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Comprehensive Energy Strategy 2017 Needs to be Revised and Reconsidered

Dear Ladies and Gentlemen:

Herewith follow comments by the Connecticut Coalition Against Millstone, which I direct, responding to the draft Comprehensive Energy Strategy 2017 (CES 2017) regarding electricity generation.

(1) The CES misses the boat on clean, green sustainable energy. With wind plentiful off the Connecticut coast, it is shameful that it has not been tapped to replace Millstone and no plans are in place to realize this opportunity. The same goes for wave energy, which in a recent storm event carried off tons of cubic yards of Millstone shoreline, leaving the nuclear site even more exposed to flooding and devastation. Many critical Millstone nuclear components are located in FEMA-identified flood zones and the trend is for accelerating expansion of such zones which could isolate the nuclear station in an emergency, leading to catastrophe. The 500-acre site could easily be converted to a solar/wind/wave energy park but CES has not considered this possibility.

(2) The CES continued reliance on nuclear energy produced at the Millstone nuclear power station is dangerous and dirty and completely unmindful of the operational history of this nuclear power station under its former and current owners (committing federal felonies regarding toxic waste discharges to the Long Island Sound, retaliating against whistleblowers, deliberately disabling its perimeter security system to save costs, creating record discharges of radioactive emissions to the air and water, defying the U.S. Department of Homeland Security directive after September 1, 2001 to install a taxpayer-funded floating barrier to protect the intake structures from catastrophic terrorism, producing ever-increasing tonnage of high-level radioactive waste for which there is no storage solution by means of repeated power “up-rates,” being among only a few of the nastier highlights). Indeed, shortly after September 11, 2001, U.S. Homeland Security identified Millstone as Connecticut’s Number One most dangerous terrorism target. Continued reliance on Millstone electricity defeats the CES goals of achieving clean air, clean water and reliability and security.

(3) Millstone’s production of nuclear energy is not carbon-free. First, such a designation disregards the extraordinary production of greenhouse gases in all the fuel extraction, processing and transport preceding fission at the nuclear station. Equally important, the designation disregards the fact that radioactive carbon-14 – routinely produced and emitted by Millstone round-the-clock to our air and water – is a greenhouse gas.

(4) Permitting Millstone to continue operating defeats the CES goal of increasing energy security. Millstone holds the near-record for SCRAMs – unplanned sudden shutdowns due to equipment malfunctions and/or human error. So many times have we been spared by sheer luck! The next time we may not be so lucky. A Millstone meltdown would be a Northeast-USA-corridor economic, not to mention social and cultural and environmental, meltdown the likes of which has never been seen. Do keep in mind: WINDMILLS DON’T MELT DOWN.

It’s time to bury the “too cheap to meter” nuclear myth and put Millstone to mothballs.

The CES needs to be revised and reconsidered so that more than lip service is paid to the phrases “energy security,” “clean air,” “clean water,” “waste reduction goals.”

Thank you for your attention to these concerns.