313, creates a Zero Emissions
Certificate (“ZEC”) program to maintain New Jersey’s
nuclear energy supply. The second bill, A-3723, among
other things, has a 35% renewables mandate by 2025
and eventually 50% by 2030. Concerning nuclear generation Governor Murphy said, “I believe the biggest
bridge we have to our clean energy future are the nukes
and, not to mention, the thousands of jobs they support.”
Both bills passed by wide margins in both the New
Jersey Assembly and Senate.

New Jersey has four nuclear reactors - the single-unit
Hope Creek, the twin-unit Salem plants, and the singleunit Oyster Creek. Together these plants generate nearly
half of that state’s electricity and more than 90% of New
Jersey’s clean generation. New Jersey’s nuclear plants
help avoid
the release
of 14 million tons
of air pollution each
year – the
equivalent
of 3 million more
cars on
the road.
ZEC Program Details: The ZEC legislation directs the
state's Board of Public Utilities (“BPU”) to issue Zero Emission Certificates, which represent the fuel diversity, air
quality, and environmental attributes of one megawatthour of electricity generated by an eligible nuclear
power plant which has been selected by the BPU to participate in the ZEC program.
To be eligible, a plant must, in addition to other requirements, be licensed to operate until 2030, demonstrate
that it makes a significant contribution to New Jersey’s
air quality and that it is at risk of closure within three
years.
Importantly, the amount an eligible nuclear plant can receive under New Jersey’s ZEC program is capped and any
excess funds are refunded. Finally, New Jersey’s ZEC program protects thousands of jobs and preserves over
$800 million in state economic activity and $400 million
in avoided rate increases annually.

86On October 19, 2016, a group of fossil generators filed a complaint in federal court seeking to overturn the August 1 Order on constitutional grounds
(Coalition for Competitive Electricity v. Zibelman et al.). The state filed a motion to dismiss the complaint. The court heard oral arguments on the motions on March 29, 2017, but held discovery in abeyance. On July 25, 2017, the court granted both motions to dismiss. On Aug. 24, 2017, the fossil
generators appealed to the Second Circuit. Fossil generators’ initial brief on appeal was filed on October 13, 2017. Oral argument was held on March
12, 2018. On September 27, 2018, the Second Circuit affirmed the district court’s decision dismissing CCE’s preemption and dormant Commerce
Clause challenges to New York’s ZEC Program.

In addition to the U.S. District Court challenge, the New York ZEC program has been challenged in the New York Trial Court. That matter has not been
fully briefed due to pending resolution relating to the dispute over the record. Plaintiff’s reply brief is due December 17, 2018.

34   Other State Actions

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

The New Jersey ZEC program:
• Preserves the most cost-effective zero-emission
resource.

jected to have inadequate market revenues as
determined by DEEP and will likely retire without
ratepayer support.”

•

Protects thousands of jobs and preserves over
$800 million in state economic activity and
$400 million in avoided rate increases annually.

•

Prevents significant increases in air pollution
emissions.

Millstone’s owner, Dominion Energy, had petitioned
PURA seeking such at-risk status in a separate but related
proceeding. The initial draft RFP created an “At-Risk Time
Period” that effectively precluded Dominion from entering into contracts for the output from its Millstone nuclear facility until June 1, 2023.

•

Preserving nuclear with these programs is a less
expensive outcome for customers than the
alternative.

✓ Connecticut
In October 2017,
Connecticut’s governor
signed a bill into law
that recognized the
carbon-free attributes
of nuclear power by allowing the Millstone
nuclear plant to compete for state contracts of zero
emission generation that contribute to the reliability,
fuel diversity, and environmental goals of the state. The
Millstone nuclear power plant, which provides more
than 70% of Connecticut’s electric generation, is at risk
of closing.87
In 2017, the State of Connecticut adopted into law provisions to enable the purchase of energy, capacity and attributes from existing nuclear generation facilities under
long term power contracts with electric distribution
utilities.
To implement this new authority, the State is conducting
a resource assessment. The Connecticut Department of
Energy and Environmental Protection (“DEEP”) and Public Utilities Regulatory Authority (“PURA”) issued the draft
final report on Jan. 22, 2018 and asked industry stakeholders to submit comments.
Recently, DEEP issued a final RFP soliciting energy from
eligible nuclear, hydro, RPS Class I and paired and co-located storage resources. These resources may be new,
existing or “existing confirmed at-risk.” The RFP defines
“at-risk” resources as generating facilities that are “pro-

