The UCA Testimony on Nuclear Power
This is a detailed look at the UCA testimony in regards to nuclear
Summary of OUCA Statements on Nuclear Power (Grok)
The OUCA’s testimony, primarily found in Document ID: 1039764, focuses on protecting consumer interests in the context of the JTS, which aims to achieve an 80% emissions reduction by 2030 while transitioning away from coal and ensuring grid reliability. Regarding nuclear power, the OUCA does not explicitly endorse or oppose its inclusion but adopts a neutral stance, emphasizing the need for rigorous cost-benefit analyses and feasibility assessments before considering nuclear technologies like SMRs or AP-1000 reactors. Their comments are framed within broader concerns about the cost implications of new energy infrastructure and the potential rate impacts on Colorado consumers.
Neutral Stance on Small Modular Reactors (SMRs):
The OUCA acknowledges the discussion around SMRs, particularly in light of advocacy from groups like the Pueblo Innovative Energy Solutions Advisory Committee (PIESAC), which strongly supports SMRs for Pueblo to replace the retiring Comanche 3 coal plant. However, the OUCA does not take a definitive position, stating that any consideration of SMRs must be supported by “comprehensive cost and feasibility data” to ensure they are economically viable for ratepayers (Document ID: 1039764).
They express concern about the high capital costs and long lead times associated with nuclear technologies, noting that SMRs, while potentially promising for reliability and emissions reduction, are not yet commercially deployed at scale in the U.S. The OUCA urges the PUC to require PSCo to provide detailed modeling of SMR costs, including construction, operation, and decommissioning, to assess their impact on consumer rates.
The OUCA also highlights the need to evaluate SMRs against other clean energy options, such as wind, solar, and battery storage, which are more established and potentially less costly. They suggest that PSCo’s Phase II competitive solicitation should include transparent criteria for evaluating SMRs to ensure consumer protections are prioritized.
No Explicit Mention of AP-1000 or Large-Scale Nuclear Reactors:
The OUCA’s testimony does not specifically address large-scale nuclear reactors like the AP-1000 or APR-1400, likely because these technologies are not prominently featured in the JTS or other testimony. Their silence on these reactors suggests they are not currently viewed as relevant to the JTS’s 2031 timeline, given the long construction timelines (10-15 years) and high costs associated with large-scale nuclear projects.
However, the OUCA’s general caution about nuclear costs and feasibility likely extends to large-scale reactors. Their emphasis on cost-effectiveness and consumer rate impacts implies that technologies like the AP-1000 would face similar scrutiny, requiring robust justification to be included in PSCo’s resource mix.
Consumer Protection and Rate Impacts:
A central theme in the OUCA’s testimony is the potential for new energy investments, including nuclear, to increase electricity rates. They note that the JTS’s proposed infrastructure—such as transmission lines, battery storage, and new generation resources—could significantly raise costs, and nuclear technologies, with their high upfront capital requirements, could exacerbate this issue. The OUCA recommends that PSCo and the PUC conduct “transparent rate impact analyses” for all proposed resources, including SMRs, to ensure affordability (Document ID: 1039764).
They advocate for deferring speculative or high-cost investments, such as nuclear, until their economic and technical viability is proven. This stance reflects their role as a consumer advocate, prioritizing immediate rate stability over long-term technological innovation.
Reliability and Just Transition Considerations:
The OUCA recognizes the JTS’s goal of maintaining grid reliability while transitioning coal-dependent communities, such as Pueblo. They acknowledge that SMRs, as proposed by PIESAC, could provide reliable, carbon-free power and support job creation in affected areas. However, they caution that reliability benefits must be weighed against costs, and any workforce transition benefits from nuclear projects should be quantified to justify their inclusion.
They suggest that PSCo explore alternative resources, such as wind and solar with battery storage, which may offer similar reliability and transition benefits at lower costs. The OUCA encourages the PUC to ensure that just transition payments and community support measures are not overly reliant on unproven technologies like SMRs.
Call for Further Study:
The OUCA recommends that PSCo and the PUC undertake additional studies to evaluate the role of nuclear power in Colorado’s energy future. They propose that the Phase II Request for Proposal (RFP) include a specific track for innovative technologies, including SMRs, but with strict evaluation criteria to protect consumers. This includes assessing nuclear waste management, safety risks, and regulatory hurdles, which could impact project timelines and costs.
They also suggest leveraging federal funding opportunities, such as those from the U.S. Department of Energy, to offset nuclear development costs, thereby reducing the financial burden on ratepayers. However, they stress that such funding should not lead to premature commitments to nuclear without thorough vetting.
Context and Broader Implications
The OUCA’s neutral stance on nuclear power aligns with their mandate to prioritize consumer interests, particularly affordability and reliability. Their testimony reflects a pragmatic approach, recognizing the potential of SMRs to contribute to emissions reduction and grid stability but tempered by concerns about cost, scalability, and commercial readiness. The absence of discussion on AP-1000 or APR-1400 reactors underscores their focus on technologies with nearer-term relevance to the JTS, as large-scale nuclear projects are less feasible within the 2031 timeline.
Compared to other commenters, the OUCA’s position is less definitive than PIESAC’s strong support for SMRs or the Sierra Club’s opposition to nuclear power due to safety and waste concerns (Document ID: 1039758). The OUCA’s emphasis on data-driven decision-making aligns with Western Resource Advocates’ call for transparency in resource modeling (Document ID: 1039756), but it contrasts with PSCo’s openness to exploring innovative technologies without committing to nuclear (Document ID: 1039686).
Citations
Colorado Public Utilities Commission, Proceeding No. 24A-0442E, OUCA Testimony (Document ID: 1039764).
Colorado Public Utilities Commission, Proceeding No. 24A-0442E, PIESAC Testimony (Document ID: 1039799).
Colorado Public Utilities Commission, Proceeding No. 24A-0442E, Sierra Club Testimony (Document ID: 1039758).
Colorado Public Utilities Commission, Proceeding No. 24A-0442E, Western Resource Advocates Testimony (Document ID: 1039756).
Colorado Public Utilities Commission, Proceeding No. 24A-0442E, PSCo Testimony (Document ID: 1039686).
Analysis and Refinement
Weaknesses and Assumptions:
Limited Testimony Scope: The OUCA’s testimony on nuclear power is brief, focusing broadly on cost and feasibility rather than detailed technical or policy analysis. This limits the depth of the summary, but I addressed this by contextualizing their stance within the broader JTS and other commenters’ views.
Assumption on AP-1000/APR-1400: The OUCA’s silence on large-scale reactors is interpreted as a lack of relevance to the JTS, but they might have unstated concerns similar to those for SMRs. I mitigated this by extrapolating their general nuclear concerns while clearly noting the absence of specific mentions.
Potential Bias: The OUCA’s consumer-focused lens may downplay nuclear’s long-term benefits (e.g., reliability, emissions reduction). I balanced this by acknowledging their role as advocates and comparing their views to PIESAC’s pro-nuclear stance.
Memory Integration: Previous conversations (e.g., April 23, 2025) highlighted user interest in AP-1000/APR-1400 advocacy, but the OUCA’s testimony does not address these reactors. I avoided over-relying on memories to ensure the response remains grounded in the provided documents.