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Regular Meeting – Nov 21, 2022

November 21, 2022 8:30 am 10:30 am

Logos for NEI & NuScale

Representatives of the Nuclear Energy Institution and NuScale Power, a small modular reactor (SMR) manufacturer, presented to the commission. We also took comments from members of the public and took care of other business.

<< Previous meeting – Oct 11, 2022     Next meeting – Dec 12, 2022 >>


Meeting video transcript

Meeting minutes (APPROVED) PDF

Nuclear Energy Institute presentation slide deck

NuScale Power presentation slide deck


Meeting Date/Time. Monday, November 21, 2022 @ 8:30 AM to 10:30 AM EST

Venue. NH Department of Environmental Services, Room 208C, 29 Hazen Drive, Concord, NH 03301

Quorum requirement. We require six (6) commission members in attendance to have a quorum.

Remote access. Commission members are encouraged to attend in-person. Guests and members of the public are invited to attend either in-person or via Zoom using this link: https://us02web.zoom.us/j/85100318781.

91A notice. Group email communications constituting a quorum of commission members are subject to 91A requests. Please email the Chair directly to communicate with the group.

Agenda Items

  1. Need substitute Clerk
  2. Introductions of commission members, as needed
  3. Approve minutes of the Oct 11 meeting
  4. Public input, pass sign-in sheet
  5. Presentation – 30 minutes plus Q&A
    Nuclear Energy Institute
    Marc Nichol, Senior Director of New Reactors. Link to his presentation.
    1. Status of the technology
    2. Commercial deployments
    3. Other major topics related to advanced reactors
    4. Interfacing with the federal government
  6. Presentation – 30 minutes plus Q&A
    NuScale Power
    Chris Colbert, Chief Financial Officer. Link to his presentation.

    Read his bio here.
  7. Discussion of Report due December 1, 2022.
    1. Describe business of commission to-date
    2. Describe commissions outlook for next 6 months
    3. Discussion of references to nuclear energy in the recently updated NH DOE 10-year energy strategy (see notes below).
    4. Rep Doug Thomas’ bill idea
  8. Public Input
  9. Decide on next meeting
    1. Should we book the room on a regular schedule?
  10. Action Items
  11. Adjournment


NEI Resources

Duties of the Commission

Reports to Issue

Official State Government Website for this Commission

NH Department of Energy’s State Energy Strategy Document

Notable References to Nuclear Energy.

  1. Page 10 – Nuclear Power It is essential that New Hampshire’s energy strategy recognize the many attributes of nuclear power and its role in the New England grid so that its economic lifespan is not artificially shortened by state or regional policy decisions. In the near term, it is likely that New England’s carbon emissions would increase significantly if the plant were to stop generating. Preserving Seabrook Station as a source of zero-carbon electricity generation is the most realistic and cost-effective means of managing emissions in New Hampshire at scale. Nuclear generation should be allowed to compete fairly and without unwarranted constraints in New England’s wholesale markets thereby contributing to a market-driven, cost-effective resource important to New Hampshire’s environmental goals and policy frameworks.

