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Mass Acquisition Of Early Site Permits For Coal-To-Nuclear Repowering

December 14, 2023

This report proposes an approach to assist with repowering existing fossil fuel sites, with higherpriority given to those sites en route to retirement. The approach leverages proactive planningand policy formulation, promoting revitalization without exclusively focusing on climate changeconcerns. In pursuit of clean energy alternatives, nuclear energy emerges as a prominent candidateto replace baseload energy from fossil fuels. As the imperative for low-carbon energy technologiesgains momentum, the opportunity to reconfigure carbon-intensive power generation sourcesnecessitates action beyond a “no-action” stance.

The coal-to-nuclear repowering (C2N) approach proposes to replace retiring coal-fired power plants(CPPs) with advanced nuclear reactors, utilizing viable existing infrastructure for power generationand transmission. This initiative aligns technological, social, and economic considerations, presenting a comprehensive response. However, the current barrier hindering implementation of thisinitiative is regulatory uncertainty.

Presently, legacy regulatory processes create friction rather than incentive for CPP owners considering engaging in C2N repowering projects. A key challenge is the regulatory process to acquire earlysite permits (ESPs). The current ESP pathway is lengthy and costly, which may discourage developersdue to uncertainties and prolonged timelines. This report addresses this challenge and proposes astreamlined approach.

The Breakthrough Institute proposes a U.S. Department of Energy (DOE)-led program aimed at alleviating regulatory uncertainty. This program would assess retiring CPP sites nationwide, categorizingand prioritizing them based on local need for power, remediation, viability of existing infrastructure, and demand for workforce transition. Under the Energy Policy Act of 2005, the DOE can applyfor an ESP to conduct site-specific evaluations of a location with potential for a nuclear power plantbefore the actual construction and operation of the facility begin. This process allows the DOE toassess the suitability of the site and address any potential safety and environmental concerns inadvance. The proposed program targets eligible sites with transferable workforces and essentialinfrastructure, helping to facilitate a seamless transition for C2N projects. In the proposed program,the DOE’s role will be to mass-acquire ESPs for multiple eligible C2N sites and subsequently to transfer those permits to utility companies and developers to recover the costs.

The program presents a strategic solution to catalyze but not to own the repowering of fossil fuelsites through regulatory innovation. By mitigating regulatory uncertainties and leveraging existingresources, the proposed program will propel the transition towards cleaner and sustainable energysources, addressing the imminent challenges of energy transition and environmental preservation.

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