87Millstone

Dominion and several State legislators protested, asserting that the financial status of the units as well as the legislation enabling the RFP mandated immediate action.
As a result, the final RFP sets the At-Risk Time Period for
June 1, 2022 – a full year earlier than the draft RFP. It also
allows an eligible resource to demonstrate to DEEP that
its at-risk status requires it to enter into a contract even
sooner than June 1, 2022. The agency expects to select
winning bidders by late 2018 or early 2019, and then bidders will submit final contracts to PURA for review and
approval by Spring of 2019.
Millstone is Connecticut’s only nuclear plant and produces nearly all the state’s zero-carbon energy. If
Millstone were to close, it could jeopardize the state’s
emission reduction targets and result in the loss of
1,500 jobs.
III. Recent FERC Action Provides Guidance on Potential
Options for Pennsylvania: Discussions have taken
place for years about how PJM's competitive wholesale
electricity market should recognize the right of states to
regulate electric generation and the protect the environment, and accommodate state programs designed to
support preferred sources of electricity like wind, solar,
and nuclear while maintaining free-market competition.
Despite decades of co-existence of the competitive market and state renewable energy programs, like Pennsylvania's AEPS program, PJM recently decided that state
efforts to value the environmental attributes of nuclear
energy represented an existential threat to its "competitive" wholesale electric markets.
Rather than working to implement a market-based solution that would accommodate state policy goals, PJM

produces 2,100 megawatts of power through two operating reactors that distribute energy throughout New England.

Other State Actions   35

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

actively opposed states' pursuit of policies to prevent the
premature shut down of their nuclear plants, while assuring state policymakers that they were working diligently
to correct flaws in the market that PJM itself had long
identified and recognized are negatively impacting
nuclear generation.

In its order, FERC concluded:
1. That the current capacity market is
not just and reasonable and needs to
be reformed; and,
2. PJM must accommodate state clean
energy programs.
In April 2018, after over twelve months of stakeholder
input, PJM submitted two proposals to FERC that, disappointingly, would have raised costs for consumers in
states that enact clean energy programs.
On June 29, 2018, FERC issued a 3-2 decision rejecting
both PJM proposals and directed PJM to accommodate
the public policy choices states have made to support
renewable and nuclear energy. In its order, FERC
concluded:
1. That the current capacity market is not just and
reasonable and needs to be reformed; and,
2. PJM must accommodate state clean energy
programs.
Since PJM was unable to come up with a policy mechanism on its own to accommodate state clean energy programs, FERC provided PJM and states with a two-part
mechanism that could protect the PJM market while also
accommodating state programs.
Under the first part of the mechanism, the bids into PJM’s
capacity market from any resource receiving state support would be reset (e.g., increased) to the level the resource would have offered if it had no state-authorized
support payments.
If only the first part of the FERC-recommended mechanism is implemented, the state-supported resources, e.g.
Pennsylvania AEPS resources, would be at risk of not
"clearing" in the PJM capacity market, as their reset bid
levels could be too high, and other capacity resources
36   Other State Actions

would be procured in place of the state-supported
resource.
As a result, the resource receiving state support would
not receive a capacity payment, and customers would
over-pay for capacity (once through the state program,
and again for the capacity being procured by PJM in
place of the state-supported resource).
However, FERC also suggested a second part of the
mechanism, called the Fixed Resource Requirement
(“FRR”) Alternative that is designed to accommodate the
state programs while preserving the PJM market.
The "FRR Alternative" mechanism allows states to independently procure capacity for a portion of their load
from specific state-preferred generation resources and
remove the generation and associated load from the PJM
capacity market. It can be viewed as a “safety valve” that
states can utilize to protect their programs from the impact of the first part of the mechanism described above.
The FRR Alternative is a variation of PJM's current FRR
construct, which has been utilized by some vertically integrated states within the PJM footprint for years so that
utilities in these states can use their own preferred resources to serve capacity for all of the load in the utilities'
service territory rather than rely on the resource mix generated by PJM's capacity auction.

FERC's proposed "FRR Alternative" offers
the prospect of a more tailored approach
that would apply only to specific
resources and a commensurate amount
of load in order to preserve the PJM
capacity market while respecting state
policy choices.
Unlike the existing FRR construct, the FRR Alternative
only applies to specific identified resources and a commensurate portion of load. Load not allocated to specific
state-supported resources would continue to participate
in PJM’s capacity market. FERC's proposed "FRR Alternative" offers the prospect of a more tailored approach that
would apply only to specific resources and a commensurate amount of load in order to preserve the PJM capacity market while respecting state policy choices.