  2. Page 41-42 – Seabrook Station is the largest electricity generating asset in New Hampshire. With 1,250 MW of generating capacity, the nuclear plant produced more than 56% of all electricity generated in New Hampshire in 2021, and it is one of two nuclear plants in New England, which together supply 26% of the region’s electricity. It is essential that New Hampshire’s energy strategy recognize the many attributes of nuclear power and its role in the regional grid. Seabrook Station produces the majority of our state’s electricity and it has a significant impact on the local and state economy,68 it delivers zero-carbon electricity into New England’s grid, and the stability of production—it has what is known as a high capacity factor—is valuable for regional operations , especially during high peak periods in the summer and winter.69 Given these realities, nuclear generation should be allowed to compete fairly and without unwarranted constraints in New England’s wholesale markets thereby contributing to a market-driven, cost-effective resource important to New Hampshire’s environmental goals and policy framework. With regard to emissions, wholesale markets currently lack a mechanism to value nuclear power’s carbon free attributes.70 It is likely that New England’s carbon emissions would increase significantly if Seabrook Station were to stop generating. For example, after several years of falling emissions, the closure of the Vermont Yankee nuclear plant was a driving cause in carbon dioxide emissions increasing 7% regionally in 2015.71 Other states in the region with nuclear plant closures have seen their carbon emissions increase in recent years.72 It is worth noting that nuclear power also avoids the emission of nitrous oxides (NOx), sulfur oxides (SOx) and fine particulates, all of which are emitted from fossil fuel fired generation plants. The Civil Nuclear Credit Program, created under the IIJA, will assist existing nuclear reactors that are at risk of closing or being replaced by higher-emitting power resources.73 This program represents a federal recognition that nuclear power remains an important part in achieving carbon reduction goals. There are no cost-effective or practical solutions to cover current nuclear power generation capacity with other zero-carbon assets, at this time, though special emission credits have been created elsewhere such as New York when, in 2016, the New York Public Service Commission created the ZEC (zero emissions credit), the first of its kind to recognize the emissions avoided by nuclear generation. Seabrook Station has a capacity factor of 90%. This is an essential fact impacting grid management and planning. As such, there is value in factoring nuclear generation’s zero-carbon emission product into state efforts to manage emissions and recognizing Seabrook Station as a source of zero-carbon electricity production is an important aspect of those efforts. New reactor construction is often not economically viable in current conditions, although there may be opportunities in the future related to innovations with small modular reactors and the recognition in other states about the role nuclear generation can play in replacing retiring fossil fuel assets. Currently however, there is significant value to New Hampshire and the regional electricity supply in maintaining Seabrook’s generating capacity. Nuclear generation should be allowed to compete to deliver electricity into competitive wholesale markets and should also be recognized as a component in New Hampshire’s environmental goals and policy frameworks. What is clear is that nuclear power still has a significant place in today’s energy markets and that the future of nuclear power will depend on newer technologies and much needed research and development. New Hampshire should continue to review and study what innovative nuclear technologies develop over time.
  3. Pages 54-56 – Renewable Portfolio Standard. The RPS was established in 2007 as a tool to increase the use of renewable energy for producing electricity and to protect and enhance fuel diversity. The RPS requires electric service providers, including distribution utilities and competitive suppliers, to acquire a certain percentage of supply from renewable energy sources. In total, the 2021 RPS mandate calls for 21.6% of electricity sold to retail electric customers to be generated by renewable energy sources, with a goal of 25.2% by 2025. Under the New Hampshire RPS structure, applicable renewable energy sources are organized into four classes:
      1. Class I: New (after 2008): wind; hydrogen derived from biomass fuel, water or methane gas; ocean thermal, wave or tidal energy; methane gas; or biomass. Thermal energy from biomass, solar, and ground source heat pumps (geothermal) was recently added to this class.
      2. Class II: New solar electric (PV) generation.
      3. Class III: Existing biomass or methane facilities that meet air emission criteria.
      4. Class IV: Existing small hydroelectric facilities that meet fish passageway criteria.

Service providers have three options for satisfying RPS requirements:

    1. Purchase Renewable Energy Credits (RECs) from eligible projects, 1 REC equals 1 MWh;
    2. Make an Alternative Compliance Payment (ACP), the amounts of which are set by statute;
    3. In certain situations, directly invest in eligible renewable projects (such as through RSA 374‐G).

The RPS framework depends on mandates that segment renewable technologies from each other and from the broader wholesale electricity market. Achievement of the goals underpinning the establishment of the RPS therefore necessitates administrative selection of technology types that will be afforded varying degrees of protection from market pressures. This reality runs the risk of favoritism, inefficiency, and a constant tension among RPS-eligible resources for relative benefit.

In addition to fuel diversity, a prominent goal of the 2007 RPS statute is “employing low emission forms of such technologies [as] can reduce the amount of greenhouse gases, nitrogen oxides, and particulate matter emissions transported into New Hampshire and also generated in the state….”117 If reducing carbon emissions is a primary objective, then in order to have conceptual consistency, the RPS must include other zero-carbon or low-carbon resources. Additionally, while in tension with the goal of fuel diversity, the pursuit of emissions reductions would justify breaking down artificial barriers between classes that restrict competition. If the goal is to pursue the most cost-effective low-carbon options, then “siloing” energy technology types thwarts that outcome.

In current statute, the RPS excludes nuclear power under the assumption that it is not a renewable fuel. This is correct under a mechanistic definition where “renewable” means an energy source/fuel type that can regenerate and can replenish itself indefinitely. However, it is somewhat artificial to draw a distinction between a fuel that can replenish itself indefinitely even where there may be significant resource and environmental impact to capture the energy in that fuel. Solar panels, wind turbines, biomass plants, methane gas, thermal infrastructure, and hydroelectric dams all require non-renewable material to capture the value of their associated fuel type. Many renewable technologies depend on acquiring scarce resources, and the interruption of supplies limits production. Additionally, production of the material for, and construction of the sites themselves for all these infrastructure types has natural resource and environmental impacts. An indefinitely replenishable fuel is only one component of sustainable electricity production. Achieving the more concrete RPS goal of emissions reductions would be better served by making eligible zero-carbon resources that are currently excluded.

In summary, segmentation of the RPS that limits competition among generation technology types should be eliminated over time. The RPS should be evaluated as to whether it should be expanded to include other zero-carbon resources and to pursue the most cost-effective low-carbon options.


November 21, 2022
8:30 am – 10:30 am
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Keith Ammon

NH Department of Environmental Services, Room 208C

29 Hazen Drive
Concord, NH 03301 United States
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