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

The FERC proceeding to establish this new capacity construct is still ongoing. The FERC conducted a 90-day
"paper hearing" process to establish the new capacity
market option, and is expected to issue an order in January 2019, just months before the 2019 Capacity Auction
(for the delivery year beginning June 2022).

Regulatory and/or legislative actions
may be necessary once FERC issues its
final order in early 2019 if Pennsylvania
desires to preserve its clean energy
resources programs prior to the 2019
PJM Capacity Auction.
Depending on FERC rules in its anticipated January 2019
order, States may soon need to reevaluate their clean energy programs to ensure they are compatible with PJM's
new capacity market rules and the new FRR Alternative.
Regulatory and/or legislative actions may be necessary
once FERC issues its final order in early 2019 if Pennsylvania desires to preserve its clean energy resources programs prior to the 2019 PJM Capacity Auction. As such,
Pennsylvania should begin exploring state-level procurement processes that would take advantage of the existing FRR construct, and possibly some form of the new
FRR Alternative, in preparation for the January issuance
of the FERC order.
The impact of PJM's long history of inaction and FERC's
ruling are far-reaching, and appears to leave Pennsylvania with four options:
1. Do nothing and leave Pennsylvania's clean energy
resources, including its nuclear plants, on a
trajectory to early retirement.
Taking no action, is in and of itself, a very deliberate
choice to allow Beaver Valley and TMI to prematurely
shut down, and to allow Pennsylvania's remaining nuclear fleet to eventually suffer the same financial challenges in an admittedly flawed marketplace.
Allowing any nuclear plant in the Commonwealth to
close would have significant consequences for fuel diversity, resiliency, the environment, customers, and the
state's economy. As abundantly supported in this report,
the value of nuclear energy is clearly evident. One need
only look at other states where nuclear plants have been

allowed to shut down - where decision-makers have
failed to act - to understand the consequences.
2. Modify AEPS (or establish a ZEC program) to put
nuclear generation on equal footing with other
zero-emission electric generation resources in
Pennsylvania.
The rationale behind this approach is simple – Pennsylvania, through AEPS, currently recognizes and compensates 16 sources of electric generation for their environmental attributes, but nuclear generation is not one
of them. A modification to AEPS to include nuclear generation or the establishment of a ZEC program would utilize a construct already in existence in Pennsylvania to
compensate nuclear generation for its environmental attribute, fairly put nuclear generation on similar footing as
other clean energy resources, and help ensure that the
continued benefits of these attributes are preserved for
the Commonwealth.
The potential outcome of the FERC proceeding, however,
puts at risk the long-term efficacy of a ZEC program or an
Alternative Energy Portfolio Standard (AEPS) modification as a stand-alone solution. Depending on the outcome of the FERC proceeding, starting as early as the
2019 capacity auction (for the delivery year starting June
2022), the support provided by any ZEC program or AEPS
will trigger a high minimum bid for clean generators in
the PJM capacity market, putting them at risk of not
clearing in the capacity auction.

Allowing any nuclear plant in the
Commonwealth to close would have
significant consequences for fuel
diversity, resiliency, the environment,
customers, and the state's economy.
This means that as early as 2019, AEPS and other statesupported resources may have to make a difficult choice
between participating in a state program like AEPS or
participating in PJM’s capacity market (where revenues
may not be sufficient to prevent them from retiring).
Consumers’ costs will increase significantly either way.
To avoid such an unhelpful outcome, the ZEC programs
and AEPS modifications must be used in combination
with the FRR Alternative, which brings us to the
next option.

Other State Actions   37

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

3. Modify AEPS (or Establish a ZEC Program) in
Combination with a “Safety Valve” Mechanism that
Would Allow a Transition to the FRR Alternative
Each state in PJM will need to have its own response or
approach to the final outcome of the FERC proceeding in
order to maintain its state policy priorities. As discussed
above, FERC has proposed the FRR Alternative as a
straightforward option to allow states to support and
maintain preferred resources for their desired attributes.
The FRR Alternative appears to be the tool recommended by FERC to allow Pennsylvania to provide a near
term solution for its nuclear fleet. If a final order from
FERC includes the FRR Alternative, it could be utilized either in combination with a revised AEPS/ZEC structure or
as a complete replacement.

If a final order from FERC includes the
FRR alternative, it could be utilized
either in combination with a revised
AEPS/ZEC structure or as a complete
replacement.
An additional option is for the Commonwealth to pursue
a phased approach to provide assistance to nuclear units
immediately and then transition to a longer-term program, such as a Pennsylvania carbon pricing regime. This
phased policy option would provide near-term assistance to nuclear plants, appears to be consistent with
the FERC order, and would allow a reasonable amount of
time to implement a carbon pricing program, leading us
to option #4.
4. Establish a state carbon fee program – the long
term solution
The Commonwealth could adopt a market solution
based on carbon emissions. The concept of putting a
price on carbon has broad and bi-partisan recognition as
the most efficient, effective, and market-based environmental policy solution.
Currently, damages and associated costs to society
caused by carbon pollution are largely not reflected in
the price of generating electricity.
Consequently, energy users do not pay the true cost for
electricity because the impacts of carbon emissions will

38   Other State Actions

be paid by
property
owners,
taxpayers,
and the
general
populace
in the form
of increased
health care
costs, insurance premiums and damages caused by climate
change.
Policy approaches that directly assign the costs of C02
pollution to C02 emitters will encourage emission
reductions.
At the same time, zero-emitting generators like nuclear
power are not subject to emission fees and become relatively more economical and thus perhaps delay or avoid
nuclear power plant retirements.
The Commonwealth could initiate a market-based carbon fee policy, aimed at reducing C02 emissions, either
unilaterally (through a Pennsylvania-specific cap and
trade program) or regionally (by joining the Regional
Greenhouse Gas Initiative "RGGI").
In either case, the carbon fee would need to be at least
an amount great enough to result in a meaningful improvement in the economics of the zero carbon generators in the Commonwealth.

Policy approaches that directly assign
the costs of C02 pollution to C02
emitters will encourage emission
reductions.
Another important issue is the concept of emissions
"leakage" which means the shifting of dispatch from covered generators within the carbon policy region to uncovered generators outside the policy region. (If gas
generation in Pennsylvania is replaced by gas generation
in Ohio, there will be a reduction in Pennsylvania emissions, but no overall emission reductions.)

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

In order to ensure that Pennsylvania resources are not
disadvantaged and the carbon fee policy operates effectively and results in actual emission reductions, the policy should include leakage mitigation. For example, PJM
has developed a virtual carbon price adder on imported
power to ensure that generators in a carbon policy region compete on a level field with generators from states
that have no carbon fee.

…carbon pricing is likely best viewed
as a long-term solution, with AEPS and
the FRR Alternative being the more
readily-available short term policy
solutions for the Commonwealth’s
nuclear generation plants.
Finally, the use of the collected fees should be considered. At a $15/ton price, the annual carbon fees for Pennsylvania would total roughly $1 billion per year. Typical
uses of carbon fees include: refunds to retail electric customers, energy efficiency programs, and general revenue
for the state.
A disadvantage of relying solely on a carbon fee policy is
that it may take too long to implement in a time frame
that would prevent the already planned early nuclear retirements. As such, carbon pricing is likely best viewed
as a long-term solution, with AEPS and the FRR Alternative being the more readily-available short term policy
solutions for the Commonwealth’s nuclear generation
plants.

Other State Actions   39

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

9. Other Considerations
Summary:
As the Nuclear Energy Caucus undertook its review of
the current challenges facing the nuclear power industry,
it became clear that a common theme across the issues
identified in this report is the lack of a coordinated structure to manage the many interconnected components of
state and national energy policy.

…we make long-term energy policy
decisions based only on what is cheap
today.
This short-sighted approach incentivizes
states to ignore the very real implications
of what is happening over the long-term,
and for nuclear assets, those choices are
irreversible.
For example, the current determining factor for whether
or not a Pennsylvania nuclear station remains online is
on short term marginal prices established through the
13 state PJM wholesale electric markets. Stated another
way, we make long-term energy policy decisions based
only on what is cheap today.
This short-sighted approach incentivizes states to ignore
the very real implications of what is happening over the
long-term, and for nuclear assets, those choices are
irreversible.
Success in achieving environmental goals, economic
goals, national and energy security goals, as well as
consumer goals cannot be accomplished without a
harmonized approach where all these vital issues are
appropriately considered, and compensated for, in
a market.
The inevitable result without such an approach will be a
disjointed, expensive and ineffective assortment of policies that, taken individually, will fail to maximize resources such as nuclear energy, which has many benefits
beyond the production of electrons.

40   Other Considerations

In short, how a power plant makes electricity matters,
and because a source happens to be the most economic
by price today does not necessarily mean it reflects all of
the other important policy goals the Commonwealth has
for its people.
Given the multi-jurisdictional nature of how Pennsylvania and other PJM states interact with PJM and FERC, and
in consideration of the many uniquely important goals
surrounding the production of electricity, the Nuclear
Energy Caucus recommends that the Commonwealth
consider creating, with existing resources, a cabinet-level
position to help coordinate and manage the various energy issues so that a more comprehensive view spanning
cross-disciplines (environmental, economic, consumer,
reliability and resiliency, energy and national security)
can be achieved.
Put another way, part of what has contributed to the
current situation is the lack of a coordinated, forwardthinking state energy policy that takes into account all
the issues involved in the production of electricity.
If Pennsylvania is to effectively use its power sector to
reduce emissions, promote economic prosperity, contribute to the national defense and ensure energy
security, and provide for long-term consumer price
stability, it must have policies that consider and value
all those attributes.

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

10. Conclusion
Conclusion:
Nuclear energy in Pennsylvania is at a crossroads.
The Commonwealth stands to lose a quarter of its nuclear power, to the detriment of its communities, economic standing, and environment. The Commonwealth
must avert further nuclear plant closures or suffer job
loss, community disruption, and higher electricity prices.

If the state does nothing, the pending
nuclear retirements will take place as
announced, and more closures may
follow.
Concurrently, the PJM electricity capacity market in
which Pennsylvania generation resources participate is
changing in 2019 due to a late June order from the FERC.
Pennsylvania, like other states in the PJM market, will
need to craft a response if it is to maintain state energy
policy priorities rather than having those priorities undermined by the coming changes.
If the state does nothing, the pending nuclear retirements will take place as announced, and more closures
may follow.
We think there is a better path forward which will preserve the nuclear industry in the Commonwealth.
In the process of our hearings on Pennsylvania nuclear
energy, the members of the Nuclear Energy Caucus
attained an expanded knowledge of PJM’s electricity
markets. As such, while we do not claim to be experts,
we are positioned to educate and assist our colleagues
in the legislature as we collectively consider the state’s
response to FERC’s order on mitigating state policy
impacts in PJM’s capacity market.
The actions needed to retain nuclear plants can be taken
in tandem with the Commonwealth’s response, needed
in any case, to the FERC order. The FRR Alternative provided to the states by the FERC, may be just the solution
that we need to tailor Pennsylvania’s energy future to
Pennsylvanians’ values and priorities, including the important role of nuclear energy in that future.

Conclusion   41

 Bicameral Nuclear Energy Caucus Report   2017-2018 Session

11. Acknowledgements
The Nuclear Energy Caucus wishes to thank all the testifiers, organizations, advocacy groups, businesses and
industries that provided their expertise and technical
guidance throughout this fact-finding mission.

…the caucus would like to acknowledge
and thank the hard-working men and
women who every day go to work in one
of the Commonwealth’s five nuclear
stations and who provide such an
incredible value to Pennsylvania by
safely producing electricity in an
environmentally responsible manner to
meet our 21st century energy needs.
Most importantly, the caucus would like to acknowledge
and thank the hard-working men and women who every
day go to work in one of the Commonwealth’s five nuclear stations and who provide such an incredible value
to Pennsylvania by safely producing electricity in an
environmentally responsible manner to meet our 21st
century energy needs.
And to the people of Pennsylvania, the caucus would like
to thank you for your patience as we sought to understand a very complex – but incredibly important – issue.

Our effort was solely on your behalf
– so that you can have economic
prosperity, energy security, long-term
price stability, clean air and all of the
associated benefits that are derived from
the highest performing, most reliable
forms of energy production in our state
and nation – nuclear power.
Our effort was solely on your behalf – so that you can
have economic prosperity, energy security, long-term
price stability, clean air and all of the associated benefits
that are derived from the highest performing, most reliable forms of energy production in our state and nation
– nuclear power.

42   Acknowledgements

 Bicameral Nuclear
Energy Caucus
Senator Ryan P. Aument
District 36
Senate Box 203036
Harrisburg, PA 17120-3036
(717) 787-4420

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Bicameral
Nuclear Energy
Caucus Report
2017-2018 Session

Senator John T. Yudichak
District 14
Senate Box 203014
Harrisburg, PA 17120-3014
(717) 787-7105

Representative Becky Corbin
District 155
PO Box 202155
Harrisburg, PA 17120-2155
(717) 783-2520

Representative Robert F. Matzie
District 16
PO Box 202016
Harrisburg, PA 17120-2016
(717) 787-4444

Co-Chairs
Senator Ryan P. Aument
Senator John T. Yudichak
Representative Becky Corbin
Representative Robert F. Matzie